EU Packaging and Packaging Waste Regulation (PPWR) Overview

On 22 January 2025, the Official Journal of the European Union formally published the Packaging and Packaging Waste Regulation 2025/40 (PPWR), which fully replaces the nearly 30-year-old Directive on Packaging and Packaging Waste (94/62/EC, PPWD). The PPWR will enter into full application on 12 August 2026, reshaping the rules for the full life cycle management of packaging in the EU.

I. Legal Status: Upgrading from 'Directive' to 'Regulation' – Comprehensive Enhancement of Legal Effect and Supervision

The most significant difference between the PPWR and the old directive (PPWD) is its upgrade from a 'directive' to a 'regulation': it is directly applicable in all EU Member States without national transposition, completely eliminating regulatory differences between Member States and establishing a unified market access threshold.

Scope of Application (Article 2)

Covers packaging and packaging waste of all materials (plastic, paper, metal, glass, composite materials, etc.) and in all scenarios (industrial, commercial, consumer goods, logistics packaging, etc.), regardless of whether they originate from factories, shops, offices or households. Packaging of imported products is also subject to this regulation.

II. Breakdown of Core Requirements: Full-Chain Constraints from Substance Control to Circular Utilization

1. Substance Requirements in Packaging (Article 5): Strict Control of Heavy Metals and PFAS

Heavy metal limits: Total content of lead, cadmium, mercury and hexavalent chromium ≤ 100 mg/kg (effective 12 August 2026).
PFAS control (restrictions on food contact packaging effective 12 August 2026):
- Individual monomeric PFAS (non-polymeric) ≤ 25 ppb;
- Sum of all monomeric PFAS (non-polymeric) ≤ 250 ppb;
- Total fluorine content of packaging containing polymeric PFAS ≤ 50 ppm (if total fluorine content exceeds 50 mg/kg, a fluorine content certificate must be provided for the preparation of technical documentation).

2. Recyclable Packaging Requirements (Article 6): From 'Theoretically Recyclable' to 'Practically Operable'

Core objective: Implement the 'design for recycling (DfR)' principle to ensure packaging can be efficiently recycled in practice.
Basic requirements: As of 1 January 2030, all packaging placed on the EU market must be recyclable and meet recyclability grades A, B or C. Packaging with a DfR score < 70% is considered 'technically unrecyclable' and prohibited from being placed on the market. From 1 January 2038 onwards, only packaging with recyclability grades A or B will be permitted on the market.
Exemption list (until the review on 1 January 2035):
1. Pharmaceutical packaging;
2. Contact-sensitive packaging for medical devices;
3. Contact-sensitive packaging for infant formula or foods for special medical purposes;
4. Sales packaging made of lightweight wood, cork, textiles, rubber, ceramics, porcelain or wax.

3. Recycled Content and Bio-Based Requirements (Articles 7-8): Promoting 'Waste-to-Resource' for Plastic Packaging

Recycled content (Article 7): All plastic packaging placed on the market must contain the following minimum percentages of recycled content recovered from post-consumer plastic waste:

Material	1 January 2030	1 January 2040
PET contact-sensitive packaging (excluding single-use beverage bottles)	30%	50%
Non-PET contact-sensitive packaging (excluding single-use beverage bottles)	10%	25%
Single-use plastic beverage bottles	30%	65%
Other plastic packaging	35%	65%

Bio-based materials (Article 8): By 12 February 2028, the EU will review the technical and environmental performance of bio-based plastic packaging and develop:
1. Sustainability requirements for bio-based raw materials;
2. Targets for increasing bio-based material use;
3. Provisions allowing bio-based raw materials to replace recycled content to meet recycled content targets when appropriate recycling technologies are unavailable;
4. Revised definition of bio-based plastics.

4. Compostable Packaging (Article 9): Regulating 'Degradable' Claims to Avoid Misleading Consumers

By 12 February 2026: The EU will require the development of uniform technical specifications for compostable packaging;
By 12 February 2028: Compostable packaging (including biodegradable plastics) must be designed for material recovery as a priority and must not impair the recyclability of other waste streams (to prevent pseudo-compostable packaging from disrupting recycling systems).

5. Packaging Minimization (Article 10): Reducing 'Excessive Packaging' at the Source

By 12 February 2027: The EU will develop calculation methods and standards for packaging minimization (e.g., limits on maximum weight, volume, wall thickness and empty space);
As of 1 January 2030: Manufacturers/importers must ensure that packaging weight and volume are minimized (while meeting functional requirements), eliminating ineffective designs such as false bottoms and excessive layers.

III. Key Timelines: Enterprise Compliance Countdown

Date	Core Requirement
22 January 2025	PPWR officially published, replacing Directive 94/62/EC
12 February 2026	EU requires development of uniform technical specifications for compostable packaging
12 August 2026	PFAS restrictions (food contact packaging) and total heavy metal limits enter into force; packaging substance requirements fully implemented
12 February 2027	EU develops calculation methods and standards for packaging minimization
12 February 2028	① Review of bio-based plastic packaging technology; ② Compostable packaging must be designed for material recovery as a priority
1 January 2030	Packaging weight and volume must be minimized (subject to functional requirements)
1 January 2035	Review of the recyclable packaging exemption list (pharmaceuticals, infant food packaging, etc.), with possible adjustments to the exemption scope

IV. Recommendations from HIC Testing: Three-Step Approach to Address PPWR Challenges

Faced with the PPWR's 'full-chain strict regulation', enterprises need to take proactive actions in three aspects: compliance screening, design optimization and system establishment.

1. Early Screening for Substance Compliance

For food contact packaging, focus on testing heavy metals (lead, cadmium, mercury, hexavalent chromium) and PFAS (monomer content, total fluorine content), and establish a supply chain composition database;
Pay attention to the particularities of PFAS testing (need to distinguish between monomers and polymers) to avoid misjudgments caused by deviations in testing methods.

2. Robust Assessment of Recyclability

Engage third-party institutions to conduct recyclability grading (A/B/C) of packaging and optimize structures (e.g., avoid multi-layer composites and difficult-to-separate materials);
Monitor developments in the exemption list (to be reviewed in 2035) and plan recyclable designs for non-exempt packaging in advance.

3. Steady Implementation of Systems and Labeling

Track standards for minimization, compostability and other aspects developed by the European Committee for Standardization (CEN) and adjust packaging designs in a timely manner;
Prepare in advance for labeling requirements for information such as carbon footprint and recycled material proportion (subsequent regulations may expand these requirements).