Timeline of requirements
According the PPWR text, the Conformity Assessment Procedure is required for packaging placed on the EU market that is subject to one or more of the following PPWR requirements. The below timeline is only illustrative, and users shall always refer to the PPWR text to check given specifications, derogations or exemptions.
2025
2025
Reusable packaging
(*) Users should also be aware of the specifications given in Recital 63 of PPWR.
Article 11(1) establishes that, from 11 February 2025, packaging placed on the market shall be considered to be reusable where it fulfils all requirements listed in Article 11(1).
2026
2026
Substances in packaging
(*) Article 5(1) mandates that packaging placed on the market shall be manufactured minimising the presence and concentration of substances of concern as constituents of the packaging material or of any of the packaging components. Please note that, although the EU Commission indicated in the PPWR FAQ that the date of application of this requirement is 12 August 2026, Article 5(6) of PPWR requires that compliance is only proved for the requirements set out in paragraphs 4 and 5 of Article 5.Article 5(4) establishes that, from 12 August 2026, the sum of the concentrations of lead, cadmium, mercury and hexavalent chromium resulting from substances present in packaging or packaging components shall not exceed 100 mg/kg.
Article 5(5) mandates that, from 12 August 2026, food contact packaging shall not be placed on the market if it contains PFAS in a concentration of or above certain given limits, notably:
(a) 25 ppb for any PFAS as measured with targeted PFAS analysis (polymeric PFAS excluded from quantification);
(b) 250 ppb for the sum of PFAS measured as the sum of targeted PFAS analysis, where applicable with prior degradation of precursors (polymeric PFAS excluded from quantification); and
(c) 50 ppm for PFASs (including polymeric PFAS); if total fluorine exceeds 50 mg/kg the manufacturer, importer or downstream user as defined respectively in Article 3, points (9), (11) and (13) of Regulation (EC) No 1907/2006 shall, upon request, provide to the manufacturer or the importer as defined respectively in Article 3(1), points (13) and (17), of this Regulation proof of the quantity of fluorine measured as content of either PFAS or non-PFAS in order for them to draw up the technical documentation as referred to in Annex VII to this Regulation.
Please note that point 5 of the PPWR Guidance and Section III of the PPWR FAQ document provide helpful guidance on this provision.
2028
2028
Compostable packaging
(*) Under certain circumstances, Member States may require that certain packaging formats, listed in paragraph 2 (a) and (b) of Article 9(2), be made available on their territory for the first time only if compostable. If so determined, the compliance assessment foreseen under Article 9(4) PPWR will also apply.Users should also be aware of the specifications given in Recital 58 of PPWR.
Article 9(2) mandates that, by 12 February 2028, packaging referred to in Article 3(1), point (1)(f) of PPWR and sticky labels affixed to fruit and vegetables to be compatible with the standard for composting in industrially controlled conditions in bio-waste treatment facilities and shall be compatible, where required by the Member States, with the home-composting standards referred to in paragraph 6 of Article 9.
Article 9(3) establishes that, by 12 February 2028, packaging other than that referred to in paragraphs 1 and 2, including packaging made of biodegradable plastic polymers and other biodegradable materials, shall be designed for material recycling in accordance with Article 6 without affecting the recyclability of other waste streams.
Please note that point 10 of the PPWR Guidance and Section VI of the PPWR FAQ document provide helpful guidance on these provisions.
2028
2028
Packaging labelling (WSL and other labels)
Article 12(1) establishes that, from 12 August 2028 or 24 months from the date of entry into force of the relevant implementing acts, packaging placed on the market shall be marked with a harmonised label containing information on its material composition in order to facilitate consumer sorting (*) For the packaging referred to in Article 9(1) and, where applicable, packaging referred to in Article 9(2), the label shall indicate that the material is compostable, that it is not suitable for home composting and that compostable packaging is not to be discarded in nature. With the exception of e-commerce packaging, this obligation does not apply to transport packaging or to packaging that is subject to a deposit and return system..
Article 12(1) also foresees that packaging subject to deposit and return systems as referred to in Article 50(1) of PPWR, shall be marked with a clear and unambiguous label. In addition to the national label, packaging may be marked with a harmonised colour label established in the relevant implementing act adopted pursuant to Article 12(6).
Article 12(4) foresees that, from 12 August 2028 or 24 months from the date of entry into force of the relevant implementing act, whichever is the latest, packaging is marked with a label containing information on the share of recycled content. That label and, where applicable, the QR code or other digital data carrier shall comply with the specifications laid down in the relevant implementing act and be based on the methodology established pursuant to Article 7(8). Where packaging is marked with a label containing information on the share of biobased plastic content, that label shall comply with the specifications laid down in the relevant implementing act adopted pursuant to paragraph 6 of Article 12.
A clause on exhaustion of stocks is also foreseen under Article 12(12) and further specifications on how to display labels, QR codes or other standardised, open, digital-marking technology are also given under Article 12.
Please note that Section VIII of the PPWR FAQ document provide helpful guidance on these provisions.
2029
2029
Packaging labelling (reusable packaging)
(*) The requirement to bear a label and a QR code or other type of standardised, open, digital data carrier shall not apply to open loop systems which do not have a system operator in accordance with Annex VI.Article 12(2) mandates that, from 12 February 2029 or 30 months from the date of entry into force of the relevant implementing act, reusable packaging placed on the market bear a label informing users that the packaging is reusable. Further information on reusability shall be made available through a QR code.
A clause on exhaustion of stocks is also foreseen under Article 12(12).
Please note that Section VIII of the PPWR FAQ document provide helpful guidance on this provision.
2030
2030
Packaging minimization
(*) According to Article 10(4), compliance shall be demonstrated in technical documentation. The latter shall contain the following elements: (a) an explanation of the technical specifications, standards and conditions used to assess the packaging against the performance criteria and methodology set out in Annex IV; (b) for each of those performance criteria, the identification of the design requirements which prevent further reduction of the packaging weight or volume; (c) any test results, studies or other relevant sources, such as modelling and simulations, used to assess the minimum necessary volume or weight of the packaging.Users should also be aware of the specifications given in Recital 62 of PPWR.
Article 10(1) establishes that, by 1 January 2030, the manufacturer or importer shall ensure that the packaging placed on the market is designed so that its weight and volume is reduced to the minimum necessary to ensure its functionality, taking account of the shape and material from which the packaging is made.
Article 10(2) provides that the manufacturer or importer shall ensure that packaging which does not comply with the performance criteria set out in Annex IV of PPWR and packaging with characteristics that aim only to increase the perceived volume of the product, including double walls, false bottoms and unnecessary layers, is not placed on the market unless given exemptions apply.
Article 70(1)(b) of PPWR clarifies that the essential requirements for minimization under the PPWR will continue to apply until 31 December 2029.
Please note that the PPWR FAQ document clarifies under section VII that Articles 10(1) and (2) apply by 1 January 2030.
2030
2030
Recyclable packaging (by design)
(*) Where a unit of packaging includes integrated components, the assessment of compliance with the design for recycling criteria and with the recycled-at-scale requirements shall include all integrated components. A separate assessment shall be carried out for integrated components that can become separated from each other as a result of mechanical stress during transportation or sorting. Where a unit of packaging includes separate components, the assessment of compliance with the design for recycling requirements and with the recycled-at-scale requirements shall be carried out separately for each separate component. All components of a unit of packaging shall be compatible with the established collection, sorting and recycling processes proven in an operational environment and shall not hinder the recyclability of the main body of the packaging unit.Article 6(2)(a) mandates that, from 1 January 2030 or 24 months from the date of entry into force of the delegated acts adopted pursuant to Article 6(4), packaging is designed for material recycling(*) In line with Article 6(9), the manufacturer shall assess packaging recyclability on the basis of the delegated acts adopted pursuant to Article 6(4). Packaging recyclability shall be expressed in the recyclability performance grades A, B or C as described in Table 3 of Annex II..
Please note that point 6 of the PPWR Guidance and Section IV of the PPWR FAQ document provide guidance on this provision.
2030
2030
Recycled content in plastic packaging
(*)Article 7(6) expressively mentions that compliance shall be demonstrated by manufacturers or importers.Article 7(1) foresees that, by 1 January 2030 or 3 years from the date of entry into force of the implementing act referred to in paragraph 8 of the same Article, whichever is the latest, any plastic part of packaging placed on the market shall contain a minimum percentage of recycled content recovered from post-consumer plastic waste, per packaging type and format as referred to in Table 1 of Annex II, calculated as an average per manufacturing plant and year.
Please note that point 7 of the PPWR Guidance and Section V of the PPWR FAQ document provide guidance on this provision.
2032
2032
Packaging labelling (substances of concern)
(*)Please note that the 2032 deadline is provisional as the date of application of the requirement will depend on the date of the entry into force of the implementing act establishing the methodology for identifying substances of concern, as per Article 12(7), second subparagraph.Article 12(1) foresees that, 24 months following the date of entry into force of the implementing act adopted pursuant to paragraph 7, second subparagraph, of Article 12, the packaging placed on the market containing substances of concern shall be marked by means of standardised, open, digital-marking technologies in accordance with the methodology referred to in paragraph 7, second subparagraph.
A clause on exhaustion of stocks is also foreseen under Article 12(12) and further specifications on how to display labels, QR codes or other standardised, open, digital-marking technology are also given under Article 12.
2035
2035
Recyclable packaging (at scale)
(*)Where a unit of packaging includes integrated components, the assessment of compliance with the design for recycling criteria and with the recycled-at-scale requirements shall include all integrated components. A separate assessment shall be carried out for integrated components that can become separated from each other as a result of mechanical stress during transportation or sorting. Where a unit of packaging includes separate components, the assessment of compliance with the design for recycling requirements and with the recycled-at-scale requirements shall be carried out separately for each separate component. All components of a unit of packaging shall be compatible with the established collection, sorting and recycling processes proven in an operational environment and shall not hinder the recyclability of the main body of the packaging unit. Please also note that, under Article 6(5) and by 1 January 2030, the EU Commission shall establish a chain of custody mechanism ensuring that packaging is recycled at scale.Article 6(2)(b) mandates that, from 1 January 2035 or 5 years from the date of entry into force of the relevant implementing acts, when packaging becomes waste, it can be collected separately in accordance with Article 48(1) and (5) PPWR, sorted into specific waste streams without affecting the recyclability of other waste streams and recycled at scale(*) In line with Article 6(9), the manufacturer shall assess packaging recyclability on the basis of the delegated acts adopted pursuant to Article 6(5). Packaging recyclability shall be expressed in the recyclability performance grades A, B or C as described in Table 3 of Annex II..
The definition of “packaging waste recycled at scale” is provided in Article 3(39) of PPWR.
Please note that point 6 of the PPWR Guidance and Section IV of the PPWR FAQ document provide guidance on this provision.
2040
2040
Recycled content in plastic packaging
(*)Article 7(6) expressively mentions that compliance shall be demonstrated by manufacturers or importers.Article 7(2) establishes that, by 1 January 2040, any plastic part of packaging placed on the market shall contain a minimum percentage of recycled content recovered from post-consumer plastic waste, per packaging type and format as referred to in Table 1 of Annex II, calculated as an average per manufacturing plant and year.
Please note that point 7 of the PPWR Guidance and Section V of the PPWR FAQ document provide guidance on this provision.
Important note: The EU DoC and relevant TD are understood as living documents. Manufacturers are therefore expected to carry out conformity assessment only for those PPWR requirements that are already applicable at the time the EU DoC and TD are drawn up. Subsequent updates of the DoC and TD should be prepared as additional PPWR requirements become applicable over time. Please also note that, although Article 38 of PPWR, expressively require conformity assessment as regards the requirements laid down in Articles 5 to 12, compliance shall also be demonstrated in TD in relation to Articles 14 and 26(2) of PPWR, respectively on environmental claims and reusable packaging.