The EU Packaging Regulation
PPWR
The Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) replaces the previous EU Packaging Directive and is a directly applicable EU regulation covering all packaging – regardless of material or origin. It is part of the European Green Deal and pursues three objectives: reducing packaging waste, increasing recyclability, and strengthening the circular economy.
The PPWR entered into force on 11 February 2025 and has generally applied since 12 August 2026. Individual requirements, however, take effect at different times. Further provisions, including those on recyclability, recycled content and certain single-use packaging formats, will be phased in. Details are specified through delegated acts and implementing acts. For businesses, this means implementing the obligations that already apply and planning ahead for upcoming requirements.
We take the complexity off your hands. With a modular consulting approach, we guide you from the initial impact analysis through the implementation of minimum requirements to the strategic optimization of your packaging portfolio—in a practical manner and tailored to your level of readiness.
Your Path to PPWR Compliance
Here’s how we work with you
Regardless of the phase selected, a PPWR project at DFGE follows a clear, transparent process:
Step 1: Stakeholder Workshop
Joint analysis of your company structure (manufacturer vs. distributor) and the relevant packaging volumes.
Step 2: Data Collection
A customized questionnaire on materials, quantities, and existing processes, including a follow-up discussion to clarify any outstanding issues.
Step 3: Analysis & Prioritization
Assessment of PPWR requirements using a traffic-light system and identification of the most urgent areas for action.
Step 4: Implementation
Depending on the phase: closing compliance gaps, preparing the necessary documentation, or developing the circularity strategy.
Step 5: Results & Handover
Presentation of the results at a results workshop and handover of all deliverables, including the action plan.
PPWR Services
Three modular phases – bookable individually or as a sequence
- Impact Matrix: PPWR requirements by article, deadline, and priority in a traffic-light format
- Initial qualitative GAP assessment using the same traffic-light format
- Action plan with measures organized by 2026 / 2028 / 2030
- Effort: Impact workshop, customized questionnaire, clarification meeting, and results workshop over 3–4 weeks
- In-depth GAP analysis on materials, PFAS, EPR, and labeling: assessed from regulatory, financial, and reputational perspectives
- Prioritized action plan with milestones for 2026, 2028, and 2030
- Management briefing: what needs to be done, why, by when, and at what cost
- Templates for the EU Declaration of Conformity, supplier inquiries, documentation, and EPR registration
- Builds on the Readiness Assessment, supplemented by data collection and implementation support
- Portfolio analysis: assessment of recyclability by packaging category and identification of critical packaging, taking the current regulatory framework into account
- Redesign Options and Material Comparisons for Supplier Discussions (Design for Recycling)
- Circularity strategy with 2030/2040 targets, PCR gap analysis, and cost model
- Circularity roadmap as a management overview from today through 2030
- Optional: ongoing advisory services with monitoring and updates on new legislation
All three phases can be booked individually. The cost depends on your company’s structure and the number of packaging items to be evaluated. Please contact us for a customized offering.
Your Advantages
Why you should turn to DFGE for PPWR implementation
For the Management
- Over 25 years of experience in sustainability and regulatory consulting
- Clear prioritization: What is mandatory, and what makes strategic sense
- Significant relief for your internal resources through modular packages
For highest Quality
- Based on the PPWR (Regulation (EU) 2025/40) and its delegated acts
- Structured impact and GAP analysis presented in a clear traffic-light format
- Ongoing monitoring of new specifications and deadlines
For Sustainability Management
- A robust foundation for compliance documentation and supplier communication
- Alignment with your overall ESG strategy through DFGE Sustainability Intelligence
- A bridge to Corporate Carbon Footprint, Product Carbon Footprint, Circular Economy Strategie and Supply Chain Engagement
FAQ | PPWR & further Information
1. What is the PPWR?
The Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40) is the new EU packaging regulation. It applies directly in all EU Member States and, unlike a directive, does not need to be transposed into national law. National rules remain relevant, particularly for enforcement and the practical implementation of extended producer responsibility.
2. When does the PPWR take effect?
The PPWR entered into force on 11 February 2025 and has generally applied since 12 August 2026. Not all requirements apply from that date: further obligations will be phased in until 2040 and will partly be specified through subsequent legal acts.
3. Who is affected by the PPWR?
The PPWR affects businesses throughout the packaging supply chain, particularly manufacturers, importers and distributors. The obligations a company must fulfil depend on its specific role, the packaging concerned and the relevant sales markets. Responsibility for packaging conformity and extended producer responsibility (EPR) obligations must be assessed separately. Within corporate groups, the roles of each legal entity should be evaluated individually.
4. At what quantities does the PPWR take effect?
There is no general minimum volume below which businesses are completely exempt from the PPWR. However, specific obligations may be subject to simplified requirements or exemptions, depending on factors such as company size, packaging volumes and packaging type. These must be assessed for the particular obligation and legal entity concerned.
5. What exactly is the PPWR calling for?
Five areas of obligation, phased in through 2040: recyclability of all packaging (rated A, B, or C), minimum percentages of recycled content in plastic packaging (starting in 2030: 10–35% post-consumer recycled content), reusable rates for transport packaging (starting in 2030: 40%), bans on certain single-use formats as well as PFAS limits, and comprehensive compliance requirements such as the EU Declaration of Conformity, technical documentation, and registration for each EU market.
The stated targets and requirements do not apply uniformly to every type of packaging. The relevant packaging category, application date and statutory exemptions must be taken into account.
6. Which requirements have applied since August 2026?
The PPWR has generally applied since 12 August 2026. For packaging newly placed on the market, compliance with the requirements already applicable must be demonstrated through the required conformity assessment, EU declaration of conformity and technical documentation. PFAS limits apply to food-contact packaging. Businesses should also review their registration and EPR obligations in the relevant sales markets. Requirements that become applicable later should be planned for in line with their respective deadlines.
7. What distinguishes the three DFGE PPWR phases?
Phase 1 (Readiness Assessment) provides clarity on where you stand.
Phase 2 (Compliance Package) guides you through meeting the minimum requirements.
Phase 3 (Circularity Advisory) strategically optimizes your packaging portfolio with an eye toward 2030 and 2040.
The phases can be booked individually and build on one another as needed.
8. What practical steps should businesses take now?
Start by recording your packaging types, materials, volumes and sales markets. Then clarify responsibilities for packaging conformity and EPR. Review existing supplier evidence, declarations of conformity and technical documentation for gaps, and prioritise the obligations that already apply. This provides a basis for preparing for upcoming requirements on recyclability, recycled content and reuse.
