On December 16, 2024, the Council of the European Union officially adopted the Packaging and Packaging Waste Regulation (EU) 2025/40 (PPWR). It was formally signed by the European Parliament and the Council on December 19, and published in the Official Journal of the European Union on January 22, 2025, officially repealing the old Directive 94/62/EC. The PPWR entered into force on February 11, 2025, and will be fully implemented from August 12, 2026 (unless otherwise specified). It covers packaging and packaging waste across all industries and scenarios, including industrial, retail, e-commerce, and household use, and all relevant parties must strictly comply.

As the EU’s new unified packaging regulatory framework, the PPWR reshapes the full-life-cycle management rules for packaging. Every requirement—from substance control and recyclability to recycled content and labeling bans—directly affects cross-border sellers’ customs clearance and sales. Below is a detailed breakdown of its core requirements to help you quickly grasp compliance priorities.

01 Who and What Does the PPWR Regulate?Regulated Entities

It covers all entire supply chain entities, including manufacturers, importers, distributors, retailers, and e-commerce platforms.

Regulatory Scope

It includes packaging and packaging waste of all materials (plastic, paper, metal, glass, wood, composite materials, etc.) and all scenarios (industrial, commercial, consumer goods, logistics packaging, etc.). Regardless of whether products are produced within or outside the EU, any product with packaging placed on the EU market is subject to this regulation.

Key Note on EPR

It is important to note that the PPWR does not abolish the existing Extended Producer Responsibility (EPR) systems of individual EU member states, nor does it introduce a “unified EU EPR number”. Enterprises must still follow the “territorial principle”:

If you place packaged products on the market for consumers in a specific EU country, you must complete EPR registration in that country and provide valid registration information to the e-commerce platform.

• Germany: Registration through relevant systems such as LUCID is required.
• France: EPR registration must be completed through institutions such as Citeo.
• Italy: Compliance must be carried out based on the CONAI system.
• Spain: Follow the local exclusive packaging EPR rules.

The core requirement of the PPWR is “full compliance coverage”, not “simplified registration procedures”. Enterprises must abandon the fluke mentality of “one-and-done” and implement compliance in each target market one by one.

02 What Are the Core Requirements of the PPWR?2.1 Mandatory Control of Hazardous Substances

Control Type	Scope of Application	Limit Requirements	Key Notes
General Heavy Metals	All packaging	Total content of lead (Pb) + cadmium (Cd) + mercury (Hg) + hexavalent chromium (Cr⁶⁺) ≤ 100mg/kg	The sum of the four substances must meet the standard; no individual limits are set for single elements.
PFAS in Food Contact Packaging	Packaging in direct contact with food	1. Individual target PFAS (excluding polymeric PFAS) < 25ppb; 2. Total of target PFAS + degradable precursors (excluding polymeric PFAS) < 250ppb; 3. Total PFAS (including polymeric PFAS) < 50ppm	If the total fluorine content exceeds 50mg/kg, a certificate of fluorine content must be provided, specifying its proportion in PFAS or non-PFAS.

2.2 Recyclability Classification and Access Thresholds

Starting from January 1, 2030, all packaging placed on the EU market must be recyclable and comply with the “design for recyclability” principle—it must be usable for material recycling to replace raw materials and be separately collectible and sortable when it becomes waste.

• 2030 Access Threshold: Packaging must meet recyclability performance grades A, B, or C; packaging below grade C is prohibited from entering the EU market.
• 2038 Upgrade Requirement: Only packaging meeting recyclability performance grades A or B in Annex II, Table 3 of Regulation (EU) 2025/40 can be placed on the EU market.
• Core Principle: Packaging design must take recyclability into account, avoiding composite materials, multi-layer structures, and other designs that increase recycling difficulty, to ensure actual recycling efficiency meets standards.

2.3 Mandatory Recycled Content Requirements for Plastic Packaging

Plastic packaging must contain post-consumer recycled plastic (PCR). The regulation sets minimum recycled content requirements in two phases—2030 and 2040—by packaging type. Failure to meet these requirements will result in customs clearance refusal.

Packaging Type	Minimum Recycled Content (2030)	Minimum Recycled Content (2040)	Notes
PET contact-sensitive packaging (excluding single-use plastic beverage bottles)	30%	50%	Contact-sensitive packaging, such as snack and cosmetic packaging.
Non-PET contact-sensitive packaging (excluding single-use plastic beverage bottles)	10%	25%	Contact-sensitive packaging without PET.
Single-use plastic beverage bottles	30%	65%	Key regulated category in the beverage industry.
Other plastic packaging	35%	65%	Including logistics turnover boxes and general plastic packaging.

Compliance Reminder: The European Commission will clarify the calculation and verification methods for recycled content by December 31, 2026. Enterprises must plan the procurement of recycled materials in advance to ensure the content ratio meets the requirements.

2.4 Control of Packaging Reduction and Over-Packaging

By February 12, 2027, the EU will introduce a unified calculation method and standards for packaging minimization (including limits on maximum weight, volume, wall thickness, and empty space).

Starting from January 1, 2030, manufacturers or importers must ensure that packaging design minimizes weight and volume to the minimum necessary to ensure its function, while considering the packaging’s shape and materials. False bases, redundant layers are prohibited, and the void ratio of e-commerce packaging must comply with EU standards.

Designs that increase perceived volume, such as double walls and false bottoms, are prohibited to avoid resource waste and environmental burden. Packaging must balance practicality and environmental protection, minimizing material consumption while ensuring product safety.

03 What Are the Key Timelines for the PPWR?

Timeline	Core Content
February 11, 2025	PPWR officially published, replacing Directive 94/62/EC.
February 12, 2026	EU requires the development of unified technical specifications for compostable packaging.
August 12, 2026	PFAS restrictions (for food contact packaging) and total heavy metal limits take effect; comprehensive implementation of packaging substance requirements.
February 12, 2027	EU formulates unified calculation methods and standards for packaging minimization.
February 12, 2028	Review of bio-based plastic packaging technology; compostable packaging must be designed for material recycling as a priority.
January 1, 2030	Packaging weight and volume must be minimized (on the premise of meeting functional requirements).
January 1, 2035	Review of the exemption list for recyclable packaging (such as pharmaceutical and infant food packaging), which may adjust the scope of exemptions.

04 What Are the Compliance Recommendations for the PPWR?Comprehensive Self-Inspection

In accordance with PPWR requirements, inspect the hazardous substance content, recyclability, and recycled content ratio of existing packaging. Focus on verifying PFAS limits for food contact packaging and conduct third-party testing in advance.

Supply Chain Upgrade

Cooperate with compliant packaging suppliers, clarify the procurement ratio of recycled materials, optimize packaging design, reduce over-packaging, and ensure packaging iteration is completed before August 2026.

Qualification Preparation

Collect compliance documents such as test reports, technical documents, and EPR registration certificates, and establish a full-link compliance file to respond to customs inspections and customer audits.

Phased Preparation Plan for Cross-Border Businesses

If you are currently operating or planning to deepen your presence in the European cross-border market, it is recommended to start the following preparations as soon as possible:

Phase 1: Current Situation Sorting (January-February 2026)

1. Sort out the list of sales destinations

• Focus on the countries where consumers actually receive goods, not just where stores are opened.
• Key countries: Major markets such as Germany, France, Italy, Spain, and Poland.
• Recommendation: Export order data from the past 12 months and count actual sales countries by delivery address.

2.Confirm EPR registration status

• Check whether EPR registration has been completed in each sales country.
• Verify whether the registration number is valid and within the validity period.
• Note: Registration must be confirmed separately for categories such as packaging, batteries, and electrical and electronic equipment.

3.Evaluate the compliance of packaging materials

• Check whether packaging materials meet PPWR hazardous substance limits (such as heavy metals and PFAS).
• Evaluate whether the recyclability design meets requirements.
• Identify packaging types that need adjustment.

Phase 2: Registration and Declaration (March-May 2026)

1.EPR registration by country

• Initiate the registration process for countries where registration has not been completed.
• Note: The registration cycle for countries such as Germany and France is expected to take 1-3 months.
• Recommendation: Prioritize major sales countries, then secondary markets.

2. Prepare materials required by platforms

• Organize EPR registration numbers for each country.
• Prepare registration entity information and authorization documents.
• Establish an EPR information management ledger.

3.Communicate verification mechanisms with platforms

• Understand the platform’s verification requirements for EPR information.
• Confirm the information submission method (backend filling, API docking, etc.).
• Test the verification process to ensure information can be correctly identified.

Phase 3: Systematic Preparation (June-August 2026)

1.Establish a data tracking mechanism

• Establish a connection system between sales data and EPR declarations.
• Ensure the ability to count packaging volume by country and category.
• Prepare for regular declarations.

2.Train internal teams

• Operations team: Understand the impact of EPR on product listing.
• Finance team: Understand EPR cost calculation and declaration.
• Compliance manager: Master regulatory trends and response strategies.

3.Formulate emergency plans

• Handling process for platform verification failure.
• Update mechanism for expired or changed registration numbers.
• Communication plan for responding to regulatory inspections.

The PPWR is not just a simple “environmental regulation”; it is a core initiative of the EU to build a circular economy and a rigid compliance constraint for export enterprises. With the full implementation date of August 12, 2026 approaching, proactive compliance planning is essential to avoid risks such as customs detention and customer loss. At the same time, packaging with high recyclability and high recycled content will become the mainstream trend in the EU market, and taking the initiative to upgrade is also the key to seizing market opportunities.

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