PPWR

The EU Packaging and Packaging Waste Regulation — Regulation (EU) 2025/40 adopted in early 2025 replacing Directive 94/62/EC — sets binding recyclability, recycled-content, minimisation, reuse and labelling obligations on all packaging placed on the EU market, with progressive targets through 2030, 2035 and 2040. The elevation from directive to directly-applicable regulation removes member state transposition divergence. Key provisions: design-for-recyclability with A/B/C grading per category against material composition, separability, additive contamination, label/adhesive impact and infrastructure availability, with packaging below grade C prohibited from 2030; minimum recycled-content for plastic packaging from 2030 (contact-sensitive PET 30%, other contact-sensitive plastic 10%, non-contact-sensitive 35%) rising in 2040 (50%, 25%, 65% respectively) with mass-balance verification via ISCC Plus, REDcert² or equivalent chain-of-custody; packaging minimisation limiting empty space and over-engineering; format restrictions (single-use plastic for fresh produce, HORECA cosmetics sachets); mandatory deposit-return for in-scope single-use plastic and metal beverage containers from 2029; harmonised waste-sorting labelling pictogram from 2028 replacing the patchwork of national symbols. Extended Producer Responsibility (EPR) schemes operate in every member state — Citeo (France), Der Grüne Punkt/DSD (Germany), Conai (Italy), Ecoembes (Spain), Fost Plus (Belgium), Verpact (Netherlands) and equivalents — requiring producer registration, periodic packaging mass and material reporting, and per-unit fees increasingly modulated by recyclability and recycled-content under PPWR alignment. The 'distributor-as-producer' assumption is a frequent compliance failure — brand-owners controlling packaging design are 'producers' under most member state EPR rules regardless of commercial distribution arrangement, requiring direct registration and (in France, Germany and others) appointment of a designated representative where the brand has no EU establishment.