PPWR Compliance Cheat Sheet: What EU Businesses Must Do in Phase 1
Table of Content
- What Is PPWR? – EU Packaging and Packaging Waste Regulation Explained
- PPWR Compliance Checklist for Businesses
- Scope Check – Are You in Scope?
- 1. Packaging Inventory & Mapping
- 2. Packaging Minimisation (Core PPWR Obligation)
- 3. Recyclability in Practice
- 4. Plastic Packaging & Recycled Content (If Applicable)
- 5. Labelling & Consumer Information
- 6. Environmental & Sustainability Claims
- 7. Conformity Documentation
- 8. Supply Chain Responsibility
- 9. Extended Producer Responsibility (EPR)
- 10. Readiness for Enforcement (From August 2026)
- Quick Self-Assessment
What Is PPWR? – EU Packaging and Packaging Waste Regulation Explained
PPWR, or the Packaging and Packaging Waste Regulation, is the European Union’s new framework law governing packaging and packaging waste across the entire lifecycle — from design and production, through placing on the market, to end-of-life and recycling. It replaces the old Packaging Directive (Directive 94/62/EC).
The regulation aims to minimise environmental impacts, increase recyclability, reduce reliance on virgin materials, and promote circular economy principles. It does this by setting requirements for packaging sustainability, waste prevention, extended producer responsibility, and the design, labelling, and recyclability criteria for all packaging placed on the EU market.
The regulation aligns with the EU’s waste hierarchy and supports the transition to a circular economy and climate neutrality by 2050.
See the other post for an explanation of PPWR and the relevant timeline.
Key PPWR Dates
- 12 February 2025 – PPWR officially enters into force as EU law.
- 12 August 2026 – All core PPWR provisions become legally binding for packaging placed on the EU market.
From 12 August 2026, all businesses placing packaging on the EU market must ensure it complies with the regulation’s sustainability, design, labelling, and recycling requirements. PPWR survival guidance
Who Must Comply with PPWR?
PPWR applies to all packaging and packaging waste, regardless of the packaging material and type — including primary (sales packaging), secondary (grouped packaging) and tertiary (transport packaging) formats.
Any organisation that:
- manufactures packaging
- imports packaged products into the EU
- sells products in packaging
- designs, uses, or supplies packaging in the EU
must comply with PPWR rules — even if packaging is outsourced or supplied by third parties. Compliance obligations follow the economic operator responsible for placing it on the market, typically the manufacturer, importer or brand owner.
Key PPWR Obligations
1. Packaging Minimisation and Design
Packaging must be designed to minimise weight and volume, while still fulfilling its basic function (protection, containment and transport). It must avoid excess or unnecessary materials, and it must be compatible with recycling systems.
This includes:
- avoiding over-packaging
- reducing packaging complexity
- shifting towards reusable/re-fillable formats where feasible
The regulation strengthens and clarifies packaging performance criteria that previously existed only in standard EN 13428:2004, and explicitly excludes aesthetic or marketing reasons as justification for extra packaging.
2. Recyclability Requirements
One of PPWR’s core objectives is to ensure that packaging is recyclable in practice and economically viable to recycle at scale.
From 1 January 2030, packaging must meet harmonised recyclability performance grades (A, B, C) based on design-for-recycling criteria set at EU level.
- Packaging below grade C may be restricted from being placed on the market.
- By 1 January 2038, packaging must meet at least grade B levels to remain marketable.
3. Labelling and Information
Packaging placed on the market must be labelled with standardised information that supports:
- correct waste sorting
- transparent recycling pathways
- enforcement of extended producer responsibility schemes
The regulation encourages digital, open labelling technologies (such as QR codes) to ensure consistency and clarity for consumers and waste operators.
While labelling of recycled content is not mandatory, recycled content targets are included and reporting on compliance will be required.
4. Recycled Content Requirements
PPWR mandates minimum recycled content levels for plastic parts in packaging. These levels will be calculated per manufacturing plant per year, giving manufacturers operational flexibility while supporting demand for post-consumer recycled materials.
5. Extended Producer Responsibility (EPR)
Packaging producers (including manufacturers and importers) must comply with EPR schemes, contributing to the cost of collection, sorting and recycling infrastructure, as well as prevention activities. Member States will organise EPR frameworks consistent with EU rules.
What to Do as of 1 January 2025
Although PPWR fully applies in August 2026, 2025 is a critical preparatory year. Companies should:
- audit packaging formats, materials and waste data
- engage suppliers for compliance data and documentation
- redesign packaging to meet minimisation and recyclability requirements
- implement conformity documentation processes
- update procurement and sustainability policies
Supply Chain Responsibility & Packaging Claims
Under PPWR, all operators remain legally responsible for ensuring packaging and claims about it are accurate and substantiated. This includes claims when packaging is designed or manufactured by a third party.
Key obligations include:
- verifying recyclability and sustainability claims
- documenting supplier declarations on material composition
- ensuring traceability of packaging components
Misleading or unsupported claims may result in enforcement action by national market authorities.
Post-Consumer Plastic Waste
PPWR recognises post-consumer plastic waste as plastic waste generated after packaging has been used by consumers in commercial or private contexts — including exports if they meet EU criteria.
This definition supports targets for recycled content and recycled material supply.
PPWR Compliance Checklist for Businesses
Use this checklist to assess packaging compliance:
- ❓ Does the packaging meet weight and volume minimisation requirements?
- ❓ Is the packaging designed for recycling and reuse?
- ❓ Is the packaging assignable to a recyclability grade?
- ❓ Are labels and QR codes providing correct waste and recyclability info?
- ❓ Do you have conformity documentation on file?
- ❓ Are your suppliers contractually obligated to support PPWR compliance?
If any answer is “no” or “not sure,” you should plan corrective action.
Scope Check – Are You in Scope?
You are subject to PPWR if you:
- Place packaged products on the EU market
- Import packaged goods into the EU
- Sell products under your own brand or private label
- Commission or specify packaging design or materials
✔ If yes, continue with the checklist below.
1. Packaging Inventory & Mapping
Have you identified and documented all packaging you place on the market?
Checklist:
- ☐ Primary (sales) packaging identified
- ☐ Secondary (grouped) packaging identified
- ☐ Tertiary (transport) packaging identified
- ☐ Materials used for each component documented
- ☐ Supplier(s) for each packaging component identified
📌 Why this matters: You cannot demonstrate PPWR compliance without a complete packaging inventory.
2. Packaging Minimisation (Core PPWR Obligation)
Is your packaging minimised to the necessary level?
Ask yourself:
- ☐ Is the packaging no heavier than necessary?
- ☐ Is the packaging no larger than necessary?
- ☐ Could any layer, insert, or component be removed?
- ☐ Is empty space avoided?
- ☐ Is packaging used only for protection, safety, or logistics — not purely marketing?
🚫 PPWR does not allow additional packaging justified only by:
- Aesthetics
- Shelf appeal
- Branding convenience
📌 Action for brand owners: Request written justification from suppliers explaining why each packaging element is necessary.
3. Recyclability in Practice
Is your packaging recyclable in real-world EU systems?
Checklist:
- ☐ Packaging materials are compatible with EU recycling streams
- ☐ Multi-material packaging is separable or recyclable
- ☐ No components hinder recycling (e.g. labels, adhesives, inks)
- ☐ Supplier has assessed recyclability performance
- ☐ Packaging is expected to meet future recyclability grading requirements
📌 Key point: “Technically recyclable” is not sufficient — PPWR requires recyclable in practice and at scale.
4. Plastic Packaging & Recycled Content (If Applicable)
If your packaging contains plastic:
- ☐ Plastic components identified and quantified
- ☐ Post-consumer recycled content (if used) documented
- ☐ Supplier declarations available
- ☐ Systems in place to track recycled content per year
📌 Note: Recycled content targets apply mainly to plastic packaging and will be enforced progressively.
5. Labelling & Consumer Information
Does your packaging provide correct and compliant information?
Checklist:
- ☐ Packaging includes required material identification
- ☐ Sorting and disposal instructions are clear
- ☐ Labels are legible, durable, and accurate
- ☐ Digital labelling (e.g. QR code) considered where appropriate
- ☐ Information aligns with EU harmonised labelling rules
📌 Brand owner risk: Incorrect or misleading labels fall on the company placing the product on the market — not the packaging supplier.
6. Environmental & Sustainability Claims
Are your packaging-related claims accurate and substantiated?
Checklist:
- ☐ “Recyclable” claims supported by evidence
- ☐ “Sustainable”, “eco”, or “green” claims justified
- ☐ No vague or unverified environmental messaging
- ☐ Supporting documentation retained
- ☐ Claims aligned with PPWR and green claims rules
🚫 Unsupported or misleading claims may trigger enforcement action.
7. Conformity Documentation
Do you have proof of compliance?
Even as a packaging consumer, you must ensure documentation exists.
Checklist:
- ☐ Supplier declarations of PPWR compliance obtained
- ☐ Technical documentation available on request
- ☐ Packaging specifications archived
- ☐ Compliance assessments retained
- ☐ Records accessible for inspections
📌 Best practice: Maintain a PPWR compliance file per product or packaging format.
8. Supply Chain Responsibility
Are your suppliers contractually aligned with PPWR?
Checklist:
- ☐ PPWR compliance clauses included in supplier contracts
- ☐ Responsibility for compliance clearly allocated
- ☐ Audit rights included where appropriate
- ☐ Change notification obligations defined
- ☐ Supplier compliance reviewed periodically
📌 Important: Outsourcing packaging does not outsource liability.
9. Extended Producer Responsibility (EPR)
Are you meeting national EPR obligations?
Checklist:
- ☐ Registered with relevant national EPR schemes
- ☐ Packaging quantities reported correctly
- ☐ Fees paid according to material and volume
- ☐ Data aligned with PPWR reporting requirements
📌 Note: PPWR strengthens and harmonises EPR but does not replace national schemes.
10. Readiness for Enforcement (From August 2026)
Final check:
- ☐ Internal owner for PPWR compliance assigned
- ☐ Procedures for inspections in place
- ☐ Documentation retrievable without delay
- ☐ Packaging updates tracked and version-controlled
- ☐ Teams trained on PPWR basics
Quick Self-Assessment
If you cannot confidently answer “yes” to all of the following, action is required:
- ❓ Is our packaging demonstrably minimised?
- ❓ Is it recyclable in practice?
- ❓ Are our claims accurate and documented?
- ❓ Do we have compliance proof on file?
- ❓ Are suppliers contractually accountable?
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