What is PPWR and Who Does PPWR Apply To?

What is PPWR?

PPWR, Regulation (EU) 2025/40 on packaging and packaging waste, establishes harmonised rules for the design, manufacture, use, and management of packaging throughout the European Union.

The main objectives of PPWR are to:

reduce packaging waste generation,
promote the reuse of packaging,
increase packaging recyclability,
eliminate excessive and unnecessary packaging,
support the transition to a circular economy.

What is the Difference Between a Regulation and a Directive?

Regulation

A Regulation is an EU legal act that is directly applicable and binding in all Member States without the need for transposition into national legislation.

The requirements of PPWR will therefore apply uniformly across the European Union, ensuring that economic operators follow the same rules regardless of the Member State in which they operate.

Directive

A Directive establishes objectives that Member States must achieve but leaves them the flexibility to determine how those objectives are implemented through national legislation.

Each Member State may therefore adopt its own legal measures to transpose the requirements of a Directive into its national legal framework.

Why is PPWR Important?

PPWR represents the most significant change in packaging regulation in recent decades. It gradually introduces new requirements concerning:

packaging recyclability,
packaging minimisation,
recycled content in packaging,
reusable packaging,
packaging labelling,
provision of packaging compliance information.

Economic operators placing packaged products on the market should begin preparing for these requirements well in advance.

PPWR Is Not Just an Environmental Department Issue

The implementation of PPWR requirements will require collaboration across multiple departments within an organisation. As the Regulation affects the entire packaging life cycle, from design and sourcing to placing products on the market, responsibility cannot be assigned to a single individual or department.

Department	Key Areas of Responsibility
Product Management and Brand Management	Selection and approval of packaging solutions, product portfolio changes, private label decisions, and packaging design.
Packaging Development	Packaging design, material optimisation, recyclability, packaging minimisation, and reuse solutions.
Procurement	Supplier selection, collection of packaging technical data, and verification of packaging material compliance.
Marketing and Communication	Packaging labelling, environmental claims, and sustainability communication.
Legal and Compliance	Monitoring legal requirements, conformity assessment, development of internal policies, and contractual adjustments.
Sustainability and ESG	Coordination of PPWR implementation, reporting, environmental target setting, and communication with external stakeholders.
Quality Assurance	Verification of technical documentation, assessment of packaging compliance, and review of technical specifications.
Supply Chain and Logistics	Transport and grouped packaging, logistics optimisation, and implementation of reusable packaging systems.
IT and Data Management	Collection and management of packaging data, documentation management, reporting support, and compliance monitoring.
Top Management	Overall PPWR implementation governance, investment decisions, and strategic direction.

Key Recommendation: Economic operators should approach PPWR as a strategic business project affecting product design, packaging management, supply chains, marketing activities, and overall corporate strategy.

Where Does PPWR Apply?

PPWR applies to all packaging and packaged products placed on the EU market, regardless of the packaging material used, including paper, plastic, glass, metal, wood, and composite packaging. If your business places packaged products on the market, PPWR will most likely apply to your activities.

Group of Economic Operators	Description
Packers / Fillers / Brand Owners	Economic operators placing packaged products on the market, including businesses marketing products under their own brand. This also includes private-label products of retail chains.
Importers	Entities placing packaged products on the EU market for the first time.
Wholesale Distributors	Wholesalers and distributors of packaged products.
Retail and E-commerce Distributors	Physical stores, online shops, and marketplace platforms.
Logistics and Fulfilment Providers	Logistics centres, warehousing operators, and fulfilment service providers using transport and grouped packaging.
Packaging Manufacturers and Importers	Manufacturers of packaging materials and components, manufacturers of empty packaging, and packaging importers.
HORECA Sector	Hotels, restaurants, cafes, fast-food operators, and catering businesses using packaging in the provision of services to customers.