EU PPWR Compliance White Paper: From Articles to Execution Checklist (Importer & Brand Edition, 2025-2026)

Executive summary—what you must do, by when

• Know the law: The Packaging & Packaging Waste Regulation is now Regulation (EU) 2025/40, published in the Official Journal on 22 Jan 2025, and applies from 12 Aug 2026.

• Design for recycling: From 1 Jan 2030, packaging may be placed on the EU market only if it attains recyclability grades A/B/C; from 1 Jan 2038, only A/B grades are allowed. Delegated acts to define grades/criteria come by 1 Jan 2028.

• Plastic recycled content: By 2030, minimums are 30% PET contact-sensitive, 10% other contact-sensitive plastics, 30% SUP beverage bottles, 35% other plastics; these rise for 2040 (e.g., 65% for bottles/other plastics). The calculation/verification method is due by 31 Dec 2026.

• Compostables: Permeable tea/coffee bags & soft single-serve units, and sticky fruit/veg labels must be industrially compostable by 12 Feb 2028 (and home-compostable where required).

• Labelling: The Commission will set harmonised labels (including digital/QR) by 12 Aug 2026. Waste receptacle labels must be in place by 12 Aug 2028.

• Deposit Return (DRS): Member States must run DRS for targeted formats to reach 90% separate collection; systems established after entry into force must meet minimum requirements by 1 Jan 2029.

• PFAS signal limit: The Regulation sets a 50 ppm total PFAS threshold (with documentation duties if total fluorine indicates exceedance).

• Context: EU packaging waste hit 186.5 kg per person in 2022, with 41% of plastic packaging recycled. Your strategy must drive absolute waste down and quality recycling up.

For a complete overview with charts, timelines, and implementation checklists, download our full EU PPWR Compliance White Paper (Importer & Brand Edition, 2025).
📥Download the White Paper (PDF)

1) Scope & roles: why importers/brands carry first-line liability

• Applicability: All packaging, all materials, all sectors. Importers may only place conforming packaging on the market and must ensure labelling, technical documentation and traceability are in order before first placing.

• Producer responsibility data: Lighter reporting applies below 10 t/year per Member State, with annual submissions by 1 June.

Implication: Build an internal “PPWR Owner” role (Regulatory Manager) with authority to block shipments lacking technical files, labels, or conformity evidence.

2) Design-for-recycling (DfR) & recyclability grades

• Gate 2030: Only A/B/C recyclable packaging allowed; criteria and grade thresholds will be defined via delegated/implementing acts. Technically non-recyclable is <70%, per Annex II tables used by future acts.

• Gate 2038: Only A/B allowed.

Importer/Brand action:

1. Run material-by-SKU assessments against emerging DfR criteria; 2) Remove non-compliant components (e.g., disruptive inks/adhesives); 3) Validate sortability and recycled-at-scale pathways per the upcoming methodology.

3) Mandatory recycled content—plastic

Minimum recycled content per packaging type (Avg. per plant/year):

• By 2030: 30% PET contact-sensitive; 10% other contact-sensitive plastics; 30% SUP beverage bottles; 35% other plastics.

• By 2040: 50% PET contact-sensitive; 25% other contact-sensitive plastics; 65% SUP beverage bottles; 65% other plastics.
  Verification method: Implementing act by 31 Dec 2026; labels indicating recycled share must follow specs from 12 Aug 2028 (or 24 months after relevant act).

Action: Contractually require chain-of-custody data from recyclers; budget for third-party audits once the verification act enters into force.

4) Compostable items—narrow and dated

• By 12 Feb 2028, the following must be industrially compostable:
  a) Permeable tea/coffee bags & soft single-serve units used with the product;
  b) Sticky labels on fruit/vegetables;
  and home-compostable where a Member State requires.

Action: For tea/coffee and fresh produce SKUs, confirm substrate certification to EN 13432 (or successor) via notified bodies; align liner/adhesive/ink systems.

5) Labelling and digital data carriers

• Commission acts by 12 Aug 2026: Harmonised labels, formats, and standardised open digital carriers (QR) for material ID, EPR identification and (by 2030) substances-of-concern disclosure.

• Waste receptacle labels by 12 Aug 2028; DRS labels aligned with EU specs; avoid misleading sustainability marks.

Action: Reserve panel/QR space on artworks now; update label architecture once acts publish; link QR to live technical data (material codes, end-of-life, EPR scheme ID).

6) DRS, separate collection & recycling targets

• DRS: Obligation to meet 90% collection for specified beverage formats; systems set up after entry into force must meet minimum requirements by 1 Jan 2029; legacy systems exempt if already at 90% by 2029.

• EU Recycling targets: 60–75% by material and 70% overall by 2030 retained; check national trajectories.

Action: Confirm SKU coverage in Member State DRS; harmonise barcodes/markings; model deposit cash flows and reverse logistics.

7) Chemicals signals—PFAS

• PFAS threshold: 50 ppm total PFAS (as fluorine) triggers documentation duties; be ready to provide proof of measured quantities upon request. Build PFAS-free specifications where feasible.

8) Market context—why this matters commercially

• 186.5 kg per person packaging waste in 2022; 83.4 Mt total; 41% of plastic packaging recycled. Customer tenders and retailers will increasingly gatekeep on PPWR readiness and verified recycled content.

9) 12-week PPWR implementation plan (importer/brand)

Week 1–2 | Mobilise & map

• Appoint PPWR Owner; build RACI.

• Map SKUs to material families; flag contact-sensitive plastics; tag DRS-subject items.

• Kick off supplier data request (DfR, recycled content, compostability, PFAS declaration).

Week 3–4 | Risk screen

• Score SKUs vs. 2030 A/B/C recyclability; identify adhesives/inks/add-ons at risk.

• For bagasse/paper bowls/cups, validate wet-strength chemistries; for CPLA, validate crystallinity/heat-deflection and sortability.

• Draft artwork panel for QR + harmonised labels.

Week 5–6 | Redesign & sourcing

• Replace non-compliant components; align pigments/inks to DfR.

• Lock recycled-content supply (PCR PET/PP/PE streams); define audit trail to meet 2026 verification act.

Week 7–8 | Documentation & testing

• Build Annex VII-style technical files (materials, DfR rationale, recyclability grade evidence path, recycled content calc basis).

• Lab trials: delamination, ink bleed, compaction, MRF detectability.

Week 9–10 | Labelling & digital

• Generate EPR/DRS identifiers; configure QR landing with material codes, disposal guidance, recycled content claim (if used).

Week 11 | Legal & commercial

• Update Supplier Quality Agreement (SQA) with recycled content warranties, change notification, PFAS clause, and audit rights.

• Align DRS handling fees in pricing.

Week 12 | Go-live & review

• Pilot in 1–2 Member States; monitor return/complaint signals.

• Finalise 2026–2030 roadmap to upgrade to A/B by 2038.

10) ERP/PLM field template (aligned to bagasse / paper bowl / paper cup / CPLA)

Use these data fields per SKU to comply and future-proof against 2028/2030 milestones.

Core identification

• SKU, GTIN/EAN, EU status (importer/producer), Member State(s) placed on market, EPR Register ID(s).

Material & construction

• Predominant material (per Annex II table), share by weight (%), component list (lid, liner, label, adhesive, ink/varnish), barrier/coating type, pigment masterbatch ID(s).

Recyclability & DfR

• Target grade (A/B/C) and justification; sortability features; detachable components; MRF tests performed; anticipated recycled-at-scale pathway.

Recycled content (plastics only)

• 2030/2040 target bucket; % recycled (avg. per plant, per year); feedstock origin (post-consumer); verification method (per 2026 act); audit evidence link.

Compostability (if applicable)

• Item falls under Art. 9(1) list (Y/N); certificate ID (industrial/home where required); test house; expiry.

Labelling & digital

• Harmonised label set applied; language set; DRS mark (Y/N); QR schema: material code, disposal route, EPR ID, recycled % (if claimed).

Chemicals

• PFAS screening result (ppm F); compliance evidence location.

Logistics/Dimensions

• Empty space ratio (for Article 24); unit dimensions; case/pallet optimisation; transport damage rate.

Category add-ons

• Bagasse bowls: wet-strength additive family; oil/grease resistance rating; hot-fill max temp.

• Paper cups/bowls: liner type (PE/dispersion/bioliner); delamination test; cup-stock fibre (virgin/recycled).

• CPLA cutlery: crystallinity %, heat-deflection temp, MRF detectability; disassembly notes.

Download the PPWR Compliance Kit (Excel, 4 sheets)

11) Importer/brand audit checklist (excerpt)

• Before import: Verify Article 12 labelling readiness, technical file completeness, and PFAS statement.

• At goods receipt: Random-check QR resolves to current data; confirm DRS mark where applicable.

• Quarterly: Review recycled content plant averages; prepare for third-party verification per 2026 act.

12) KPIs to manage

• % SKUs mapped to A/B/C; % volume already A/B.

• % plastic SKUs meeting 2030 minimums (by format).

• % compostable SKUs certified per Art. 9(1) obligations.

• % labels compliant with 2026 acts; % bins/receptacles labelled by 2028.

• DRS return rate trend toward 90%.

FAQ

Q1. When does PPWR start to apply?
A. It applies from 12 Aug 2026 across all Member States (directly applicable regulation).

Q2. My tea bags/coffee pods—what’s special?
A. Permeable tea/coffee bags and soft single-serve units, plus sticky labels on fruit/veg, must be industrially compostable by 12 Feb 2028 (home-compostable if a Member State requires).

Q3. Do I need to hit recyclability grade targets now?
A. Grades A/B/C become a market access condition from 1 Jan 2030, then A/B only from 1 Jan 2038. Use 2025–2029 to redesign and validate.

Q4. How do I calculate recycled content for plastics?
A. Follow the Commission implementing act due by 31 Dec 2026; calculate as average per manufacturing plant/year for the defined format.

Q5. Can I claim recycled % on-pack now?
A. You can, but from 12 Aug 2028 such claims/labels must follow the PPWR specs (and the Article 7 methodology).

Q6. What about DRS coverage?
A. Member States must ensure DRS reach 90% collection for the targeted beverage formats; systems set up after entry into force must meet minimum requirements by 1 Jan 2029.

Q7. Do I need to change my bin labels?
A. Yes—harmonised labels on waste receptacles by 12 Aug 2028, aligned to packaging labels established by 12 Aug 2026.

Q8. Is there a PFAS limit?
A. The Regulation sets a 50 ppm total PFAS threshold, triggering documentation duties; many brands are moving to PFAS-free specs.

References

1. 1. European Commission – Regulation (EU) 2025/40 on Packaging and Packaging Waste.

   2. Official Journal of the European Union, Jan 2025 – PPWR full text.

   3. European Council Press Release – Agreement on Packaging and Packaging Waste Regulation.

   4. Eurostat – Packaging waste statistics, 2022.

   5. European Parliament – Circular Economy and Sustainable Packaging reports.

   6. RecyClass – Design-for-Recycling Guidelines.

   7. CEN – EN 13432: Requirements for packaging recoverable through composting.

   8. Ellen MacArthur Foundation – Global Commitment progress report.

   9. European Environmental Bureau – PFAS in food packaging.

   10. OECD – Extended Producer Responsibility in packaging systems.

   11. European Commission – FAQs on Single-Use Plastics Directive and transition to PPWR.