PPWR

“PPWR” is the abbreviation for “Packaging & Packaging Waste Regulation.” As a binding “regulation,” it replaces the previously valid “directive” for packaging and packaging waste within the EU. The regulation came into force on February 11, 2025.

By 2030, crucial details for implementation will be defined within the framework of so-called “delegated acts.”


With regard to flexible packaging, the requirements for recyclability and the use of recycled materials are particularly important. The following summary is based on information provided by the German Plastics Packaging Industry Association.


Last update: September 10, 2025

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Additional information

  • By the end of 2025 EN 18120 Design for Recycling guidelines for plastic packaging are to be published by CEN
  • By January 1, 2028 The assessment criteria will be defined by delegated acts
  • By January 1, 2030 Additional implementing act on the method for “recycled at scale”
  • From 2030: Packaging is considered non-recyclable if it meets < 70% of the D4R criteria. (Performance level C)
  • From 2035: Packaging is considered non-recyclable if it is not ≥ 55% recycled across the EU (“recycled at scale”)
  • From 2038: Packaging that meets < 80% of the DfR criteria (performance level B) is considered non-recyclable

  • Calculation must be carried out by the “manufacturer” (usually the bottler)
  • Averaging across packaging manufacturers is conceivable, but not yet regulated
  • The obligation applies to any plastic content ≥ 5% of the packaging weight (Art. 7 (1) in conjunction with 5b)
  • Applies to each type and format of packaging (Annex II Table 1) calculated as the average per manufacturing plant and year
  • Averaging is permitted per “plant,” not per “company” (group)
  • Exceptions are possible if recycled material poses a health hazard or violates Regulation (EC) 1935/2004
  • Further exceptions by the Commission via delegated act possible (Art. 7 (12) and (13))
  • Recyclate quota cannot be met with post-industrial recyclates (PIR)
  • Only post-consumer recyclates are permitted (Art. 3 (1) No. 48)
  • Closures do not have to contain recycled material separately if this is compensated for in other components
  • Stock levels do not count towards the quantity placed on the market
  • The use of bio-based plastics is currently not planned, but will be reviewed (Art. 8(2c))

  • Chemical recycling is recognized as a recycling method
  • Presumably favored mass balance method:“fuel-use exempt”
  • This means that only the portion that can be turned back into packaging is counted toward the recyclate output, but not the portion that is necessary for process energy
  • Goal: Attribution of high recyclate content possible

  • From August 12, 2026, a conformity assessment by the manufacturer (Manufacturer) is required (Art. 15).
  • The manufacturer must issue technical documentation (Annex VII) and a declaration of conformity before placing the product on the market
  • The declaration must be kept for 5 years and presented on request
  • Packaging manufacturers are usually considered suppliers and provide the necessary documentation (Art. 16)
  • In case of violations: First request for correction, then measures by national authorities (Art. 62)

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Information & solutions for your flexible packaging


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