Packaging used to be regulated mainly as waste. Under the PPWR, Regulation (EU) 2025/40 on packaging and packaging waste, it is now regulated as a product: with design requirements, substance limits, a conformity assessment, a technical file and an EU Declaration of Conformity for the packaging placed on the EU market. The Regulation was adopted on 19 December 2024, entered into force on 11 February 2025, has applied since 12 August 2026 and repeals Directive 94/62/EC. It covers all packaging placed on the EU market, whatever the material and wherever it was made.
What already applies: the conformity file
Since 12 August 2026, before placing packaging on the market the manufacturer must ensure conformity with Articles 5 to 12, carry out the conformity assessment under Article 38 (the internal production control procedure of Annex VII), draw up the technical documentation set out in Annex VII and issue an EU Declaration of Conformity under Article 39, whose model is in Annex VIII. Article 15 sets these manufacturer duties, including keeping the declaration and the technical documentation for five years after the last unit is placed on the market. Article 16 obliges suppliers of packaging and packaging materials to provide the information needed to demonstrate conformity, so the evidence chain runs upstream, to the material supplier.
The substance rules already bite. Under Article 5 the combined concentration of lead, cadmium, mercury and hexavalent chromium in packaging must not exceed 100 mg/kg, and food-contact packaging above the Regulation’s PFAS thresholds (25 ppb for an individual PFAS, 250 ppb for the sum of PFAS, 50 mg/kg for total fluorine) may not be placed on the market.
Recyclability, graded: Article 6
Article 6(1) is one line: “All packaging shall be recyclable.” Recyclable means designed for material recycling, collected separately and sorted into specific waste streams, and recycled at scale. The grading arrives in stages:
Recyclability grades — Annex II, Table 3
- Grade A: at least 95% recyclable by weight;
- Grade B: at least 80%;
- Grade C: at least 70%. Below 70%, packaging is technically non-recyclable.
From 1 January 2030, or 24 months after the design-for-recycling delegated acts enter into force, whichever is later, packaging may be placed on the market only in grades A, B or C. From 1 January 2038 only grades A and B remain. From 2035 the assessment also turns on recycling at scale, not design alone.
Recycled content in plastic packaging: Article 7
For plastic packaging, Article 7 sets minimum percentages of recycled content recovered from post-consumer plastic waste, calculated per packaging type and format as an average per manufacturing plant and year:
| Plastic part of packaging | 2030 stage | 2040 stage |
|---|---|---|
| Contact-sensitive, mainly PET (excl. single-use beverage bottles) | 30% | 50% |
| Contact-sensitive, other plastics (excl. single-use beverage bottles) | 10% | 25% |
| Single-use plastic beverage bottles | 30% | 65% |
| Other plastic packaging | 35% | 65% |
Both stages are conditional on the implementing act setting the calculation and verification methodology, due by 31 December 2026: if it enters into force late, the Article 7 dates move with it. A percentage will have to be calculated and verified under a common method, per plant: a data duty long before it is a materials duty.
Less packaging, labelled packaging, returned packaging
- Minimisation (Article 10): by 1 January 2030 packaging weight and volume must be reduced to the minimum necessary for its functionality; double walls, false bottoms and unnecessary layers are out. Grouped, transport and e-commerce packaging must respect a maximum 50% empty-space ratio (Article 24).
- Re-use (Article 29): from 1 January 2030, at least 40% of transport packaging used by an economic operator must be reusable within a re-use system, and at least 10% of beverages must be offered in reusable packaging.
- Labelling (Article 12): from 12 August 2028, or 24 months after the implementing acts, whichever is later, packaging carries a harmonised, pictogram-based label on its material composition to facilitate sorting; plastic packaging also states its recycled content, and reusable packaging gets its own label from 12 February 2029, with a data carrier showing how to return it.
- Deposit return (Article 50): by 1 January 2029 Member States must ensure separate collection of at least 90% per year of single-use plastic beverage bottles and single-use metal beverage containers up to 3 litres, normally through deposit return systems; a state already collecting at least 80% in 2026 may be exempted if it presents a plan to reach 90%.
Not a passport, but the same data discipline
The PPWR does not create a Digital Product Passport for packaging: recital 100 only envisages exploring product passports for packaging in the future, in connection with the ESPR. What it creates today is the data and the proof such a record would carry: composition, substances, recycled-content percentages calculated under a common method, a technical file kept current, and labels a consumer can act on. The discipline is the one our evidence piece described across packaging, batteries and textiles, and the registry machinery in the DPP registry article: claims about a product must be backed by a record that can be produced and checked.
What companies should do now
- Open the file for every packaging type: technical documentation (Annex VII) and the EU Declaration of Conformity (Article 39) are already due, not a 2030 problem.
- Pull supplier data in now: composition, substances and recycled content sit with suppliers (Article 16). Ask for them in structured form, per plant.
- Design to grade: score today’s formats against the A, B and C scale before the 2030 gate, and drop formats that cannot reach grade C.
- Plan the label and the return: artwork for the 2028 label, and deposit or re-use logistics for 2029 and 2030, are decisions being taken this year.
Ledger Consortium aggregates the product and packaging data held by you and your suppliers, anchors each record on a governed blockchain, timestamped and tamper-evident, and manages the regulatory updates as the PPWR’s delegated and implementing acts land. Anchoring proves a record existed and has not been altered; it does not certify that the data a client supplied was true, and conformity remains the manufacturer’s responsibility, exactly as Article 15 provides. Costs are predictable, there is no token and no crypto exposure, and the platform is GDPR- and eIDAS-aligned. In Italy, the Ledger DPP is distributed by Il Sole 24 Ore (Valore24), whose channel onboards dozens of companies per month. See a working passport in our live demo and browse the other analyses in News.