PPWR – Regulation (EU) 2025/40 on Packaging and Packaging Waste
- Daniel Jiménez
- 3 days ago
- 4 min read
The European Union has adopted Regulation (EU) 2025/40 on packaging and packaging waste, also known as the Packaging and Packaging Waste Regulation (PPWR).
This new regulation represents one of the most significant changes to the European regulatory framework for packaging. Its objective is to reduce packaging waste, improve recyclability, promote the use of recycled materials, and ensure that packaging placed on the EU market complies with stricter environmental and documentation requirements.
The PPWR entered into force in 2025 and will generally apply from 12 August 2026. From that date, companies placing packaged products on the EU market will need to ensure that their packaging complies with the applicable requirements.
For many companies, this will require a detailed review of their current packaging, technical documentation, and supply chain information.
Table of Contents
Scope of the Regulation
The PPWR applies to packaging placed on the European Union market and to packaging waste, regardless of the type of material used.
This includes primary packaging, secondary packaging, and transport packaging used for products sold in the EU.
In practice, the regulation affects packaging used for a wide range of consumer products, including products manufactured within the EU and products imported from third countries.
The PPWR introduces obligations relating to, among other things:
Packaging design
Packaging minimisation
Recyclability
Substances of concern
Labelling and consumer information
Extended Producer Responsibility (EPR)
Declaration of Conformity
As a result, packaging compliance will become an essential part of the regulatory strategy for companies selling products in Europe.
Main Products Affected
The PPWR will affect a wide range of sectors and product categories, including:
Cosmetic products
Food supplements
Detergents
Home care products
Chemical mixtures
General consumer goods
It will also become a regulatory requirement linked to product placement on the market, documentation control, and supply chain responsibility.
Products or Situations Requiring Specific Assessment
Some products, sectors, or types of packaging, such as medical devices or pharmaceuticals, may be subject to specific rules, derogations, or additional requirements under other EU legislation.
Main Impact for Brands and Manufacturers
The PPWR has a direct impact on brands and manufacturers placing packaged products on the EU market, including companies located outside the European Union.
One of the main challenges will be the need to collect detailed technical information on all packaging components used in the final product for assessment and evaluation.
Companies must evaluate whether their packaging complies with the new sustainability and safety requirements.
Based on this review, companies may need to prepare a conclusion regarding the current sustainability and compliance status of their packaging.
Where gaps are identified, an adaptation plan should be implemented to bring the packaging into compliance within the deadlines established by the regulation.
Declaration of Conformity and Technical Documentation
One of the key consequences of the PPWR is the need to support packaging compliance with appropriate documentation.
Companies may need to prepare and maintain technical documentation demonstrating that the packaging complies with the applicable requirements.
In addition, companies may need to issue a Declaration of Conformity (DoC) confirming compliance with the relevant PPWR requirements.
This means that packaging claims, sustainability statements, and compliance conclusions should be based on documented technical evidence.
Main Impact for Importers and Distributors
Importers and distributors will also be affected by the PPWR.
Companies placing packaged products on the EU market may need to ensure that the packaging complies with the regulation before making the products available.
This may include verifying that:
The manufacturer has carried out the required assessment
The packaging complies with the applicable requirements
The technical documentation is available
The Declaration of Conformity has been prepared, where required
The packaging is correctly labelled
Importers and distributors may also need to be enrolled in national Extended Producer Responsibility systems in the EU Member States where products are placed on the market.
This may involve:
Registration with national packaging registers
Annual reporting of packaging placed on the market
Estimation and declaration of packaging waste by material type
Payment of applicable environmental or EPR fees
Keeping records available for competent authorities
These obligations may vary depending on the Member State, the type of packaging, and the commercial model used by the company.
Obligations for Non-EU Companies Selling B2C
Non-EU companies selling products directly to consumers in the European Union should pay special attention to the PPWR.
Where a company sells packaged products directly to EU consumers, including through e-commerce or distance selling, it may need to appoint an EU-based Authorised Representative for packaging-related obligations, such as a third-party service provider like Belab Services.
Main Points to Consider in a Packaging Adaptation Plan
A structured packaging adaptation plan should consider at least the following points:
Packaging mapping and material identification
Recyclability assessment
Packaging minimisation and simplification
Substances of concern
Labelling and consumer information
Internal deadlines and corrective actions
Finally, companies should create an internal action plan with clear deadlines, designated responsible persons, and corrective actions.
This plan should enable the company to adapt its packaging before the applicable PPWR deadlines.
Risks of Non-Compliance
Failure to comply with the PPWR may expose companies to regulatory and commercial risks.
Depending on the case and the Member State, companies may face:
Market access issues
Administrative enforcement actions
Product withdrawals or corrective measures
Financial penalties
Delays in importation or distribution
Loss of commercial opportunities with retailers, distributors, or marketplaces
As sustainability and packaging compliance become increasingly important in Europe, companies that fail to prepare may face difficulties when placing products on the EU market.
How Belab Services Can Help
Belab Services helps companies understand and comply with the new PPWR requirements by assessing their packaging compliance status, identifying regulatory gaps, and preparing the necessary documentation to support market access in the European Union.
We also support non-EU companies with Extended Producer Responsibility obligations and EU Authorised Representative services where applicable.
The PPWR is not just a packaging regulation. It is a new compliance framework that will affect how companies design, document, and place packaged products on the European market.
Preparing now will help companies reduce risks, avoid future disruptions, and ensure a smoother transition to the new EU packaging requirements.
Belab Services can help your company understand the applicable obligations and implement a clear regulatory pathway for PPWR compliance.
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