PPWR deadlines: the full timeline from 2026 to 2040
The PPWR has applied since 12 August 2026, when Regulation (EU) 2025/40 replaced the old Packaging Directive. Seven business duties started that day: the PFAS and heavy-metal limits (Art. 5(4), 5(5)), conformity documentation (Art. 15), registration in each market (Art. 44), extended producer responsibility (Art. 45), the ban on misleading sustainability labels (Art. 12(8)) and the re-use system duties for reusable packaging (Art. 26, 27). The next business deadline is 12 February 2027, when take-away food and drink sellers must let customers bring their own container (Art. 32). On 12 February 2028 come the reusable take-away offer (Art. 33), minimum empty space in sales packaging (Art. 24(4)) and the compostable and recyclable design rules (Art. 9). Labelling, recycled content, minimisation (Art. 10), recyclability grades, the 50% empty-space cap and re-use targets then phase in through to 2040, several of them later if the Commission act behind them is late.
This is general information about Regulation (EU) 2025/40, not legal advice. Confirm anything you act on with qualified counsel or an accredited body.
Business deadlines
| Date | What happens | Cited |
|---|---|---|
| 11 Feb 2025 | Entry into force. Packaging placed on the market from this date counts as reusable only if it meets every condition in Art. 11(1). Reusable packaging already on the market before it is outside the manufacturer's duty to bring non-conforming packaging into conformity, withdraw or recall it. | Art. 11(1), 15(9) |
| 12 Aug 2026 | Regulation applies; Directive 94/62/EC repealed. Seven duties live: the PFAS limits in food-contact packaging (25 ppb for any single PFAS, 250 ppb for the sum, 50 ppm including polymeric) and the 100 mg/kg heavy-metal sum limit; conformity assessment, technical documentation and the EU declaration of conformity; registration in each member state where a producer first makes packaging available; extended producer responsibility, including an authorised representative wherever a producer sells directly to end users in a member state where it is not established; no misleading sustainability labels; and re-use systems and reconditioning for reusable packaging. The old Directive's minimisation requirement continues until 31 December 2029 (Art. 70(1)(b)). | Art. 5(4), 5(5), 12(8), 15, 26, 27, 44, 45, 71 |
| 12 Feb 2027 | Hotel, restaurant and catering businesses selling take-away drinks or ready-prepared food must let customers bring their own container, at no higher cost than single-use and signposted at the point of sale. No micro-enterprise exemption. Packaging in an EPR scheme may be identified by a symbol in a QR code or other standardised, open digital marking. | Art. 32, 12(9) |
| 12 Feb 2028 | The same take-away sellers must also offer reusable packaging within a re-use system (micro-enterprises exempt). Operators filling sales packaging must reduce empty space to the minimum necessary for functionality. Tea and coffee bags, soft single-serve units and fruit and vegetable stickers must be compatible with industrial composting; all other packaging, including biodegradable plastic, must be designed for material recycling. The Commission's methodology for calculating the empty-space ratio behind the 50% cap is due the same day. | Duties: Art. 9(1), 9(3), 24(4), 33. Methodology: Art. 24(2) |
| 12 Aug 2028 | Harmonised material-composition label, with digital marking for substances of concern and a label on deposit-return packaging; voluntary recycled-content labels must follow the EU format; producers must explain the labels to end users. 12 August 2028 or 24 months after the Art. 12(6) and 12(7) implementing acts enter into force, whichever is later. Those acts had not been adopted by 29 September 2026, so this date will fall later. | Art. 12(1), 12(4), 55(1)(d) |
| 1 Jan 2029 | Recycled content in plastic packaging must be calculated and verified by the rules in the Art. 7(8) implementing act. 1 January 2029 or 24 months after that act enters into force, whichever is later. | Art. 7(11) |
| 12 Feb 2029 | Reusable packaging must carry a label saying it is reusable, from 12 February 2029 or 30 months after the Art. 12(6) act enters into force, whichever is later, so later than this date. The Art. 67(5) changes to the Single-Use Plastics Directive apply on the fixed date: reworded entries for EPS and XPS food and beverage containers and cups, and new market restrictions on airport and station luggage shrink wrap, polystyrene and other plastic packing chips, and multi-pack plastic rings. | Art. 12(2), 67(5), 71 |
| 31 Dec 2029 | Last day of the old Directive's minimisation requirement (Directive 94/62/EC, Annex II, point 1, first indent, assessed against EN 13428:2004); from 1 January 2030 the PPWR's own minimisation rules take over. | Art. 70(1)(b) |
| 1 Jan 2030 | Recyclability grade A to C floor (or 24 months after the Art. 6(4) delegated acts enter into force, whichever is later), with a derogation of up to 5 years for innovative packaging. Minimum recycled content in plastic packaging: 30% contact-sensitive PET, 10% other contact-sensitive plastics, 30% single-use plastic beverage bottles, 35% other (or 3 years after the Art. 7(8) act, whichever is later). Minimisation of weight and volume, and no packaging that fails the Annex IV criteria or has double walls, false bottoms or unnecessary layers. The 50% empty-space cap for grouped, transport and e-commerce packaging (or 3 years after the Art. 24(2) act, whichever is later). Annex V single-use bans. Re-use targets for transport packaging, grouped boxes and beverages, with proof required (or 18 months after the Art. 30(3) act, whichever is later). Best efforts on refill stations in shops over 400 m² and on a 10% reusable offer in HORECA. | Art. 6(2)(a), 6(3), 6(10), 7(1), 10(1), 10(2), 24(1), 25, 28(5), 29, 30(4), 33(5), 67(2)-(3), Annex V |
| 30 Jun 2031 | First annual re-use report, covering 2030, due to the national competent authority. | Art. 31 |
| 12 Aug 2031 | Sell-through for unlabelled stock ends: packaging made or imported before the labelling duties applied may be made available for 3 years after they apply. 12 August 2031 at the earliest, 12 February 2032 for the reusable label, and later with the labelling dates. | Art. 12(12) |
| 1 Jan 2035 | Recyclable at scale: packaging must be collectable, sortable and recyclable at scale, not only designed for recycling. 1 January 2035 or five years after the Art. 6(5) implementing acts enter into force, whichever is later. | Art. 6(2)(b) |
| 1 Jan 2038 | Only grades A and B may be placed on the market; grade C is phased out. | Art. 6(3) |
| 1 Jan 2040 | Higher recycled content: 50% contact-sensitive PET, 25% other contact-sensitive plastics, 65% single-use plastic beverage bottles, 65% other. Operators shall endeavour to reach 70% reusable transport packaging, 25% reusable grouped boxes and 40% of beverages in reusable packaging. | Art. 7(2), 29 |
Member-state deadlines and the Commission acts behind the business dates
| Date | What happens | Cited |
|---|---|---|
| 12 Jul 2025 | Member states notify the Commission of their competent authorities. | Art. 40(3) |
| 31 Dec 2025 | Member states: 65% of packaging waste recycled, with per-material rates; lightweight plastic carrier bags at or below 40 per person a year; a member state that finds a substance harms re-use or recycling sends that information to the Commission and ECHA; member states may ask for a base year other than 2018. | Art. 5(2), 34(1), 43(8), 52(1)(a)-(b) |
| 12 Feb 2026 | Commission: implementing acts on the producer-register format. National registers are due 18 months after they enter into force (Art. 44(1)). | Art. 44(14) |
| 12 Aug 2026 | Member states: Directive 94/62/EC repealed, except the parts Art. 70(1)(a) to (d) keep for a transition. Commission: labelling acts and the waste-receptacle label act due. The Art. 12(6) and 12(7) acts had not been adopted by 29 September 2026. | Art. 12(6), 12(7), 13(2), 70(1) |
| 31 Dec 2026 | Commission: implementing act on calculating and verifying recycled content, which starts the Art. 7(1) and 7(11) clocks. | Art. 7(8) |
| 12 Feb 2027 | Member states lay down penalty rules and notify them to the Commission. | Art. 68(1), 68(3) |
| 30 Jun 2027 | Commission: methodology for calculating the re-use targets, which starts the Art. 30(4) clock. | Art. 30(3) |
| 1 Jan 2028 | Commission: design-for-recycling delegated acts, which start the grade-floor clock. Member states: last date to seek a deposit-return exemption with an implementation plan. | Art. 6(4), 50(5)(b) |
| 12 Feb 2028 | Commission: methodology for calculating the empty-space ratio. The 50% cap stays at 1 January 2030 only if this act enters into force by 1 January 2027. | Art. 24(2) |
| 12 Aug 2028 | Member states: harmonised labels on all packaging-waste receptacles (or 30 months after the adoption of the Art. 13(2) acts, whichever is later). Decision 97/129/EC, the old material identification system, repealed. | Art. 13(1), 70(2) |
| 31 Dec 2028 | Member states: the old Directive's re-use accounting, 2025 targets and reporting rules end (data transmission to the Commission until 31 December 2029). | Art. 70(1)(c)-(d) |
| 1 Jan 2029 | Member states: collection objectives; 90% separate collection of single-use plastic beverage bottles and metal beverage containers up to 3 litres, with deposit and return systems for them (exemptions in Art. 50(3) to (5)); Annex X minimum requirements for deposit systems. | Art. 49, 50 |
| 1 Jan 2030 | Commission: recycled-at-scale methodology, which starts the Art. 6(2)(b) clock. Member states: national restrictions on Annex V formats may be kept until this date. | Art. 6(5), 70(4) |
| 31 Dec 2030 | Member states: 70% of packaging waste recycled, with the 2030 per-material rates; packaging waste per person down 5% on 2018. | Art. 43(1)(a), 52(1)(c)-(d) |
| By 2035 | Member states: packaging waste per person down 10% on 2018. | Art. 43(1)(b) |
| By 2040 | Member states: packaging waste per person down 15% on 2018. | Art. 43(1)(c) |
The Commission acts listed are the ones whose timing sets or moves a business date; its other reports, reviews and guidelines are left out.
Dates that wait on an act
Five provisions have no calendar date, because each runs only from a Commission act:
- Old marking rules (Art. 70(1)(a)): Art. 8(2) of Directive 94/62/EC keeps applying until 30 months after the Art. 12(6) labelling act enters into force.
- National producer registers (Art. 44(1)): due 18 months after the Art. 44(14) implementing act enters into force; until then producers register in the existing national registers.
- EPR fees modulated by recyclability grade (Art. 6(8)): 18 months after the Art. 6(4) delegated acts and Art. 6(5) implementing acts enter into force.
- Packaging databases (Art. 57(1)): 12 months after the adoption of the Art. 56(7) implementing acts, due 12 February 2027.
- Customs connection (Art. 61(4)): no later than 24 months after the Art. 61(5) implementing act, which has no deadline.
What is due on day one (12 August 2026)
Seven business duties have applied since 12 August 2026, with no phase-in:
- PFAS in food-contact packaging (Art. 5(5)): food-contact packaging placed on the market from 12 August 2026 may not contain PFAS at or above 25 ppb for any single PFAS, 250 ppb for the sum of PFAS, or 50 ppm for PFAS including polymeric PFAS.
- Heavy metals (Art. 5(4)): the sum of lead, cadmium, mercury and hexavalent chromium held at or below 100 mg/kg.
- Conformity documentation (Art. 15): the Art. 38 conformity assessment, the Annex VII technical documentation and the EU declaration of conformity for each packaging type, kept 5 years for single-use and 10 years for reusable packaging.
- Registration (Art. 44(2), (4)): registered in the producer register of each member state where you first make packaging or packaged products available, before you make them available there.
- Extended producer responsibility (Art. 45(1), (3)): EPR for the packaging you first make available in a member state, and an authorised representative in each member state where you sell directly to end users without being established there.
- No misleading labels (Art. 12(8)): no labels, marks, symbols or inscriptions likely to mislead or confuse consumers about the packaging's sustainability, its other characteristics or how to dispose of it.
- Re-use systems (Art. 26(1), 27(1)-(2)): anyone first making reusable packaging available must ensure a re-use system meeting Annex VI exists, take part in one, and recondition the packaging before it is used again.
Art. 6(1) also says all packaging placed on the market shall be recyclable, but the conditions that decide whether packaging counts as recyclable apply from 1 January 2030 (design for recycling) and 1 January 2035 (recycled at scale), later still if the Commission acts behind them are late (Art. 6(2)). Minimisation under Art. 10(1) and 10(2) applies from 1 January 2030; until the end of 2029 the old Directive's minimisation requirement (EN 13428:2004) applies under Art. 70(1)(b), as the Commission's guidance C(2026)3702 confirms.
Why the later dates depend on pending acts
Several business dates run from Commission implementing or delegated acts: the date is the later of the calendar date in the regulation and a set period after the act enters into force. The Art. 12(6) and 12(7) labelling acts were due by 12 August 2026 and had not been adopted as at 29 September 2026, so the material-composition label (Art. 12(1)) will apply later than 12 August 2028 and the reusable label (Art. 12(2)) later than 12 February 2029. The recyclability grades (Art. 6(4)), recycled-content calculation (Art. 7(8)), empty-space ratio (Art. 24(2)) and re-use target (Art. 30(3)) acts are due between 31 December 2026 and 12 February 2028. 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 on 11 February 2025 and has applied since 12 August 2026, when it repealed the old Packaging Directive 94/62/EC. Seven business duties started on that date. The next business deadline is 12 February 2027, when take-away food and drink sellers must let customers bring their own container (Article 32).
When do the take-away rules for cafés and restaurants start?
From 12 February 2027, hotel, restaurant and catering businesses that sell take-away drinks or ready-prepared food must let customers bring their own container, at no higher cost than single-use packaging, and signpost it at the point of sale (Article 32). There is no micro-enterprise exemption from this duty. From 12 February 2028 they must also offer the option of reusable packaging within a re-use system (Article 33(1)), a duty micro-enterprises are exempt from (Article 33(4)). From 2030 they shall endeavour to offer 10% of products in a reusable format (Article 33(5)).
What is the deadline for recycled content in plastic packaging?
The first minimum recycled-content targets apply from 1 January 2030 or 3 years after the Commission's implementing act on the calculation method (Article 7(8), due by 31 December 2026) enters into force, whichever is later, and a higher set of targets applies from 1 January 2040 (Article 7). From 1 January 2029, or 24 months after that act enters into force if later, recycled content must be calculated and verified by its rules (Article 7(11)). 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 label applies from 12 August 2028 or 24 months after the Commission's Article 12(6) and 12(7) implementing acts enter into force, whichever is later (Article 12(1)). The reusable-packaging label follows from 12 February 2029 or 30 months after the Article 12(6) act, whichever is later (Article 12(2)). Those acts were due by 12 August 2026 and had not been adopted as at 29 September 2026, so both labels will apply later than those calendar dates. Labels likely to mislead consumers about sustainability have been banned since 12 August 2026 (Article 12(8)).
When is grade C packaging banned?
Packaging below grade C may not be placed on the market from 1 January 2030 or 24 months after the Commission's design-for-recycling delegated acts (Article 6(4), due by 1 January 2028) enter into force, whichever is later. From 1 January 2038 grade C is phased out too, and only grades A and B may be placed on the market (Article 6(3)).
Sources
- Regulation (EU) 2025/40 (PPWR), entry into force, application date and repeal of 94/62/EC; Art. 5, 6, 7, 9, 10, 11, 12, 13, 15, 24, 25, 26, 27, 28, 29, 30, 31, 32, 33, 34, 38, 40, 43, 44, 45, 49, 50, 52, 55, 56, 57, 61, 67, 68, 70, 71; Annexes IV, V, VI, VII and X, 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 (OJ C/2026/3084, 10 June 2026) 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).