PPWR ObligationsEU Reg. 2025/40
Timeline · 2026–2040

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, restricted-substance limits including the PFAS ban in food-contact packaging (Art. 5), packaging minimisation (Art. 10) and EPR registration (Art. 45). Recyclability, recycled-content, 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

Key PPWR milestones — Regulation (EU) 2025/40
DateWhat happensCited
12 Aug 2026Regulation applies; Directive 94/62/EC repealed. Declaration of Conformity, heavy-metal limits and the PFAS ban in food-contact packaging, minimisation duty, and EPR registration all live.Art. 5, 10, 15, 45
By 12 Aug 2026Commission due to adopt implementing acts on the harmonised labelling format and on the digital methodology for identifying material composition. Pending as of 9 July 2026.Art. 12
~2028Design-for-recycling delegated act expected, defining the recyclability assessment methodology and grades A/B/C. Pending as of 9 July 2026.Art. 6, Annex II
12 Aug 2028Harmonised material-composition and separate-collection labelling obligation applies to packaging.Art. 12
1 Jan 2030Recyclability grade C becomes the minimum — packaging below grade C is not placeable on the market. Minimum recycled-content targets in plastic packaging apply. Empty-space cap (≤50%) applies to grouped, transport and e-commerce packaging. Reuse targets and Annex V single-use bans take effect.Art. 6, 7, 10, 29, Annex V
1 Jan 2035Recyclability assessed "at scale" — packaging must be recyclable in practice at the scale of installed EU sorting and recycling infrastructure.Art. 6
1 Jan 2038Only grades A and B remain placeable on the market — grade C packaging is phased out.Art. 6
1 Jan 2040The higher recycled-content targets for plastic packaging apply.Art. 7

What is due on day one (12 August 2026)

Several duties bite the moment the regulation applies, so they are the ones to plan for first:

  • Declaration of Conformity for each packaging type, held and produced to authorities on request.
  • Restricted substances (Art. 5): the ban on PFAS above threshold in food-contact packaging — with no grandfathering — and the sum of lead, cadmium, mercury and hexavalent chromium held at or below 100 ppm.
  • Minimisation (Art. 10): the general duty to minimise packaging weight and volume, documented.
  • EPR registration (Art. 45): 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 9 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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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 9 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

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