PPWR - Milestones & Deadlines *

From 11 February 2025:

• Applies to: Micro-enterprises
• Details: The definition of micro-enterprises (in accordance with Recommendation 2003/361/EC) serves as the reference date for various exemptions in the future.

By 12 July 2025:

• Applies to: Member States
• Details: Designation of the competent authorities for implementation and enforcement.

By 31 December 2025:

• Applies to: Member States
• Details: Submission of information to the Commission on substances that may hinder recycling.

By 12 February 2026:

• Applies to: Commission / standardisation bodies
• Details: The Commission must adopt implementing acts for the manufacturer registration format and request standards for compostable packaging.

From 12 August 2026 (main date of application):

• Applies to: Producers, importers, suppliers, distributors, fulfilment service providers.
• Details:
  • Substance restrictions (Art. 5): Compliance with limit values for substances of concern (e.g. lead, cadmium, mercury, chromium VI ≤ 100 mg/kg).
  • PFAS restrictions (Art. 5): Entry into force of restrictions on PFAS in food contact packaging (limit values: 25 ppb to 50 ppm).
  • Conformity assessment (Art. 15): Producers must carry out conformity assessment procedures, prepare technical documentation, and issue EU declarations of conformity.
  • Information obligations (Art. 16): Suppliers must provide producers with all necessary conformity-related data.
  • Distributor obligations (Art. 19): Distributors must verify, prior to placing packaging on the market, that the producer is registered and that the packaging is compliant.
  • EPR financial contributions (Art. 45): Producers must comply with extended producer responsibility and make financial contributions.
  • Authorisation (Art. 47): Producers or producer responsibility organisations (PROs) must apply for authorisation.

• Applies to: Member States.
• Details:
  • Repeal of Directive 94/62/EC (with exceptions).

By 31 December 2026:

• Applies to: Commission
• Details: Establishment of the methodology for calculating recycled content and sustainability criteria for plastic recycling.

By 12 February 2027:

• Applies to: Final distributors (hospitality / take-away).
• Details: Refill obligation (Art. 32): Final distributors selling beverages or food for take-away must allow customers to bring their own containers (“bring your own” system).

• Applies to: Member States.
• Details:
  • Adoption of rules on penalties for infringements.

• Applies to: Producers (within EPR systems).
• Details:
  • Labelling of packaging covered by an EPR system will be enabled via QR codes.

By 12 August 2027:

• Applies to: Producers / PROs.
• Details: Final deadline for registration in the national producer register (18 months after the implementing act of February 2026).

From 1 January 2028:

• Applies to: Commission.
• Details: Adoption of delegated acts on Design for Recycling (DfR) criteria and recyclability performance classes (A, B, C).

From 12 February 2028:

• Applies to: Producers.
• Details:
  • Compostable packaging (Art. 9): Certain packaging (e.g. tea bags, stickers on fruit and vegetables, very lightweight carrier bags) must be compostable. Other packaging must be designed for material recycling.
  • Packaging minimisation (Arts. 10 & 24): Obligation to minimise the weight and volume of sales packaging. Limitation of empty space in sales packaging.

• Applies to: Final distributors (hospitality / take-away).
• Details:
  • Reuse offer (Art. 33): Obligation to also offer beverages and food for take-away in reusable packaging (exception: micro-enterprises).

From 1 June 2028:

• Applies to: Producers / PROs.
• Details: Start of annual quantity reporting to the national register.

From 12 August 2028 (or 24 months after the implementing act):

• Applies to: Producers.
• Details: Labelling obligation (Art. 12): Packaging must be labelled with harmonised pictograms indicating material composition (sorting guidance). Where applicable, labelling of recycled content may also be required.

• Applies to: Member States.
• Details: Obligation to label waste collection containers in line with the packaging pictograms.

From 1 January 2029:

• Applies to: Member States / system operators.
• Details: Deposit obligation (Art. 50): Establishment of deposit and return systems (DRS) for single-use plastic bottles and metal cans (up to 3 litres) is mandatory, unless an exemption has been granted (a 90% collection rate must be achieved).

From 12 February 2029:

• Applies to: Economic operators.
• Details: Amendment of the Single-Use Plastics Directive (SUPD): PPWR prohibitions take precedence over national SUPD measures for certain products.

From 1 January 2030:

• Applies to: Producers.
• Details:
  • Recyclability (Art. 6): All packaging placed on the market must be recyclable (at least performance class C in accordance with the Design for Recycling criteria). Packaging classified as class D or worse is prohibited (exception: innovative packaging subject to a 5-year transitional period).

• Applies to: Producers / importers.
• Details:
  • Recycled content targets (Art. 7): Obligation to meet minimum shares of post-consumer recycled (PCR) content in plastic packaging:
    • 30% for contact-sensitive PET packaging (excluding bottles).
    • 10% for other contact-sensitive plastics.
    • 30% for single-use beverage bottles.
    • 35% for other plastic packaging.
  • Packaging minimisation (Art. 24): Limitation of empty space to a maximum of 50% for grouped packaging, transport packaging, and e-commerce packaging.

• Applies to: Economic operators.
• Details:
  • Prohibitions (Arts. 25 & Annex V): Ban on certain packaging formats, such as single-use plastic packaging for fresh fruit and vegetables (<1.5 kg), single-use packaging for food and beverages in the HORECA sector (on-site consumption), and mini portion packaging (e.g. hotels, condiments).
  • Reuse targets (Art. 29): First binding reuse targets apply to transport packaging (e.g. pallets, crates, drums) and beverage packaging.

Outlook: From 2030 onwards
The regulatory requirements will be progressively tightened after 2030, with a focus on more efficient recycling (“recycled at scale”) and higher targets.

Evaluation by the Commission (e.g., review of recycling targets and exemptions).

Comprehensive evaluation of the entire regulation.

• Recyclability: Tightening of the definition. Packaging will only be considered recyclable if it is recycled “at scale” (i.e., actual infrastructure and collection must be demonstrated).
• Waste prevention: Reduction target increases to 10%.

• Recyclability: Packaging of performance level C (according to Design for Recycling) may no longer be placed on the market. Only levels A or B are permitted.

• Use of recycled material: Massive increase in mandatory quotas for recycled material in plastic packaging (e.g., 50% for contact-sensitive PET, 65% for single-use bottles and other plastics).
• Reuse: Increase in reusable quotas (e.g., transport packaging to 70%, beverages to 40%).
• Waste prevention: Reduction target increases to 15%.

• Producer: Primarily responsible for design, recyclability, freedom from harmful substances, recycled content, and declarations of conformity.
• Manufacturer (in EPR context): Pays EPR fees and registers (often identical to producer/importer).
• Importers: Must ensure that third-country goods comply with all EU rules (often act as “manufacturers” within the meaning of EPR).
• Distributors: Control obligations (no sale without manufacturer registration); special obligations for catering (reusable options, refilling).
• Economic operators: Umbrella term. Applies to all parties in the case of bans (Annex V) and transport packaging reuse quotas.
• Member States: Must set up collection systems (deposit), registers, and sanctions, and achieve waste reduction targets.