PPWR guide: the EU Packaging Regulation explained for brands

The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, is the EU law for all packaging placed on the EU market, whatever the material and wherever it was made. It replaced the Packaging Directive 94/62/EC and applies since August 12, 2026. As a regulation, it applies the same way in every EU country without national transposition.

No. It applies since August 12, 2026, and no act postpones it. The Commission's December 2025 simplification package proposed one change, COM(2025) 982, which would suspend the rule on appointing an authorized representative for extended producer responsibility (Article 45(3)); as of September 2026 it had not been adopted. Actions for annulment pending before the EU General Court don't suspend the regulation either. What has slipped are some implementing acts, which moves the dates that depend on them, such as the harmonized label.

The company that manufactures packaging or a packaged product, or has it designed or manufactured under its own name or trademark (Article 3(1)(13)). The Commission's guidance says there is only one manufacturer per packaging, and the owner of the name or trademark on it can be assumed to be that manufacturer. So a brand is usually the manufacturer of its own packaging, even when a supplier makes it. Importers and distributors who put packaging on the market under their own name become manufacturers too (Article 21).

Partly. If the company with the packaging under its name is a micro-enterprise (fewer than 10 people and at most €2 million turnover or balance sheet) and its packaging supplier is in the same EU country, that supplier is the manufacturer instead (Article 3(1)(13)(b)). Micro-enterprises also have exemptions from some re-use targets and format restrictions.

Annex VIII sets eight points: the packaging's unique identification, the manufacturer's name and address, a statement of sole responsibility, a description of the packaging, the legislation it conforms to, the standards or specifications used, the notified body (not applicable for internal production control) and additional information, followed by the place, date and signature. It must be in the language required by each EU country where the packaging is sold (Article 39(2)).

Packaging will carry a harmonized label showing its material composition to help consumers sort it (Article 12), from August 12, 2028 or 24 months after the implementing act that sets the label, whichever is later. Reusable packaging will carry a QR code or another data carrier with information on re-use.

For plastic packaging, from 2030: 30% recycled content for contact-sensitive PET packaging, 10% for other contact-sensitive plastic packaging, 30% for single-use plastic beverage bottles and 35% for other plastic packaging. The targets rise in 2040, up to 65% for single-use beverage bottles and other plastic packaging (Article 7).

No, but it includes it. Extended producer responsibility (EPR) is the obligation to register with each country's producer register and pay for the packaging waste you place on its market. The PPWR harmonizes those EPR rules across the EU, alongside the design and declaration rules for the packaging itself.