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Procurement Glossary
PPWR in Procurement: EU Packaging Regulation, Requirements and Implementation
June 9, 2026
The EU Packaging and Packaging Waste Regulation (PPWR) tightens the requirements for packaging across the entire supply chain – and turns packaging compliance into a procurement task. From 12 August 2026, only packaging that meets the PPWR requirements and for which a declaration of conformity exists may be placed on the market. Below, learn what the PPWR is, which obligations and deadlines apply, and how procurement manages implementation with suppliers.
Key Facts
- The PPWR (Regulation (EU) 2025/40) applies directly in all EU member states and replaces the Packaging Directive 94/62/EC.
- In force since 11 February 2025; most obligations apply from 12 August 2026.
- It affects nearly all economic operators – manufacturers, importers, distributors, fulfilment providers – across all sectors and materials, with no general SME exemption.
- From August 2026, a declaration of conformity plus technical documentation is mandatory for every packaging unit.
- Material-related quotas (recyclability, recycled content, reuse, empty space) phase in from 2030.
Content
What is the PPWR? Definition, content and relevance
The PPWR is a core element of the European Green Deal and the EU Circular Economy Action Plan. It aims to curb growing packaging waste and, for the first time, creates a single, directly applicable legal framework for packaging – from design through recycled content to labelling and take-back.
Core elements of the PPWR
As a regulation, the PPWR applies directly in all member states, without national transposition. It covers requirements across the full packaging life cycle:
- Substance restrictions (heavy metals, PFAS in food-contact packaging)
- Recyclability based on design for recycling plus actual recycling rates
- Minimum post-consumer recycled content in plastic packaging
- Packaging minimisation including an empty-space limit
- Harmonised labelling of material composition
- Reuse and refill quotas
- Declaration of conformity, technical documentation and extended producer responsibility (EPR)
PPWR vs. the German Packaging Act (VerpackG)
Unlike the German Packaging Act (VerpackG), which transposes the old packaging directive, the PPWR applies directly and EU-wide. From 2026 it overlays parts of the VerpackG. As with EUDR in procurement, control shifts from the national to the European level.
Relevance of the PPWR in procurement
Under the PPWR, packaging becomes a regulated product with market-access conditions – and therefore a procurement responsibility. Buying organisations must assess packaging and suppliers by recyclability, recycled content and PFAS status, request evidence, and extend their packaging management accordingly.
Requirements and implementation of the PPWR in procurement
The PPWR bundles six core obligations with staggered deadlines. The key point for procurement: administrative obligations apply early (2026), while material- and quota-related requirements follow from 2030 – so supplier work must start now.
The six core obligations at a glance
- Substance restrictions (from 12 Aug 2026): a combined limit of 100 mg/kg for lead, cadmium, mercury and hexavalent chromium, plus new PFAS limits in food-contact packaging.
- Recyclability (from 2030/2035): design for recycling (≥ 70 % recyclable by weight) from 2030, recycled at scale (≥ 55 %) from 2035.
- Minimum recycled content (from 2030/2040): 30 % (contact-sensitive PET), 10 % (other contact-sensitive), 35 % (non-contact-sensitive); up to 65 % by 2040.
- Packaging minimisation (from 2030): weight and volume to the functional minimum; empty-space limit of max. 50 % for grouped, transport and e-commerce packaging.
- Labelling (from 2028): harmonised material labelling, earliest from 12 August 2028; some mandatory digital information (QR code).
- Reuse (from 2026/2030): reusability criteria from 2026; quotas from 2030, e.g. 40 % of transport and e-commerce packaging.
Declaration of conformity and technical documentation
From 12 August 2026, a declaration of conformity must exist for every packaging unit, confirming compliance with Articles 5–12. It requires a conformity assessment and technical documentation kept for five years.
Adapting supplier management
PPWR compliance is impossible without supplier data. Procurement must survey packaging suppliers on recycled content, recyclability and PFAS status and extend the supplier code of conduct. Structured due diligence makes the company's own declaration defensible.
Deadlines, quotas and KPIs at a glance
The PPWR phases in its requirements. For procurement planning, the distinction between early administrative obligations and later material-related quotas is decisive.
Timeline of the key deadlines
- 11 February 2025: PPWR enters into force (Regulation (EU) 2025/40).
- 12 August 2026: most obligations apply – substance restrictions (incl. PFAS), declaration of conformity, reuse systems, EU authorised representative.
- 12 February 2028: compostability requirement for tea bags, coffee capsules, fruit/vegetable stickers.
- from 12 August 2028: harmonised material labelling.
- 1 January 2030: recyclability (≥ 70 %), recycled content (10–35 %), packaging minimisation, 50 % empty-space limit, reuse quotas (40 %).
- 1 January 2035: recycled at scale (≥ 55 %).
- from 2038: recyclability ≥ 80 %.
- 1 January 2040: recycled content up to 65 %.
Relevant KPIs for procurement
- Share of packaging with a declaration of conformity (%)
- Share of suppliers with verified recycled content (%)
- Recyclable weight share per packaging unit (%)
- Empty-space share of shipping packaging (% – target ≤ 50 %)
Compliance risks and controls for the PPWR
Non-compliance with the PPWR hits companies at their most sensitive point: market access.
Sanction and market-access risks
Unlike the EUDR, the PPWR does not set an EU-wide fine level – penalties are set by member states. The most immediate consequence is product-related: packaging without a valid declaration of conformity may not be placed on the market from August 2026.
Supply-chain risks
- Suppliers cannot prove recycled content or PFAS-free status
- Non-recyclable material composites
- Private and retail brands unknowingly assume the producer role
Operational risks
Incomplete conformity processes can lead to supply interruptions. Central, auditable documentation reduces the risk.
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Practical example
A mid-sized machinery manufacturer with high shipping volumes prepares for the PPWR. Procurement builds a complete packaging inventory and surveys all packaging suppliers on recycled content, recyclability and PFAS status.
- Packaging inventory of around 120 items built
- Declarations of conformity requested per packaging unit
- Box-size grid optimised to ≤ 50 % empty space
- PFAS-containing coatings switched to alternatives
Current developments and interpretation of the PPWR
The PPWR is continuously specified through delegated and implementing acts.
Delegated acts and labelling
Particularly relevant for procurement are the design-for-recycling criteria expected by 2028 and the design of the harmonised labelling.
Moving details
In early 2026, the European Commission exempted certain transport packaging from specific reuse obligations – detailed rules are still shifting. In addition, in February 2026 the European Commission published official guidance and FAQs on implementing the PPWR.
Interplay with other regulation
Reporting obligations under the CSRD increase the pressure to keep packaging and material data structured in any case.
Conclusion
The PPWR turns packaging into a regulated product – and packaging compliance into a strategic procurement task. While material-related quotas only apply from 2030, the declaration of conformity, substance restrictions and reuse requirements are binding from August 2026. Companies that analyse their packaging portfolio now and request supplier evidence secure market access and lower costs long-term through modulated EPR fees.
FAQ
What is the PPWR?
The PPWR (Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40) is the new EU packaging regulation. It replaces the Packaging Directive 94/62/EC and applies directly in all member states.
When does the PPWR apply?
In force since 11 February 2025; most obligations apply from 12 August 2026. Material-related quotas phase in from 1 January 2030.
Who is affected by the PPWR?
Nearly all economic operators: manufacturers, importers, distributors and fulfilment providers – regardless of material or sector, with no general SME exemption.
What does procurement need from suppliers?
Evidence on material composition, recycled content, recyclability and PFAS status – as the basis for the technical documentation and declaration of conformity.
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