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’s timeline is tight: Following its entry into force in February 2025, the basic compliance requirements are now mandatory. Additional requirements will take effect by 2030, including bans on certain types of single-use packaging. Further details are being specified on an ongoing basis through delegated acts – for you, this means ensuring continuous compliance and addressing developments early on.
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: Recyclability Grade by Product Category, Critical Packaging Identified
- 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 replaces the previous EU Packaging Directive (94/62/EC), is directly applicable in all member states, and allows no scope for national implementation.
2. When does the PPWR take effect?
The PPWR entered into force in February 2025. The basic compliance requirements will take effect on August 12, 2026. Starting in 2030, certain types of single-use packaging will be phased out of the market, with additional requirements to be phased in gradually through 2040. The framework is being further specified on an ongoing basis through delegated acts.
3. Who is affected by the PPWR?
Basically, anyone who places packaging on the market in the EU. A manufacturer is defined as anyone who sells products under their own brand name—regardless of whether they produce the products themselves. A distributor is defined as anyone who exclusively resells third-party brand products and is therefore subject to significantly fewer obligations. Within corporate groups, each legal entity is assessed separately.
4. At what quantities does the PPWR take effect?
The basic obligations generally apply starting with the first unit of packaging—there is no minimum quantity. Regarding the reporting requirement: A simplified report is sufficient for amounts under 10 metric tons per year; for amounts of 10 metric tons or more, a full report is required. Companies that use less than 1,000 kg of packaging per year, as well as micro-enterprises, are exempt from the reusable packaging targets. Threshold values apply per legal entity, not at the group level.
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.
6. What will take effect as early as 2026?
Starting in 2026, the PFAS ban will take effect for packaging intended for food contact. In addition, an EU declaration of conformity for all packaging, complete technical documentation, and registration in the national producer registry of each EU market will become mandatory.
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.
