PPWR deadlines: the full timeline from 2026 to 2040
The PPWR applies from 12 August 2026, when Regulation (EU) 2025/40 replaces the old Packaging Directive. From that date the day-one duties are live: the Declaration of Conformity and technical documentation (Art. 15), restricted-substance limits including the PFAS limits in food-contact packaging (Art. 5), the requirement that packaging be recyclable in principle (Art. 6(1)), and EPR registration (Art. 44). Packaging minimisation (Art. 10), the recyclability grades, recycled-content targets, the 50% empty-space cap (Art. 24), reuse and labelling obligations then phase in on set dates through to 2040.
This is general information about Regulation (EU) 2025/40, not legal advice. Confirm anything you act on with qualified counsel or an accredited body.
The dated timeline
| Date | What happens | Cited |
|---|---|---|
| 12 Aug 2026 | Regulation applies; Directive 94/62/EC repealed. Declaration of Conformity and technical documentation, heavy-metal limits and the PFAS limits in food-contact packaging, the requirement that packaging be recyclable in principle (Art. 6(1)), and EPR registration all live. The existing EU minimisation requirements carry over until 31 December 2029 (Art. 70(1)(b)). | Art. 5, 6, 15, 44, 70 |
| By 12 Aug 2026 | Commission due to adopt implementing acts on the harmonised labelling format and on the digital methodology for identifying material composition. Pending as of 10 July 2026. | Art. 12 |
| 12 Feb 2027 | Member states must notify the Commission of their national penalty rules for PPWR breaches. | Art. 68 |
| By 1 Jan 2028 | Design-for-recycling delegated acts due, defining the recyclability assessment methodology and grades A/B/C. Pending as of 10 July 2026. | Art. 6, Annex II |
| 12 Feb 2028 | Operators filling sales packaging must minimise the empty space in that packaging; and the Commission's empty-space calculation-methodology implementing act is due. | Art. 24, 24(2) |
| 12 Aug 2028 | Harmonised material-composition and separate-collection labelling obligation applies, from 12 August 2028 or 24 months after the labelling implementing act enters into force, whichever is later. | Art. 12(1) |
| 1 Jan 2029 | Deposit-return systems for single-use plastic and metal beverage containers must be operational (a member-state duty; some states may be exempt where separate-collection rates are high). | Art. 50 |
| 12 Feb 2029 | Reusable packaging must bear a label identifying it as reusable, from 12 February 2029 or 30 months after the labelling implementing act, whichever is later. | Art. 12(2) |
| 1 Jan 2030 | Recyclability grade C becomes the minimum, packaging below grade C is not placeable on the market (this floor is 1 January 2030 or 24 months after the design-for-recycling delegated acts enter into force, whichever is later). Minimum recycled-content targets in plastic packaging apply. The empty-space cap (≤50%, Art. 24) applies to grouped, transport and e-commerce packaging (1 January 2030 or 3 years after the Art. 24(2) methodology act, whichever is later). Reuse targets and Annex V single-use bans take effect. The PPWR minimisation standard (Art. 10) applies. | Art. 6, 7, 10, 24, 29, Annex V |
| 1 Jan 2035 | Recyclability assessed "at scale", packaging must be recyclable in practice at the scale of installed EU sorting and recycling infrastructure. | Art. 6 |
| 1 Jan 2038 | Only grades A and B remain placeable on the market, grade C packaging is phased out. | Art. 6 |
| 1 Jan 2040 | The higher recycled-content targets for plastic packaging apply. | Art. 7 |
What is due on day one (12 August 2026)
Several duties take effect the moment the regulation applies, so they are the ones to plan for first:
- Declaration of Conformity and technical documentation (Art. 15): for each packaging type, held and produced to authorities on request (retained 5 years for single-use, 10 years for reusable packaging).
- Restricted substances (Art. 5): the PFAS limits in food-contact packaging placed on the market from 12 August 2026, 25 ppb for any single PFAS, 250 ppb for the sum of PFAS, 50 ppm for PFAS including polymeric, and the sum of lead, cadmium, mercury and hexavalent chromium held at or below 100 mg/kg.
- Recyclable in principle (Art. 6(1)): all packaging placed on the market must be recyclable; the graded design-for-recycling assessment and market bans phase in from 2030.
- EPR registration (Art. 44): being registered and paying fees in each market you place packaging in.
Why the later dates depend on pending acts
Some of the most consequential thresholds, the recyclability methodology and grades (Art. 6, Annex II) and the harmonised labelling format (Art. 12), are set out in the regulation but detailed in implementing and delegated acts the Commission has yet to finalise as of 10 July 2026. The framework dates are fixed in the regulation; the operational detail firms up as those acts are adopted, which is why any responsible timeline flags them as provisional. Check the Commission's packaging page for the current status.
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Get my PPWR obligations report →Frequently asked questions
When does the PPWR come into force?
Regulation (EU) 2025/40 entered into force in early 2025 and applies from 12 August 2026, at which point it repeals the old Packaging Directive 94/62/EC. Most day-one obligations start on that date.
What is the deadline for recycled content in plastic packaging?
The first minimum recycled-content targets apply from 1 January 2030, and a higher set of targets applies from 1 January 2040 (Article 7). The exact percentage depends on the material, contact-sensitivity and whether it is PET.
When must packaging carry the new labels?
The harmonised material-composition and separate-collection labelling obligation applies from 12 August 2028 (Article 12). The implementing acts defining the label format are due by 12 August 2026 but were still pending as of 10 July 2026.
When is grade C packaging banned?
Grade C is the minimum recyclability grade from 1 January 2030 (below C is not placeable on the market), and grade C itself is phased out from 1 January 2038, after which only grades A and B may be placed on the market (Article 6).
Sources
- Regulation (EU) 2025/40 (PPWR), application date and repeal of 94/62/EC; Art. 5, 6, 7, 10, 12, 24, 29, 44, 45, 50, 68, 70; Annex II; Annex V, https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng
- European Commission, Packaging and packaging waste (guidance and implementing/delegated acts status), https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste_en
- European Commission, Commission guidance C(2026)3702 on the relationship between the Article 10 minimisation and Article 24 empty-space requirements and the Article 70 transitional rules, and the Commission's PPWR FAQ (30 March 2026).