PPWR has applied since 12 August 2026. See every deadline to 2040, what changes on your pack, and what UK and US brands selling into the EU must do now.
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This guide explains the law from a packaging-design point of view. It is not legal advice.
PPWR, Regulation (EU) 2025/40, is the EU's packaging law. It has applied in every EU country since 12 August 2026, and most of it also applies in Northern Ireland, though not in Great Britain. Later rules follow: EU sorting labels from August 2028 at the earliest, recyclability and recycled-content minimums from 2030 at the earliest, and tighter thresholds in 2038 and 2040.
Sources for the quick answer: Regulation (EU) 2025/40, Art. 6, 7, 12 and 71; DAERA, Packaging and packaging waste.
This guide is for UK brands, US and Canadian exporters and EU teams working in English: what PPWR is, every key date to 2040, who is responsible, and which change belongs in which redesign. For the declaration of conformity in detail, read our German guide: PPWR: Was die neue EU-Verpackungsverordnung für Ihr Verpackungsdesign bedeutet.
These definitions follow Art. 3(1) of Regulation (EU) 2025/40, shortened for readability.
Working with German partners? In the German text, the "manufacturer" is the Hersteller and the EPR "producer" is the Erzeuger; our German PPWR guide uses those terms.
Not every PPWR date is fixed. Some apply automatically; others apply on a set date or a period after a Commission act, whichever is later, so they move when the Commission is late. The table flags which is which.
| Date | What applies | Article | Fixed or "whichever is later"? | What it means for your pack |
|---|---|---|---|---|
| 11 Feb 2025 | Entry into force. Reusable-packaging definition applies. Cut-off date for design and shape-trademark protection under the minimisation exemption. | Art. 71, 11(1), 10(2)(a) | Fixed | Only designs or trademarks protected before this date can rely on that exemption. |
| 12 Aug 2026 | General application. PFAS limits in food-contact packaging. Heavy metals (lead, cadmium, mercury, hexavalent chromium) max. 100 mg/kg combined. Conformity assessment, technical documentation, declaration of conformity, ID number and manufacturer name and address on pack or via QR. Rules on environmental claims. Directive 94/62/EC repealed (a few provisions continue for a transition period). | Art. 71, 5(4), 5(5), 14, 15, 70 | Fixed (in force now) | New marks on every pack placed on the market from this date; claims and food-contact materials audited. |
| 12 Feb 2027 | Member States must have their penalty rules in place. | Art. 68 | Fixed | Enforcement becomes concrete, country by country. |
| 12 Feb 2028 | Tea and coffee bags, soft single-serve pods and fruit and vegetable stickers must be compostable. Empty space in sales packaging minimised. Takeaway businesses must offer a reuse option (micro-enterprises are exempt). | Art. 9(1), 24(4), 33 | Fixed | Affected formats and stickers need new materials; oversized sales packs need resizing. |
| 12 Aug 2028 at the earliest | Harmonised EU material and sorting label. Label specifications for recycled content. | Art. 12(1), 12(4) | Whichever is later: 12 Aug 2028 or 24 months after the implementing act | Reserve artwork space now; the final design is not yet published. |
| 12 Feb 2029 at the earliest | Label and QR code for reusable packaging. | Art. 12(2) | Whichever is later: 12 Feb 2029 or 30 months after the implementing act | Reuse systems need their own label and data carrier. |
| 1 Jan 2030 | Packaging recyclable within design-for-recycling grades A to C. Minimum recycled content in plastic packaging (10–35%). Packaging minimisation. Max. 50% empty space in grouped, transport and e-commerce packaging. Formats in Annex V banned. Reuse targets for transport packaging. | Art. 6(3), 7(1), 10(1), 24(1), 25, 29 | Mixed: the Annex V bans, minimisation and transport reuse targets are fixed; recyclability grades (Art. 6(3)), recycled content (Art. 7(1)) and empty space (Art. 24(1)) apply from 2030 or a set period after a Commission act, whichever is later | The big redesign deadline: materials, structure, box sizes and some formats change. |
| 1 Jan 2035 at the earliest | Packaging must also be "recycled at scale". | Art. 6(2)(b) | Whichever is later: 1 Jan 2035 or 5 years after the recycled-at-scale implementing acts | Recyclable in theory is no longer enough; collection and recycling must exist in practice. |
| 1 Jan 2038 | Only recyclability grades A or B allowed. | Art. 6(3) | Fixed | Grade C packaging must be redesigned or withdrawn. |
| 1 Jan 2040 | Higher recycled content in plastic packaging (25–65%). Member States must cut packaging waste per capita by 15% compared with 2018. | Art. 7(2), 43 | Fixed | Long-term sourcing of recycled plastic becomes a design input. |
Source for all rows: Regulation (EU) 2025/40; timeline cross-checked with the Commission's PPWR implementation page.
Status of the labelling act (November 2026). The implementing act for harmonised labels was due by 12 August 2026 (Art. 12(6)). On 11 November 2026 the Commission's implementation page still says the Commission is "currently preparing" it. Because the sorting label applies 24 months after the act enters into force if that is later than 12 August 2028, every month of delay now pushes the sorting-label date back by a month.
Yes, once your packaging is placed on the EU market, wherever your business is based.
PPWR does not apply to packaging placed only on the market in England, Scotland or Wales (DAERA). Great Britain keeps its own rules, chiefly UK packaging extended producer responsibility, run by Defra and PackUK. It applies to UK-established organisations that supplied or imported more than 25 tonnes of packaging in the UK in the previous year and have an annual worldwide turnover of £1 million or more (GOV.UK, EPR for packaging: who is affected).
Once the same pack is sold into the EU, PPWR applies to it. According to DAERA, a decision on whether to align with PPWR across the UK "has not yet been taken"; a formal consultation is being planned.
Under the Windsor Framework, much of PPWR applies in Northern Ireland: recyclability, labelling, the substance limits and the restrictions on single-use formats (DAERA). The European Commission's notice on applying PPWR in Northern Ireland (C/2025/946) lists the parts that do not apply there: Art. 23, Art. 29–33 (reuse targets and the take-away reuse offer), Art. 34 on carrier bags (under conditions), Art. 41–55 (including the waste-prevention and recycling targets, producer registration, EPR and deposit return schemes), parts of Art. 56, and Art. 57 and 63. UK packaging EPR applies in Northern Ireland instead (GOV.UK). Packaging first placed on the Northern Ireland or EU market from 12 August 2026 must meet the PPWR rules that apply from that date (DAERA).
PPWR is marked as relevant to the European Economic Area, but EU law only binds Norway, Iceland and Liechtenstein once an EEA Joint Committee decision takes it into the EEA Agreement. On 11 November 2026, EFTA's EEA-Lex entry for Regulation (EU) 2025/40 still lists it as under scrutiny by the three EEA EFTA States, with no Joint Committee decision shown. If you sell into those countries, check their national packaging rules and watch that entry.
If you have no EU entity, the EU importer becomes your compliance gatekeeper. Under Art. 18, the importer must check that you, the non-EU manufacturer, carried out the conformity assessment and drew up the technical documentation, that the pack is labelled and accompanied by the required documents, and that it carries the ID and your contact details. The importer keeps a copy of your declaration of conformity (Art. 18(7); Commission FAQ X.11) and must add its own name and address (Art. 18(3)). Expect EU buyers to ask for this paperwork.
Separately, producer (EPR) registration applies in each Member State where the packaging is first made available (Art. 44). Businesses that sell directly to end users in an EU country where they are not established, including UK and US brands, must appoint an EPR authorised representative in that country by written mandate (Art. 45(3)).
On 10 December 2025 the Commission proposed suspending that obligation until 1 January 2035 (COM(2025) 982). Even in that version, each Member State could still require producers from outside the EU to appoint one. The European Parliament voted on the file on 20 October 2026 and sent it into negotiations with the Council (Legislative Observatory, 2025/0395(COD)). The Council's comparison table of 4 November 2026 shows that both the Parliament and the Council would limit the relief to producers established in the EU: small and micro businesses in Parliament's text, and producers below 1 tonne per country per year in the Council's (Council document 15120/26). Nothing has been adopted. For a UK or US brand the obligation stands today, and neither negotiating position would remove it.
| Set-up | Manufacturer | Importer | Producer (EPR) |
|---|---|---|---|
| UK brand selling to an EU retailer | UK brand (packs carry its name or trademark) | EU retailer or distributor that first places the goods on the EU market | Usually the EU business that first makes the packaging available in each country |
| UK brand shipping direct to EU consumers | UK brand | Often no EU importer in the chain; ask your adviser who takes this role | UK brand as distance seller in each country, via an EPR authorised representative (still required; see above) |
| US brand selling via an EU distributor | US brand | EU distributor | Usually the distributor, per country |
| US brand with its own EU company and warehouse | US brand, or the EU company if packs carry its name | The EU company that brings the goods in | The EU company, in each country where it first makes packaging available |
| Brand based in Northern Ireland | NI brand | Not applicable for its own NI-made packs | UK EPR in Northern Ireland; national EPR in each EU country it sells into |
Roles follow Art. 3(1), 18 and 44–45; confirm yours with your compliance adviser.
Since 12 August 2026, packaging must carry a type, batch or serial number and the manufacturer's name and postal address, either on the pack or via a QR code or other data carrier (Art. 15(5)–(6)). Imported packaging also carries the importer's details (Art. 18). One component of the sales unit is enough; the Commission's FAQ uses a yoghurt cup as the example (Commission FAQ X.8).
The EU label will be pictogram-based and accessible. A QR code can carry component-level sorting information. For online sales, the label information must be shown before purchase (Art. 12(1) and 12(5)). Labels and symbols must not mislead consumers about the packaging's properties (Art. 12(8)).
Design tip: reserve artwork space for the label now, but do not reprint for it before the implementing act is published. Packaging made in the EU or imported before the label applies can still be made available for up to 3 years after that date (Art. 12(12)).
From 2030 (or 24 months after the Commission's design-for-recycling rules, if that is later), packaging must reach recyclability grade A, B or C; from 2038, only A or B (Art. 6(3)). Every component counts: each one is assessed, and none may hinder the recyclability of the main body of the pack (Art. 6(9)). Exemptions include immediate packaging of medicines and sales packaging of lightweight wood, cork, textile, rubber, ceramic, porcelain or wax (Art. 6(11)).
From 1 January 2030, packaging must be minimised in weight and volume, and double walls, false bottoms and unnecessary layers are not allowed (Commission FAQ VII.1; Art. 10). From 2030 (or 3 years after the Commission's calculation method, if that is later), grouped, transport and e-commerce packaging may contain at most 50% empty space; sales packaging that is shipped as it is counts as an exception (Art. 24(1)).
There is an exemption for packaging designs and shape trademarks protected before 11 February 2025, and for products with a protected geographical indication or covered by an EU quality scheme (Art. 10(2)).
From 1 January 2030, Art. 25 and Annex V restrict these formats:
Annex V sets detailed conditions and exceptions for each.
Environmental claims about packaging are only allowed for properties that go beyond the legal minimum, and they must say what they cover: the packaging unit, one part of it, or all packaging the business places on the market (Art. 14).
For the declaration of conformity itself, including the Annex VIII fields and how many declarations you need, see our German PPWR guide.
Plan PPWR changes around your artwork and structural cycles so you never pay for the same reprint twice.
What you'll need: a SKU list, current dielines and artwork files, supplier specifications, and your EU importer's details.
What you'll need: a component-level materials list, pack and product dimensions, shipping-box sizes, and test samples from your converter.
What you'll need: recycled-content supply agreements, recyclability assessments per pack, and logistics data on transport packaging.
Budgeting? See packaging design costs in Europe in 2026 and our sustainable packaging trends for 2026.
Want this checklist as a printable PDF? It is available on request: send us a message through our contact form and our team will share it with you.
UnFoldMart is a branding and packaging design agency, not a law firm or test laboratory. We work alongside your compliance adviser and suppliers and turn their requirements into packs that still sell.
What we do for PPWR projects:
We have offices in Frankfurt, Zürich, London, Amsterdam, Paris, Madrid, Warsaw, Singapore, Vancouver and Gurugram. UK brands can work with our packaging design team in London; North American exporters with our team in Vancouver. See also how to choose a packaging design agency.
Planning your next redesign? Book a PPWR packaging review: we map your SKUs against the deadlines that apply to them. Or book a free call with our team.
Got Questions? We’ve Got Answers – Clear, Simple, and Straight to the Point
For plastic packaging from 2030 (later if the Commission's calculation method is late): 30% for contact-sensitive PET, 10% for other contact-sensitive plastics, 30% for single-use beverage bottles and 35% for other plastic packaging. From 2040: 50%, 25%, 65% and 65% (Art. 7).
The manufacturer is the business that makes packaging, or has it designed or made, under its own name or trademark. For branded goods this is usually the brand owner (Art. 3(1)).
Packaging already placed on the market before that date can stay on the market. Stock produced but not yet placed on the market can use an accompanying document for the ID and address (Commission FAQ X.5).
The application date of 12 August 2026 has not moved. Some Commission implementing acts are late, which pushes back the "whichever is later" dates, such as the sorting label. A proposal to suspend the EPR authorised-representative obligation is still being negotiated by Parliament and Council (COM(2025) 982).
Since 12 August 2026, packs need an ID number and the manufacturer's name and address (Art. 15). The harmonised EU sorting label follows from 12 August 2028 at the earliest (Art. 12(1)), and the reusable-packaging label from 12 February 2029 at the earliest.
Yes, for any packaging placed on the EU market. The EU importer must check that the US manufacturer has done the conformity assessment, drawn up the documentation and marked the pack (Art. 18).
Not in Great Britain. Most of PPWR applies in Northern Ireland under the Windsor Framework, and it applies to any UK packaging sold into the EU (DAERA).
PPWR entered into force on 11 February 2025 and has applied since 12 August 2026 (Art. 71). Many requirements apply later, mainly between 2028 and 2030, with stricter thresholds in 2035, 2038 and 2040.
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