European Market

PPWR

Regulation (EU) 2025/40 on Packaging and Packaging Waste

EU Packaging and Packaging Waste Regulation

 

The Council of the European Union officially approved the Packaging and Packaging Waste Regulation on December 16, 2024. This new regulation will enter into force on February 11, 2025, and will apply from August 12, 2026.

The regulation aims to reduce the amount of packaging and packaging waste generated, while lowering the use of primary raw materials and promoting the transition to a circular, sustainable, and competitive economy. It replaces the Packaging and Packaging Waste Directive (PPWD), further harmonizing measures across Member States to strengthen the functioning of the internal market, particularly in secondary raw materials, manufacturing, recycling, and reuse.

Definition of Packaging

According to Article 3, “packaging” means any item used for the containment, protection, handling, transport or presentation of products, irrespective of the materials from which it is made, and which can be differentiated by packaging format based on its function, material and design.

Categories of packaging:
  1. Sales packaging - the smallest sales unit composed of product and packaging intended for the end user.
  2. Grouped packaging - packaging designed to group multiple sales units for sale, replenishment, storage, or distribution purposes.
  3. Transport packaging - packaging designed to protect products during handling and transport (excluding containers).
  4. E-commerce packaging - transport packaging used to deliver products to end users via online or other remote sales channels.

Regulatory Requirements

  • Substance requirements: The total concentration of four heavy metals (Pb, Cd, Hg, Cr6+) in packaging or packaging materials shall not exceed 100 ppm.
    From 2026/8/12, PFAS substances in food-contact packaging will also be restricted.
Controlled Substances EU (PPWR)
Lead, Cadmium, Mercury, Hexavalent Chromium
Pb, Cd, Hg, Cr6+

Total < 100 ppm
Per- and Polyfluoroalkyl Substances
PFAS

From 2026/8/12, limits for food-contact packaging:
Individual PFAS < 25 ppb (excluding polymeric PFAS)
Total PFAS < 250 ppb (excluding polymeric PFAS)
Individual PFAS < 50 ppm (including polymeric PFAS)
  • Recyclability requirements: From 2030, packaging must comply with design for recycling standards; from 2035, it must ensure effective collection, sorting and recycling, and large scale recycling in accordance with the applicable methodology.
  • Recycled content requirements: From 2030, all plastic packaging* must contain at least 35% recycled content.
  • Compostability requirements: Certain packaging, or packaging required by EU Member States, must meet compostability standards as well as recycling requirements.
  • Minimization requirements: From 2030, packaging weight and volume must be reduced and unnecessary packaging must be avoided.
  • Reuse requirements: Packaging must meet minimum reuse cycles, be cleanable and repairable, and must not adversely affect consumer health, safety or product quality.
  • Labeling requirements: Packaging must indicate material composition, reuse instructions and recycled content, and the labelling must be visibly, clearly and permanently affixed, printed or engraved on the packaging.

*Different levels depending on whether the packaging is or not contact-sensitive.

Penalties and Inspection Mechanism

  1. Penalties: Each Member State shall establish rules on penalties applicable to infringements of this regulation and shall take all necessary measures to ensure enforcement. Penalties must be effective, proportionate, and dissuasive.
  2. Inspection mechanism: The EU will publish RAPEX (Rapid Alert System for dangerous non-food products) notifications weekly based on post-market surveillance, customs inspections, and self-reporting by manufacturers and distributors.

SGS Services and Solutions

Packaging manufacturers should provide relevant documentation to demonstrate compliance with EU packaging regulations, including test results and audit verification. Companies using packaging materials for product protection must also verify supplier documentation. SGS provides comprehensive packaging regulatory solutions—please contact us for more information.

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Further Reading

  1. 出口歐美包裝回收標示要注意，SGS一同與您超前部署

  2. 【70週年永續ESG系列專題】歐美及國際包材法規趨勢 創造永續綠色包材

  3. 歐盟會員國舉報違反 REACH 與 POPs 法規 RAPEX 案例分享

  4. 2022 年 1 月份-歐盟會員國舉報違反 EU 法規 RAPEX 案例分享

  5. PPWR落地倒數：歐盟包材及包材廢棄物法規將於2026年8月中旬開始管制
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