PPWR: Important articles on packaging

Article 5: Requirements for Substances in Packaging

Article 5 of the PPWR regulation defines specific requirements for substances used in packaging. The EU pursues two main goals here: protecting the environment and ensuring consumer safety. Packaging materials may contain no more than 100 mg/kg of critical heavy metals such as lead, cadmium, mercury, and hexavalent chromium. The rules are especially strict for food packaging: if PFAS (per- and polyfluoroalkyl substances) limits are met or exceeded, the packaging may not be placed on the market.

Article 6: Recyclability of Packaging

From 2030 onwards, all packaging in the EU must be recyclable or reusable. The PPWR sets binding design requirements for packaging. Packaging is considered recyclable if it can be recycled into high-quality secondary raw materials that can replace primary materials. Additionally, it must not interfere with the recycling processes of other material streams. Starting January 1, 2035, packaging must also be practically recyclable on a large scale to contribute to the circular economy.

Recyclability Classification

A new classification system rates recyclability in three performance levels: A, B, and C. From 2030, packaging with less than 70% recyclability may no longer be sold. From 2038, this ban will also apply to Class C packaging with recyclability under 80%. The focus is on the principle of "design for recycling" – designing packaging specifically with recycling in mind. Companies should review and optimize their packaging concepts accordingly. This can also be financially beneficial: highly recyclable packaging will be subject to lower fees than hard-to-recycle options. Matching “Design for Recycling Guidelines” are expected to be published by the EU Commission by early 2028, with implementation about a year and a half later by member states.

Article 7: Use of Recycled Materials in Packaging

The PPWR requires manufacturers to include a minimum percentage of recycled material (post-consumer recycled material, or PCR) in packaging starting in 2030. This requirement varies depending on packaging type, material, and product category. The aim is to significantly reduce the use of virgin materials and close material loops. PCR content must be calculated annually per company and averaged by packaging type, with proof provided in technical documentation.

Required PCR content in plastic packaging from 2030:

• PET packaging with food contact: min. 30% (from 2040: 50%)
• Other plastic packaging with food contact: min. 10% (from 2040: 25%)
• Single-use beverage bottles: min. 30% (from 2040: 65%)
• Other plastic packaging: min. 35% (from 2040: 65%)

PCR targets for other materials:

• Glass: at least 50%
• Paper and cardboard: at least 70%
• Metal: at least 25%

Mandatory use of PCR comes with challenges. In particular, the availability and quality of suitable recyclates are major obstacles.

Article 8: Bio-Based Plastics

Unlike recycled materials, the PPWR currently does not set binding targets for the use of bio-based plastics. However, by February 12, 2028, the EU will assess whether such materials may count toward PCR quotas. This makes sense for several reasons: high-quality recyclates, especially for food contact, are already in short supply. At the same time, bio-based plastics can help reduce CO2 emissions and decrease dependence on fossil resources. Drop-in plastics like bio-PE may offer a viable, recyclable solution and ease the transition to sustainable packaging systems.

Article 9: Compostable Packaging

From February 12, 2028, certain packaging types must be compostable. This includes tea bags, coffee pods, and stickers on fruits and vegetables. A requirement here is biological degradability. Additionally, individual EU member states may designate further packaging types as compostable, provided suitable collection and disposal infrastructure is in place. These may include very lightweight carrier bags or coffee capsules.

Article 10: Reduction and Prevention of Packaging Waste

The PPWR aims to systematically reduce packaging waste. EU targets call for a reduction of 5% by 2030, 10% by 2035, and 15% by 2040. The focus is on avoiding unnecessary packaging and using materials more efficiently. As of January 1, 2030, packaging may only be as large as absolutely necessary. Prohibited will be things like double walls, unnecessary inserts, or misleadingly oversized packaging. Additionally, Article 24 regulates the maximum empty space in shipping packaging: from 2030, it may contain no more than 50% air or filler.

Articles 12 & 13: Packaging Labeling

From August 12, 2028, packaging must carry uniform labeling across the EU. This is to clearly inform consumers whether the packaging is recyclable, compostable, or reusable, and how to dispose of it correctly. Additional labeling requirements will apply to specific types of packaging, such as compostable or reusable ones, as well as those containing hazardous substances. Exact requirements will be detailed in a separate implementing act.

Article 25: Ban on Certain Single-Use Packaging

From January 1, 2030, certain single-use packaging types may no longer be placed on the market. These include:

• Single-use plastic packaging used to bundle products at the point of sale
• Packaging for fresh, unprocessed fruit and vegetables under 1.5 kg
• Single-use packaging for food and drinks meant for immediate consumption in hospitality
• Single-portion packs for sugar, creamer, condiments, and sauces
• Very lightweight plastic carrier bags under 15 microns
• Single-use packaging in hotels, such as hygiene item packaging

Additionally, Article 67 bans more plastic packaging, such as:

• Shrink wrap for luggage
• Polystyrene chips used as filler
• Plastic multipack rings
• Extruded polystyrene (XPS) packaging for ready-to-eat products

Composite packaging with up to 5% plastic content is exempt. However, paper packaging with plastic coating is not automatically considered sustainable, as it complicates recycling processes.

Articles 11 & 29: Reuse and Refill Requirements

The PPWR actively promotes the use of reusable packaging. From August 12, 2026, reuse systems must be available for certain types of packaging. Binding reuse quotas will apply from 2030:

• 10% for beverage packaging (from 2040: 40%)
• 40% for transport, retail, and e-commerce packaging (from 2040: 70%)
• 10% for outer packaging (from 2040: 25%)

Internal company packaging used between different locations must also be reusable. Paper, cardboard, and packaging for hazardous goods or large machinery are exempt. Starting in 2030, companies must submit annual compliance reports. The EU will define the calculation method by the end of June 2027.

Articles 32 & 33: Obligations for the Foodservice Sector

From February 12, 2027, foodservice businesses must offer to fill food and drinks into containers brought by customers. Starting in 2028, they must also provide reusable packaging that isn’t more expensive or inconvenient than single-use alternatives. Micro-enterprises with fewer than ten employees and less than two million euros in annual revenue are exempt. A binding EU-wide reuse quota for takeaway services is not planned but may be set nationally.

Articles 44 ff.: Extended Producer Responsibility (EPR)

The PPWR establishes extended producer responsibility. Producers must account for the environmental impact of their packaging throughout its lifecycle – from design to disposal. They are responsible for the collection, recovery, and recycling of their packaging. EPR is also intended to encourage the use of more environmentally friendly packaging. Implementation of EPR requirements into German law is planned with the next amendment of the Packaging Act in fall 2025.