February 2025 – The European Parliament and the European Council formally adopted Regulation (EU) 2025/40 on packaging and packaging waste (“PPWR”) on 16 December 2024, as part of a comprehensive review of packaging obligations in line with the Circular Economy Action Plan.
The PPWR introduces measures affecting all packaging and packaging waste, impacting businesses across various sectors. Key provisions include restrictions on substances in packaging (e.g. limits on on lead content), mandatory recyclability requirements, and specific rules on extended producer responsibility for packaging waste.
Packaging must be designed for recycling by 1 January 2030 and capable of being recycled at scale by 1 January 2035. Additionally, minimum recycled content requirements for plastic packaging will be enforced as of 1 January 2030, including a 30% threshold for single-use plastic beverage bottles, with certain exceptions, such as medical devices. These minimum recycled content percentages are set to increase by 2040.
The most important changes are as follows:
- Compostable packaging – Certain types of packaging, such as filter coffee pods and produce stickers, must be compostable within two years of 11 February 2025, when the PPWR enters into force.
- Optimised packaging design – Packaging must minimise weight and volume, and new standards for reusable packaging will be introduced.
- New labelling requirements:
- Within 3.5 years, packaging labels must include clear information on material composition.
- Within 4 years, labels must also indicate whether the packaging is reusable.
- Reduced empty space in packaging – The PPWR limits the empty space ratio to 40% and requires businesses to implement systems for reusing reusable packaging.
- Ambitious reuse and refill targets:
- By 2030, at least 20% of cold and hot beverages sold in take-away containers must be in reusable packaging or part of a refill system.
- By 2040, this target increases to 80%.
- Plastic bag consumption limits – By the end of 2025, annual per capita consumption of lightweight plastic carrier bags must be limited to 40 bags, with exceptions for very lightweight bags used for hygiene or food preservation.
- Packaging waste reduction targets – Member States must reduce packaging waste per capita relative to 2018 levels by: 5% by 2030, 10% by 2035, and 15% by 2040.
- Improved collection & recycling systems – To enhance reuse and high-quality recycling, systems must be established for the return and separate collection of all packaging waste, with some exceptions.
- Mandatory deposit & return systems – By 1 January 2029, all Member States must implement deposit and return systems for single-use plastic beverage bottles and metal beverage containers of up to three litres, excluding certain products such as wine and spirits. Hungary has already introduced this system under the name “RePont.”
The recycling targets set by Directive 94/62/EC (the current Packaging and Packaging Waste Directive) will remain in force. Additional measures include bans on specific packaging formats by 31 December 2027, such as single-use plastic shrink wrap for suitcases and bags at airports, as well as grouped packaging for cosmetics (except perfumes), hygiene and toiletry products. Companies selling hot or cold beverages and ready-prepared food must allow consumers to use reusable packaging at no additional cost. Businesses must also enable consumers to bring their own containers for filling at a reduced price. Micro-companies will be exempt from certain obligations, such as packaging minimisation and minimum recycled content requirements.
The PPWR also introduces specific rules on extended producer responsibility (“EPR”) for packaging and packaging waste. It clearly establishes the responsible producer for domestic, cross-border and online/distance sales, and empowers the European Commission to adopt legislation harmonising the criteria for modulating financial contributions payable by producers to producer responsibility organisations (which collectively fulfil EPR obligations) in respect of certain characteristics of products or their packaging, e.g. reusability, recyclability. This modulation will create additional financial incentives to encourage more environmentally friendly packaging.
The PPWR was published in the Official Journal of the EU on 22 January 2025, and will enter into force on 11 February 2025. However, the PPWR will only apply starting 12 August 2026, providing stakeholders with an 18-month transition period to comply with the new rules.