PPWR · Guides

PPWR Deadlines 2025 to 2040: Which Dates Are Fixed and Which Are Still Open

Updated: 5 min readIvan Cvitkušić

The PPWR, formally Regulation (EU) 2025/40 on packaging and packaging waste, entered into force on 11 February 2025 and has applied since 12 August 2026. Many obligations, however, are phased in up to 2040, and some of the dates are only the earliest possible date because they depend on acts of the European Commission. Anyone who makes or uses transport and protective packaging should therefore clearly distinguish between fixed and conditional deadlines.

What the new Packaging Regulation changes

The PPWR replaces Packaging Directive 94/62/EC, which is repealed from 12 August 2026 with a few transitional provisions. Unlike a directive, the regulation applies directly in all Member States without national transposition. The requirements are therefore essentially the same across the EU, and the deadlines are set out in the text of the regulation itself.

For industrial suppliers this means there is one common timetable, which customers in Germany, Austria or other Member States will follow. Knowing that timetable makes it easier to put your customers’ enquiries in context.

The deadlines at a glance

Date What applies Type of deadline
11 Feb 2025 Regulation enters into force fixed
12 Aug 2026 General application: substance restrictions (Art. 5), conformity assessment with technical documentation and EU declaration of conformity, producer registration, ban on packaging designed only to look larger (Art. 10(2)) fixed
12 Feb 2027 Member States lay down rules on penalties and notify them to the Commission (Art. 68) fixed
12 Feb 2028 Commission adopts the method for calculating empty space (Art. 24) deadline for the Commission
12 Aug 2028 Labelling of material composition (Art. 12) earliest
12 Feb 2029 Labelling of reusable packaging (Art. 12) earliest
1 Jan 2030 Minimization of weight and volume (Art. 10(1)), at least 40 % reuse for transport packaging (Art. 29) fixed
1 Jan 2030 Recyclability classes A to C as the minimum standard (Art. 6), recycled content in plastic packaging (Art. 7), maximum 50 % empty space (Art. 24) earliest
1 Jan 2038 Only recyclability classes A and B (Art. 6) fixed
1 Jan 2040 Higher recycled-content shares, e.g. 65 % for other plastic packaging (Art. 7(2)); 70 % reuse as a target to aim for in transport packaging (Art. 29) fixed

A clarification on penalties: Art. 68 requires Member States to lay down rules on penalties by 12 February 2027. For infringements of Art. 24 to 29, for example on empty space and reuse, these must provide for fines. The date is a deadline for the Member States, not a cut-off date from which fines begin.

Fixed or conditional: the “whichever is later” rule

Several obligations need technical details that the Commission only sets out in implementing acts or delegated acts: labelling formats, calculation methods or criteria for design for recycling. For these obligations the regulation gives two points in time, a fixed date and a period after the relevant act. The later one applies.

Some examples:

  • Labelling (Art. 12): from 12 August 2028 or 24 months after the implementing acts. This obligation does not apply to transport packaging, except for e-commerce packaging.
  • Empty space (Art. 24): from 1 January 2030 or three years after the implementing acts.
  • Recycled content (Art. 7): from 1 January 2030 or three years after the implementing act.
  • Recyclability (Art. 6): criteria from 1 January 2030 or 24 months after the delegated acts.

In these cases 2030 is therefore a lower limit, not a fixed date. The later the Commission acts, the later the obligation applies. For planning purposes it is still advisable to work with the earliest date: packaging concepts, supplier changes and tests need lead time, and many customers prefer to clarify their supply chain early.

What industrial suppliers should prepare and when

Right now: since the start of application

Since 12 August 2026, packaging placed on the market needs technical documentation and an EU declaration of conformity. Customers are therefore asking for information on materials and substances. It makes sense to do the following now:

  • a complete list of all packaging components: cartons, inserts, stretch film, strapping, edge protectors, filling material, pallets
  • collect supplier declarations for the individual materials and keep them in order
  • clarify who has which role in the supply chain and who issues the declaration of conformity

A structured material review and documentation helps here. Important: a supplier declaration for a single material is not automatically a complete declaration of conformity for every assembled package.

By 2028: groundwork for the follow-on obligations

During this phase the Commission adopts important acts, including the method for calculating empty space by 12 February 2028. It is meant to take into account, for example, irregularly shaped products and packaging that is necessary to protect the product. Companies should follow these acts and review their packaging sizes critically even before then. Filling material counts as empty space.

By 2030: changing packaging concepts

From 1 January 2030, manufacturers and importers must ensure that weight and volume are reduced to the minimum needed for the packaging to function (Art. 10(1)). At the same time the 40 % reuse quota applies to transport packaging such as pallets, plastic boxes, pallet wrap and strapping (Art. 29; cartons are exempt). For stretch film that is not contact-sensitive, a recycled-content share of 35 % generally applies from 2030 at the earliest (Art. 7).

This is where early packaging optimization pays off, because formats, material thicknesses and load units cannot be changed overnight. For details on cartons, film and pallets, see our guide Transport packaging and the PPWR.

Long term: 2038 and 2040

From 1 January 2038, only packaging in recyclability classes A and B may be placed on the market. From 2040, recycled-content shares increase, to 65 % for other plastic packaging. For transport packaging, economic operators are then expected to aim for a reuse quota of 70 %. Anyone choosing materials today should already keep these steps in mind.

Turning the timetable into concrete steps

The PPWR deadlines are public, but which of them apply to your packaging depends on your role, your customers and the type of packaging. Our PPWR and EU compliance service maps the requirements to your product range. If you want to know where you stand today, request an initial assessment.

Related services

Let’s look at your packaging

Tell us where you stand: materials, documentation or a request from an EU customer. We reply with concrete next steps.

Get in touch

Related guides