There is renewed movement in European sustainability regulation: Following the extensive requirements of CSRD, EUDR and other ESG regulations, the new [regulation] is now coming into focus. EU Packaging Regulation VO (EU) 2025/40 “Packaging and Packaging Waste Regulation” (PPWR) into focus. With its entry into force on February 11, 2025, and the start of the first implementation phase on August 12, 2026, companies are facing a fundamental transformation in their handling of packaging and packaging waste.
The aim of the regulation is to reduce the environmental impact of packaging throughout its entire life cycle and to sustainably strengthen the European circular economy. The PPWR goes significantly beyond previous requirements and obliges companies to systematically reassess, report, and adapt their packaging design and recyclability.
This creates a need for immediate action, particularly for medium-sized businesses. The regulation essentially affects all companies that place packaging or packaged goods on the market within the European Union, regardless of industry or company size.
Objectives of the Regulation
With the PPWR, the European Union is pursuing a paradigm shift. While previously the focus was primarily on the disposal and recycling of packaging waste, the prevention of waste is now moving further into the foreground, starting with product and packaging development.
In the future, it should be ensured that packaging is designed to conserve resources as much as possible, contains a higher proportion of recycled materials, and can be effectively returned to the recycling loop after use. The regulation establishes uniform requirements across Europe and aims to reduce existing national differences.
Companies are therefore obligated to fundamentally adapt their packaging design and material use to increase recyclability and reuse. Key levers include reducing packaging weight, increasing the use of post-consumer recycled (PCR) materials, and expanding extended producer responsibility (EPR). In addition, new labeling and transparency requirements are intended to ensure greater clarity along the value chain. The specific requirements will be further defined step by step through approximately 30 delegated acts.
The first provisions of the PPWR will be applicable from August 12, 2026. At the same time, the years 2030 and 2040 mark important milestones for further implementation.
The most important deadlines at a glance
- 12.08.2026: Application of the regulation with initial organizational and regulatory requirements (e.g. registration, system participation)
- January 1, 2030 (central target date): Mandatory recyclability of all packaging, minimum recycled content (especially for plastics), limits on empty space, and a sales ban on non-compliant packaging and packaged goods.
- By the year 2040: Increasing recycling rates, further packaging reduction targets and reusable packaging requirements
Why companies should take action now
In practice, it often turns out that companies first need to define their specific role within the supply chain. The regulation distinguishes between various responsibilities, which can vary considerably depending on the business model. Correct classification is a prerequisite for identifying the applicable obligations.
Furthermore, companies should review their packaging portfolio early on with regard to recyclability, material usage, and labeling requirements. The information required for this will increasingly need to be provided by suppliers in the future. Therefore, establishing robust data structures and involving relevant suppliers early on are key prerequisites for the efficient and legally compliant implementation of the PPWR (Product Packaging and Recycling Directive).
In light of the expected increase in recycling rates, it is also advisable to consider the availability of suitable alternative materials at an early stage, as high-quality recyclates in particular could become scarcer and more expensive in the future.
Last but not least, the PPWR requires significantly greater transparency regarding packaging data. Companies will have to document extensive information and make it available along their supply chains. Establishing appropriate processes early on not only creates regulatory certainty but also enables more efficient compliance with packaging and sustainability requirements.
Conclusion
The PPWR is a significant regulatory requirement in the field of circular economy. It will fundamentally change the requirements for packaging and have far-reaching effects on business models, supply chains and operational processes.
Companies should therefore not view the regulation solely as a compliance issue. Rather, addressing the new requirements early on offers the opportunity to optimize packaging strategies, use resources more efficiently, and prepare for future market trends.
What you should do now
- Analysis of the existing packaging portfolio with regard to recyclability, material efficiency and resource use, as well as assessment of conformity with the requirements of the PPWR.
- Clarifying a company's role according to the PPWR (Production Planning and Supply Chain Regulation) is the basis for compliance. Depending on their function in the supply chain, different requirements may apply to producers, importers, or distributors. Early classification creates transparency regarding the relevant legal obligations and necessary actions.
- Establishing a recycling and circular economy strategy early on is crucial to securing material availability and limiting future cost increases. This strengthens competitiveness, fosters customer loyalty, and unlocks additional sales potential in sustainability-oriented markets.
- Development of measures to reduce packaging volume and material usage. Targeted improvements to packaging design can contribute to resource conservation, cost reduction, and regulatory compliance.
- Establishing a robust database for packaging in order to efficiently meet future EU labelling requirements and to implement regulatory adjustments in a timely manner.
- Verification of the completeness and accuracy of the registration in the packaging register, as well as the correct licensing of all relevant packaging. This ensures legal certainty and minimizes compliance risks.
- Assessment of the potential for the use of reusable solutions, especially for transport and shipping packaging, and their economic and ecological viability.
The Moore TK PPWR Readiness Approach: From Impact Analysis to Implementation
Our performance promise to you: Holistic ESG excellence for your business success
At Moore TK, we understand ESG as a strategic success factor – far beyond simply fulfilling regulatory reporting obligations. Current developments surrounding PPWR, CSRD, Omnibus I, EUDR, SFDR, VSME, and other regulatory requirements demonstrate that sustainability is increasingly shaping business models, financing options, supply chains, and the expectations of customers, investors, and other stakeholders.
With over 100 years of consulting experience and leading expertise in ESG, sustainability, and financial reporting, we support companies in implementing regulatory requirements efficiently, pragmatically, and with a future-oriented approach. Our interdisciplinary team combines professional expertise, technological competence, and regulatory depth into a holistic consulting approach that integrates all relevant ESG dimensions.
In the context of the PPWR, we support companies in assessing the impact of the regulation in a timely manner, determining their responsibilities and impact along the supply chain, and classifying and implementing regulatory requirements in a legally compliant manner. Together, we develop a practical and economically viable implementation that considers both compliance requirements and operational, financial, and strategic implications.
Our goal is not only to support companies in complying with regulatory requirements, but also to create competitive advantages, minimize risks and unlock value creation potential.
The most important regulations at a glance
- recyclabilityAll packaging must be recyclable from 2030 onwards (Art. 6).
- Minimum recycled content: Plastic packaging must contain certain proportions of PCR from 2030 onwards (Art. 7)
- Empty space boundary: Maximum 50% empty space for transport, e-commerce and outer packaging (Art. 24)
- restrictions: Ban on PFAS in food contact packaging from 12.08.2026 (Art. 5 paragraph 5); ban on certain single-use formats from 01.01.2030 (Art. 25 and Annex V)
- LabelingHarmonised markings for all packaging from 12.08.2028 (Art. 12)
- Reuse goals: 40% reusable packaging for transport, e.g. Euro pallets, beverage crates or canisters, from 12.08.30 (Art. 29)
- Reuse offer in the hospitality industryMandatory provision of reusable packaging for takeaway drinks or food (Art. 33)
- Due diligence obligations: EU Declaration of Conformity (Art. 39)
- Extended Producer Responsibility (EPR): Registration in the national packaging register and increased obligations for manufacturers, (Articles 44-47)
- Mandatory (deposit) return systemsMember States must ensure the infrastructure and systems for the take-back and separate collection of packaging waste, e.g. for beverage cans and plastic bottles, by 01.01.2029 (Articles 48-50)
- Waste reduction targets for member states: 5% by 2030, 10% by 2035, 15% by 2040 (compared to 2018 levels) (Art. 43)
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