PPWR Is Now Law: Act Now to Ensure EU Market Access

14. May 2025

9 minutes

Deutsche Recycling editorial team

The new EU Packaging and Packaging Waste Regulation (PPWR) is officially in force. With an 18-month transition period now active, companies must adapt their packaging strategies immediately to avoid sales disruptions and fines.

For Quick Readers

  • The PPWR is now EU law, and a strict 18-month transition period is active, requiring full compliance by August 2026.
  • All companies selling packaged goods in the EU are affected and must meet new targets for recyclability, recycled content, and reuse.
  • Immediate action is required to avoid significant fines and the risk of having products barred from the EU market.

PPWR Is Now Law: Act Now to Ensure EU Market Access

The EU’s new Packaging and Packaging Waste Regulation (PPWR) became law on February 11, 2025, initiating a critical 18-month transition period for all companies operating within the EU market. This regulation replaces the previous directive and establishes legally binding targets for every member state, impacting any business that manufactures, imports, or sells packaged goods. The rules demand significant changes in packaging design, material sourcing, and waste management, with non-compliance posing a direct threat to market access. For companies that have not yet prepared, the time to take decisive action is now. Deutsche Recycling provides the expert guidance and full-service solutions needed to navigate these complex requirements and ensure 100% legal conformity.

The Packaging and Packaging Waste Regulation (PPWR) was officially adopted by the EU Council in late 2024 and entered into force on February 11, 2025. This marks the start of a strict 18-month transition period, making the new rules fully applicable by August 12, 2026. Unlike a directive, this regulation applies directly in all 27 EU member states without needing national laws, creating a single, harmonized legal framework. The primary goal is to reduce per-capita packaging waste by 5% by 2030, 10% by 2035, and 15% by 2040, using 2018 levels as the benchmark. For businesses, this means the theoretical preparation phase is over; immediate implementation is required. These new regulations, which you can read about in our PPWR explanation, demand urgent attention to avoid future penalties. The next sections detail exactly who is affected and what changes are necessary.

The Clock Is Ticking: Understanding the PPWR’s Current Status

The PPWR applies to all companies placing packaging on the EU market, regardless of their location. This includes manufacturers, importers, distributors, and online retailers sending goods cross-border into the EU. The regulation reinforces the principle of Extended Producer Responsibility (EPR), making producers financially and operationally responsible for the entire lifecycle of their packaging. This means if you sell to customers in the EU, you must comply with these rules. A key change is the requirement to appoint a single authorized representative for EPR in each EU country where you operate. This requirement alone adds a significant administrative layer for businesses that have not yet established a compliance framework. Understanding your role is the first step toward action. Our experts can help you determine your specific obligations under the new PPWR rules.

Are You Affected? Identifying Your Obligations Under the New Law

The PPWR introduces stringent, non-negotiable targets for packaging design and material composition. By 2030, all packaging on the EU market must be designed for recycling. The EU will implement a grading system, and by 2038, only packaging achieving the top two grades (A or B) will be permitted. Furthermore, the regulation sets specific minimums for post-consumer recycled (PCR) content in new plastic packaging. For instance, by 2030, single-use plastic beverage bottles must contain at least 30% recycled content, a figure that rises to 65% by 2040. Other plastic packaging has targets ranging from 10% to 35% by 2030. These rules require immediate adjustments to supply chains and product design. You can learn more about the PPWR recycled content requirements on our blog. These material changes are coupled with new reuse quotas.

Mandatory Changes: Recyclability and Recycled Content Targets

In addition to recycling, the PPWR actively promotes reuse to reduce overall waste generation. The regulation sets binding reuse targets for various sectors. For example, by 2030, companies in the beverage sector must offer at least 10% of their products in reusable packaging systems. For transport packaging used in business-to-business transactions within the EU, reuse is set to become the standard. The target for reusable transport packaging is 40% by 2030. The regulation also mandates that by January 1, 2029, nearly all EU member states must establish deposit-return systems for single-use plastic bottles and metal beverage containers up to 3 liters. This shift requires businesses to develop or participate in new logistics and return systems, a complex operational challenge. Exploring these new packaging regulations is critical for planning. These logistical changes are as important as the new labeling rules.

The Shift to Reuse: New Quotas and System Requirements

To empower consumers and streamline recycling, the PPWR mandates harmonized labeling across the EU. New labels will clearly indicate material composition and provide sorting instructions. Additionally, a QR code will be required on reusable packaging to facilitate its return and reuse. The regulation also takes a firm stance against excessive packaging. A key provision taking effect in 2030 is the introduction of a maximum 50% empty space ratio for transport and e-commerce packaging. This rule targets oversized boxes and unnecessary void-fill materials. Certain single-use plastic formats, such as those for small fresh produce or miniature hotel toiletries, will be banned entirely from 2030. These labeling requirements are another critical compliance point that requires immediate action.

Harmonized Labeling and Waste Prevention Rules

Ignoring the PPWR is not an option and carries severe business risks. Companies failing to comply by the August 2026 deadline face significant penalties, which will be determined by individual member states but are expected to be substantial enough to ensure enforcement. Beyond fines, the greatest risk is the disruption of market access. Non-compliant packaging can be barred from sale in the entire EU, effectively halting business operations for affected product lines. The principle of Extended Producer Responsibility means authorities will hold producers directly accountable. The financial and reputational damage from non-compliance could be immense, far outweighing the investment in a proactive compliance strategy. The complexity of these rules makes expert guidance essential.

The Cost of Inaction: Risks and Penalties

The transition to PPWR compliance requires a clear strategy, and waiting is no longer a viable strategy. Deutsche Recycling offers a comprehensive EPR Full-Service solution to manage all your obligations under the new regulation. We handle everything from registering your company and appointing legal representatives to managing data reporting and ensuring your packaging meets all design and labeling requirements. Our team of experts stays current on every regulatory update, guaranteeing you 100% legal conformity across all 27 EU member states. We simplify the complexity, allowing you to focus on your core business without risking costly penalties or sales interruptions. The preliminary agreement has now become law, and the time to act is now. Do not delay your compliance journey any longer.

Your Action Plan: How Deutsche Recycling Ensures Compliance

The PPWR is a fundamental shift in EU environmental policy, and its requirements are extensive and complex. With the 18-month transition period already underway, every day of inaction increases your risk. You must ensure your business is fully compliant by mid-2026 to continue operating in the European Union. The necessary changes to packaging, logistics, and reporting systems require time to implement correctly. We strongly urge every affected company, especially those that have not yet started their compliance process, to take immediate steps. Contact Deutsche Recycling today for a professional consultation. Our experts will analyze your specific situation and provide a clear, actionable roadmap to ensure you meet every PPWR requirement swiftly and efficiently. Secure your market access and achieve full legal compliance by partnering with us.

Take Action Now to Secure Your Business Future

FAQ

When do I need to be compliant with the PPWR?

The regulation is already in force. All requirements must be fully implemented by the end of the 18-month transition period, which is August 12, 2026. Action must be taken now to meet this deadline.

My company is not based in the EU, but we sell online to EU customers. Does the PPWR apply to us?

Yes, absolutely. The PPWR applies to any company placing packaged goods on the EU market, including cross-border e-commerce sales. You are required to comply with all EPR obligations.

What is the easiest way to ensure my business complies with the PPWR?

The most effective way to ensure 100% compliance is to partner with a specialist service provider. Deutsche Recycling offers a full-service solution that manages all aspects of your EPR and PPWR obligations, from registration to reporting, across all EU member states. Contact us immediately to get started.

What are the new recycled content targets for plastic packaging?

By 2030, the targets vary by packaging type. For example, single-use plastic beverage bottles must have 30% recycled content, while other contact-sensitive packaging made from PET also requires 30%. These targets increase significantly by 2040.

What does ‘designed for recycling’ mean under the PPWR?

By 2030, all packaging must be designed to be recycled in an economically viable way. The EU will establish specific design criteria and a grading system (A-E). By 2038, only packaging that achieves a high recyclability score (Grades A or B) will be allowed on the market.

I have not taken any action yet. Is it too late?

It is not too late, but you must act without any further delay. The compliance deadline is absolute. We strongly advise you to contact Deutsche Recycling now for an urgent consultation to begin the compliance process immediately.

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