What is the PPWR?
A plain-language primer on Regulation (EU) 2025/40
Regulation (EU) 2025/40 on Packaging and Packaging Waste (PPWR) entered into force on February 11, 2025. It is directly applicable EU law, no national transposition law is needed. Every business that places packaged goods on the EU market, including importers and online marketplaces, must comply from August 12, 2026. The regulation covers all packaging: primary (consumer-facing), secondary (transit), and tertiary (industrial/transport).
๐ฏ Core Goals
- Reduce packaging weight and complexity (minimization rules)
- Make all packaging recyclable or reusable by 2030
- Mandate post-consumer recycled (PCR) content targets by 2030
- Harmonize EPR fees across all 27 member states via eco-modulation
- Mandate DRS for beverage containers by 2029
- Eliminate PFAS from food-contact packaging (from Aug 12, 2026)
๐ Who Must Comply
- Brand owners / manufacturers, primary obligation holders
- Importers, treated as producers if no EU manufacturer
- Online marketplaces, backstop registrant for non-EU sellers
- Packaging suppliers / converters, technical information duties
- Distributors, labeling compliance and pass-through obligations
๐ 5 Actions to Take Now
- Audit packaging against PFAS thresholds (25 ppb individual / 250 ppb sum)
- Prepare a Declaration of Conformity (DoC) for each packaging format
- Register with EPR systems in each EU market where you sell
- Identify which packaging formats risk a below Grade C (non-recyclable) classification
- Phase out standalone Green Dot symbols before the harmonised label applies (August 12, 2028, Art. 12(8))
โก What's Still Uncertain
- Recyclability Grade A/B/C thresholds (ACT-02 not yet adopted)
- PCR content verification methodology (ACT-03 pending)
- Harmonized EPR registration format, statutory deadline missed Feb 12, 2026
- Italy compostable packaging exemption (EC response expected ~Jul 2026)
- Authorized Representative suspension under Environmental Omnibus (not yet formally adopted)
Key Compliance Timeline
| Date | Obligation | Articles | Status |
|---|---|---|---|
| Aug 12, 2026 | PPWR directly applicable. Declaration of Conformity (DoC) required. PFAS ban (25 ppb / 250 ppb) in food-contact packaging. EPR registration and fee obligations apply (grade-based eco-modulation under Art. 6(4)/45(1) is mandatory later, about 18 months after the design-for-recycling act, roughly mid-2029). | 5โ12, 41, 45 | Immediate |
| Feb 12, 2027 | Deadline for the Commission to adopt several PPWR implementing and delegated acts (staggered act timeline). No new producer labelling obligation falls on this date. | Various | Act deadlines |
| Jan 1, 2028 | First PCR content reporting period. Reusable packaging first reporting requirements. | 7, 29 | Upcoming |
| Aug 12, 2028 | Harmonized EU sorting label mandatory on consumer packaging. Standalone Green Dot and other marks that could confuse consumers restricted once the harmonised label applies (Art. 12(8)). Contact-sensitive SUP plastic ban. Digital Product Passport requirements (ACT-09 pending). | 12, 13, 22 | Upcoming |
| Jan 1, 2029 | Deposit Return Systems mandatory in all 27 member states for single-use plastic and metal beverage containers 0.1Lโ3L (Art. 50). | 50 | Upcoming |
| Jan 1, 2030 | PCR content targets mandatory (plastic packaging). Packaging below Grade C (non-recyclable) cannot be placed on the EU market. Reuse Phase 1 targets apply. | 7, 6, 29 | 2030 |
| Jan 1, 2035 | Authorized Representative suspension under the Environmental Omnibus (if adopted) expires. | 45 | 2035 |
| Jan 1, 2038 | Only packaging recyclable within grades A or B (Annex II, Table 3) may be placed on the EU market. Grade C no longer sufficient. | 6 | 2038 |
| Jan 1, 2040 | Second-tier minimum recycled-content targets for plastic packaging (50% PET contact-sensitive, 25% other, 65% single-use bottles, 65% other plastic). Reuse Phase 2 targets (endeavour: 70% transport, 40% beverages). | 7, 29 | 2040 |
Key Definitions at a Glance
| Term | Plain-Language Meaning |
|---|---|
| Producer | Any business that places packaged goods on the EU market. Broader than most expect, includes importers and online marketplaces. |
| Declaration of Conformity (DoC) | Formal written attestation (per Arts. 5โ12) that a packaging format meets PPWR requirements. Required from Aug 12, 2026. No US equivalent. |
| Eco-modulation | EPR fees adjusted up or down based on recyclability, PCR content, and design attributes. Mandatory under Art. 6(4)/45(1). |
| Recyclability Grade A/B/C | Grade A = 95 percent or more recyclable by weight; Grade B = 80 percent or more; Grade C = 70 percent or more. Below 70 percent is non-recyclable and cannot be placed on the EU market from Jan 1, 2030. Exact criteria pending the design-for-recycling act (ACT-02). |
| PCR Content | Post-consumer recycled material. PPWR sets mandatory minimums from 2030 by polymer type. Methodology pending ACT-03. |
| PFAS | Per- and polyfluoroalkyl substances. Banned from food-contact packaging from Aug 12, 2026 at >25 ppb individual / >250 ppb total. |
Country Navigator
Click any country on the map to see EPR system details, fee thresholds, eco-modulation notes, and DRS status. All 27 member states are subject to PPWR direct application from August 12, 2026.
DRS Active
DRS In Development
DRS Deferred / Limited
DRS Not Yet Operational
Select a Country
Select any country to see EPR program details, thresholds, and DRS status.
All 27 Member States, EPR & DRS Summary
PPWR Art. 50 DRS mandate: All 27 EU member states must operate a deposit return system for single-use plastic and metal beverage containers from 0.1L to 3L by January 1, 2029. Member states already achieving a 90 percent or higher separate collection rate for a container type may apply for exemption. The mandate does NOT cover glass bottles unless a member state chooses to include them. Click any country on the map for its DRS status, launch date, deposit amount, scope, and operator.
Fee data note: Base EPR fee rates are indicative figures from 2025/early 2026 schedules. Eco-modulation adjustments can shift final liability significantly. Verify current tariffs directly with each national PRO.
| Country | PRO / Registry | SME Threshold | DRS Status | Key Note |
|---|---|---|---|---|
| ๐ฉ๐ช Germany | LUCID / Multiple PROs | โค80,000 units AND โค200 kg | DRS Active, โฌ0.25 | Competitive multi-PRO market. Declaration of Completeness required above tonnage threshold. |
| ๐ซ๐ท France | CITEO / Lรฉko | ~โค200 units or โค5 kg (~โฌ80/yr flat) | DRS Developing | Triman label still required. ICP B2B rate from Jan 1, 2026. CITEO bonus/malus up to ยฑ100%. |
| ๐ฎ๐น Italy | CONAI (7 consortia) | Varies by consortium | DRS Developing | Alphanumeric codes required. TRIS notification 2026/0167/IT pending EC response ~Jul 2026. |
| ๐ช๐ธ Spain | Ecoembes / Envalora | <15 tonnes/year | DRS Deferred 2029 | SDDR deferred to Jan 1, 2029. No PPWR national implementing measures enacted. |
| ๐ณ๐ฑ Netherlands | Verpact | <50 tonnes/year | DRS Active, โฌ0.15/โฌ0.25 | Most generous SME threshold. Statiegeld fully operational. DRS-eligible formats require deposit marking. |
| ๐ต๐ฑ Poland | NFOลiGW / BDO | PLN 150/quarter waiver | DRS Not Yet | All private PROs liquidated. AR required for non-EU e-commerce sellers. BDO portal in Polish. |
| ๐ฆ๐น Austria | ARA | Kleinstzeichner ~โฌ150/yr flat rate | DRS Limited / Voluntary | Strictest AR requirement in EU, zero de minimis. Omnibus AR suspension NOT yet formally adopted. |
| ๐ง๐ช Belgium | Fost Plus / Bruxelles-Propretรฉ | Varies by region | DRS Developing | Three separate regional EPR schemes (Flanders, Wallonia, Brussels). |
| ๐ธ๐ช Sweden | FTI (Fรถrpacknings- och Tidningsinsamlingen) | ~2 tonnes/year | DRS Active, SEK 1โ2 | Mature EPR system since 1994. Pantamera DRS operational. |
| ๐ฉ๐ฐ Denmark | Dansk Retursystem | ~1 tonne/year | DRS Active, DKK 1โ3 | One of oldest DRS systems globally (1989). High return rates. |
| ๐ซ๐ฎ Finland | Rinki / Palpa | ~1 tonne/year | DRS Active, โฌ0.10โโฌ0.40 | World-leading return rates (>93%). DRS since 1996. |
| ๐จ๐ฟ Czech Republic | EKO-KOM | 300 kg or 600 units | DRS Developing | DRS legislation under development. EKO-KOM well-established. |
| ๐ญ๐บ Hungary | OHร | ~200 kg | DRS Active, HUF 50 | Centralized state system. DRS launched 2024 via MOHU. |
| ๐ท๐ด Romania | ANPM / RetuRO | To confirm | DRS Active, RON 0.50 | DRS launched Nov 2023 via RetuRO. |
| ๐ง๐ฌ Bulgaria | ECOBULPACK | To confirm | DRS Not Yet | EPR system transitioning. PPWR application may outpace national readiness. |
| ๐ฌ๐ท Greece | EOAN | To confirm | DRS Not Yet | EPR system in place. Limited DRS development. PPWR mandate by 2029. |
| ๐ต๐น Portugal | SPV (Sociedade Ponto Verde) | ~1 tonne/year | DRS Not Yet | DRS in planning. SPV EPR system well-established. |
| ๐ฎ๐ช Ireland | Repak / Re-Turn | ~1 tonne or โฌ1M turnover | DRS Active, โฌ0.15/โฌ0.25 | Re-Turn DRS launched 2024. Repak established EPR operator. |
| ๐ธ๐ฐ Slovakia | NATUR-PACK / ENVI-PAK | To confirm | DRS Active, โฌ0.15 | DRS operational since 2022. |
| ๐ญ๐ท Croatia | FZOEU | To confirm | DRS Active | DRS operational since 2006 via FZOEU. |
| ๐ธ๐ฎ Slovenia | SLOPAK | To confirm | DRS Developing | DRS in development. SLOPAK EPR system established. |
| ๐ช๐ช Estonia | Eesti Pandipakend | To confirm | DRS Active, โฌ0.10 | DRS operational since 2005. |
| ๐ฑ๐ป Latvia | Latvijas Zaฤผais Punkts | To confirm | DRS Active, โฌ0.10 | DRS operational since 2011. |
| ๐ฑ๐น Lithuania | Green Dot Lithuania | To confirm | DRS Active, โฌ0.10 | DRS operational since 2016. |
| ๐ฑ๐บ Luxembourg | Valorlux | ~300 kg | DRS Not Yet | Small market. Valorlux EPR established. PPWR DRS mandate by 2029. |
| ๐จ๐พ Cyprus | GreenDotCyprus | To confirm | DRS Not Yet | EPR system present. PPWR DRS mandate by 2029. |
| ๐ฒ๐น Malta | GreenPak / WasteServ | To confirm | DRS Not Yet | Very small market. GreenPak EPR operational. PPWR DRS mandate by 2029. |
Roles & Obligations
Pick your role and packaging types to see which PPWR obligations apply to you, and when. Every date is taken from the EUR-Lex text of Regulation (EU) 2025/40 (fact base locked July 2, 2026); evidence labels show how settled each item is.
Your role
Packaging types (pick all that apply)
Role-wide duties (like EPR registration) always show; type-specific rows appear only for the types you pick.
โ ๏ธ Planning aid only, not legal advice. Dates marked LOCKED were read in the EUR-Lex text of Regulation (EU) 2025/40; SIGNALED items rest on official sources not yet final or not yet re-read; SPECULATIVE items are proposals. Several 2030+ dates shift if their delegated or implementing acts are adopted late (the row notes say so). Verify against primary sources before compliance decisions.
Role Snapshots
PPWR's definition of "producer" is broader than most practitioners expect. Any business that places packaged goods on the EU market is a producer, including importers and online marketplaces. Role determines which obligations apply and who bears EPR liability. The cards below summarize each role, including two (packaging supplier/converter and packaging engineer/R&D) whose duties are data and design deliverables rather than dated obligations.
Brand Owner / Product Manufacturer
- Primary obligation holder under PPWR
- Must prepare a Declaration of Conformity (DoC) per packaging format from Aug 12, 2026
- Register with EPR system in each EU country of sale; pay eco-modulated fees
- Ensure packaging meets recyclability design criteria (ACT-02 pending)
- Meet PCR content minimum targets from Jan 1, 2030
- Eliminate PFAS from food-contact packaging by Aug 12, 2026
- Phase out standalone Green Dot when the harmonised label applies (Aug 12, 2028, Art. 12(8)); add harmonized pictograms by Aug 12, 2028
Focus: DoC, EPR registration, packaging redesign, labeling timeline
Packaging Supplier / Converter
- Technical information duties: provide brand owner clients with material composition data, PCR % with chain-of-custody evidence, PFAS and SoC test results
- Must support DoC preparation with substrate-level technical data
- Recyclability grade evidence and DfR compliance documentation is a new commercial deliverable
- Expect significant increase in customer data requests from 2026
- Suppliers of compliant formats (mono-material, high-PCR, barrier-free) have commercial opportunity to displace non-compliant alternatives
Focus: Technical data packages, DfR compliance, customer support playbook
Importer / Distributor
- Treated as producer if the manufacturer is not established in the EU
- Must verify that packaging meets PPWR requirements before placing on EU market
- EPR registration obligation, cannot shift liability back to non-EU manufacturer
- Must maintain DoC and technical documentation
- If distributing under own brand: full producer obligations apply
Focus: Producer definition test, EPR liability allocation, DoC chain of custody
E-Commerce / Online Marketplace
- Marketplace is backstop EPR registrant if third-party seller is non-EU and unregistered
- 50% maximum empty-space ratio for e-commerce, grouped, and transport packaging from 2030 (Art. 24); minimisation duty starts Aug 2026
- EPR fees apply per-country-of-delivery, registrations required in each delivery market
- Non-EU direct-to-consumer sellers must appoint Authorized Representatives in some markets
- Reuse targets for transport packaging apply from 2030
Focus: Void space rule, per-country EPR, AR requirements, marketplace backstop liability
Packaging Engineer / R&D
- Design for Recycling (DfR) criteria will be defined by ACT-02, track its adoption closely
- Recyclability Grade A/B/C classification will determine EPR fee modulation (mandatory about mid-2029) and market-access eligibility from 2030
- Priority redesign targets: dark/opaque pigmented plastics, multi-layer laminates, PFAS-coated paperboard, PVC, EPS/XPS foams
- PCR content: distinguish post-consumer (eligible) from post-industrial (not eligible for PPWR targets)
- Mass balance accounting for chemical recycling credits contested, conservative approach recommended
Focus: DfR criteria (ACT-02), recyclability grades, PCR specification, material substitution
Global Manufacturer (Non-EU HQ)
- EU imports: importer bears producer obligations unless EU Authorized Representative appointed
- No US equivalent to the Declaration of Conformity, budget time to build DoC process
- Authorized Representative (AR) required in some markets (Austria: mandatory regardless of volume)
- Environmental Omnibus proposal would suspend AR until Jan 1, 2035, not yet adopted as of mid-2026
- PFAS ban stricter than US regulations, food-contact packaging reformulation may be needed
Focus: AR requirement, DoC (no US equivalent), PFAS reformulation, PCR sourcing for EU-specific SKUs
Glossary
Precise definitions for PPWR terminology. Legal definitions often differ from common usage.
ProducerArt. 3(27) PPWR
Any natural or legal person that makes packaging or packaged products available on the EU market for the first time on a professional basis. Includes manufacturers, importers, and online marketplaces acting as backstop registrants for non-EU sellers.
Common misuse: "producer" is often assumed to mean manufacturer only. PPWR's definition is explicitly broader and captures importers and marketplaces.
Packaging Types (Primary / Secondary / Tertiary / Service)Art. 3(1) PPWR
Primary: packaging constituting a sales unit to the final consumer. Secondary: grouping packaging for a number of sales units. Tertiary: transport/industrial packaging. Service packaging: provided to consumer at point of sale (e.g., carrier bags, takeaway cups).
Recyclability Grade A/B/CArt. 6 + ACT-02 (pending)
A classification of packaging recyclability by weight. Grade A = 95 percent or more (enabling the largest EPR fee discounts), Grade B = 80 percent or more, Grade C = 70 percent or more. Below 70 percent is non-recyclable and cannot be placed on the EU market from January 1, 2030.
Exact criteria are pending ACT-02 (Delegated Act on Design for Recycling). No final technical thresholds published as of mid-2026.
Post-Consumer Recycled (PCR) ContentArt. 7 PPWR
Material recovered from waste generated by households or commercial/institutional facilities after use by end consumers. PPWR sets mandatory minimum PCR content targets by polymer type from January 1, 2030.
Distinct from post-industrial / pre-consumer recycled content. Only PCR content counts toward PPWR targets. Methodology for verification: pending ACT-03.
Mass Balance AccountingArt. 7 + ACT-03 (pending)
A chain-of-custody methodology that allows recycled feedstock inputs to be allocated to specific outputs without requiring physical separation throughout production. Relevant to chemical recycling credits for PCR content claims.
Heavily contested. NGOs argue mass balance overstates actual recycled content. Industry argues it is essential for chemical recycling viability. ACT-03 will define the permissible methodology.
Declaration of Conformity (DoC)Arts. 5โ12 PPWR
A formal written document attesting that a packaging format meets applicable PPWR requirements. Required for all packaging placed on the EU market from August 12, 2026. Must cover minimization, recyclability, PCR content, PFAS/SoC compliance, and reuse classification.
No direct US equivalent. Some DoC fields (recyclability grade) require data not yet finalizable pending ACT-02.
Authorized Representative (AR)Art. 3(29) + national requirements
A natural or legal person established in the EU, mandated by a non-EU producer to fulfill EPR registration and compliance obligations on the producer's behalf in a specific member state.
Austria requires an AR for all non-resident producers regardless of volume. The Environmental Omnibus proposal would suspend the AR requirement until Jan 1, 2035, not yet formally adopted as of mid-2026.
Eco-ModulationArt. 6(4)/45(1) PPWR
Mandatory adjustment of EPR fees based on the environmental performance of packaging. Member states must ensure PROs apply higher fees to less recyclable, lower-recycled-content packaging and lower fees to more sustainable formats.
France's CITEO bonus/malus is the most developed example: up to โ50% bonus for best-practice design, up to +100% malus for worst-performing formats.
EPR / PROArt. 44โ49 PPWR
Extended Producer Responsibility: policy requiring producers to bear financial responsibility for end-of-life management of their packaging. A PRO (Producer Responsibility Organisation) is the collective scheme through which producers fulfill EPR obligations (e.g., CITEO, CONAI, Verpact, ARA).
Deposit Return System (DRS)Art. 50 PPWR
A system where consumers pay a deposit on beverage containers at point of sale, refunded when the container is returned to a collection point. PPWR mandates DRS in all 27 member states by January 1, 2029 for single-use plastic and metal beverage containers between 0.1L and 3L.
Digital Product Passport (DPP)Art. 13 + ACT-09 (pending)
A data carrier (e.g., QR code) on packaging linking to a digital record of the packaging's material composition, recyclability grade, PCR content, and compliance documentation. Required from August 12, 2028. Technical format pending ACT-09.
Substances of Concern (SoC)Art. 3(12) + Annex I PPWR
Hazardous substances present in packaging that may impair human health or hinder recycling. Includes PFAS, certain heavy metals, phthalates, and others listed in Annex I. PFAS in food-contact packaging banned from Aug 12, 2026 (>25 ppb individual / >250 ppb total).
Design for Recycling (DfR)Art. 6 + ACT-02 (pending)
Technical design criteria that packaging must meet to qualify for specific recyclability grades. Covers material composition, colorants, labels, adhesives, closures, barrier coatings, and separability. Exact criteria pending ACT-02 adoption.
PFAS (Per- and Polyfluoroalkyl Substances)Annex I PPWR
A class of approximately 4,700 synthetic fluorinated compounds. PPWR bans PFAS in food-contact packaging from August 12, 2026 at concentrations exceeding 25 ppb for individual PFAS or 250 ppb for total PFAS sum. Common in grease-resistant coatings on paper cups, fast-food wrappers, and microwave packaging.
PFAS testing and reformulation lead times are typically 12โ18 months. Brands that have not started this process are now operating very close to the deadline.
Green Dot (Der Grรผne Punkt)Art. 12(8) PPWR
The interlocking green arrows symbol historically used to indicate EPR fee payment to a national scheme. PPWR Article 12(8) restricts marks, symbols or inscriptions (including a standalone Green Dot) that could mislead or confuse consumers about packaging waste management, applying once the harmonised label takes effect from August 12, 2028. It may not be used as a recycling instruction symbol.
Harmonized Sorting PictogramArt. 13 + ACT-04 (pending)
A standardized EU-wide graphical symbol indicating how a packaging component should be sorted. Replaces national sorting labels (e.g., France's Triman, Italy's alphanumeric codes). Required on consumer packaging from August 12, 2028. Visual format pending ACT-04.
Compostable PackagingArt. 3(34) + Art. 9 + ACT-05 (pending)
Packaging that can be organically recovered through composting. PPWR distinguishes industrial compostable from home compostable. Permitted only for specific applications (e.g., tea bags, coffee capsules, some fresh food wrapping). Technical criteria pending ACT-05.
Italy filed TRIS notification 2026/0167/IT seeking exemption for compostable single-use food-service packaging. EC response pending ~July 2026.
Void Space / Minimization RuleArt. 24 PPWR
PPWR requires that packaging volume be minimized relative to product volume. For e-commerce, grouped, and transport packaging, the empty (void) space ratio may not exceed 50% from January 1, 2030 (Art. 24); the calculation methodology comes in an implementing act due February 12, 2028, and the general minimisation duty starts August 2026. Retail packaging must use the minimum material weight and volume necessary for protective function and labeling.
Life Cycle Assessment (LCA)Not directly applicable under PPWR
A methodology for quantifying environmental impacts across a product's full life cycle. PPWR does not currently permit LCA-based arguments to override its specific format bans or reuse exemptions.
Common misconception: brands sometimes assume an LCA showing single-use outperforms reusable will earn an exemption. PPWR is prescriptive, LCA is not currently a permitted compliance pathway.
Delegated Acts Tracker
Live status tracker for PPWR secondary legislation, where the technical details are actually defined. Each act shows its status, due date, evidence label, last-verified date, and what it does to your fees or formats.
๐ Tracker last verified: July 2, 2026 (statuses checked against EUR-Lex and the June 30 monitoring scan; re-verified on the biweekly update cycle)
Why this matters: PPWR's broad requirements are in force from Aug 12, 2026, but many specific technical thresholds (recyclability grades, PCR methodology, DfR criteria) are defined in delegated and implementing acts, most of which are still pending. No act below is marked Adopted; none has a EUR-Lex OJ publication as of the last verification. Compliance planning should account for the risk that these acts may be published on short notice.
ACT-01
Reuse Targets, Calculation Methodology (Art. 30(3))
The reuse targets themselves are self-executing in Article 29 (transport and e-commerce packaging 40% from 2030; beverages 10% from 2030; endeavour targets 70% and 40% from 2040). What is pending is the Article 30(3) implementing act defining how the targets are calculated and measured.
Consequence: Determines how the Art. 29 percentages are counted (qualifying systems, trip counting, exemptions), which drives reuse-system planning for beverage and e-commerce brands ahead of the 2030 deadline. No direct fee effect.
Pending
ACT-02
Design for Recycling (DfR) Criteria + Recyclability Grade A/B/C Methodology (Art. 6(4))
Defines the technical criteria for each recyclability grade (A, B, C) across all packaging material categories. Determines which formats fall below Grade C (and cannot be placed on the market from 2030) and which earn Grade A fee discounts. JRC methodology work in development; not yet published for public consultation.
โ ๏ธ Blocks: EPR fee grade calculation, DoC recyclability field, packaging design investment decisions, non-recyclable (below Grade C) market-access planning
Consequence: The single most fee-relevant pending act. It delivers the Art. 6(4)(d) eco-modulation framework keyed to the Art. 45(1) EPR obligation: harmonized grade-based fee modulation becomes mandatory in all 27 member states about 18 months after it enters into force (roughly mid-2029), and grade assignments decide 2030 market access for every format in the Format Risk Screener.
In Preparation
ACT-03
PCR Content Calculation Methodology (Art. 7)
Defines how post-consumer recycled content must be calculated, verified, and certified. Determines whether mass balance accounting is permissible for chemical recycling inputs. Contested by NGOs and chemical recycling industry.
โ ๏ธ Blocks: PCR target compliance claims, chemical recycling credit eligibility, PCR supply contract structuring
Consequence: Decides which recycled inputs count toward the Art. 7(1) 2030 minimums (30/10/30/35 by category), so it directly sets the compliance cost of PCR sourcing, whether chemical-recycling credits are usable, and eligibility for national PCR fee bonuses (Verpact 200 EUR/t discount, CITEO PCR prime, Ecoembes 20%+ PCR bonus).
Not Published
ACT-04
Harmonized Labelling Implementing Act, Sorting Pictograms (Art. 12(6)/(7))
Defines the visual format, sizing, placement, and color specifications for EU-wide harmonized sorting pictograms replacing national labeling schemes from August 12, 2028.
โ ๏ธ Blocks: Artwork planning for the 2028 label transition; national labels (Triman, IT alphanumeric) remain in force until adopted
Consequence: Starts the 24-month clock to the harmonised label (applies Aug 12, 2028, or 24 months after this act if later), which also triggers the Art. 12(8) restriction on standalone marks such as the Green Dot. Late adoption pushes the whole labelling timeline. Artwork and inventory cost effect, no fee-rate effect.
Pending
ACT-05
Compostable Packaging Technical Criteria (Art. 9)
Defines the specific application categories where compostable packaging is permitted, and technical standards for industrial vs. home compostable certification. Related to Italy TRIS notification 2026/0167/IT (EC standstill response expected ~July 2026).
โ ๏ธ Blocks: Compostable packaging investment decisions; Italy TRIS outcome interacts with this act
Consequence: Decides which formats (coffee capsules, tea bags, fruit stickers, light carrier bags) may or must be compostable, which determines whether bioplastic SKUs stay marketable and how they are priced under schemes like Italy's Biorepack (246 EUR/t from July 2026).
Consultation
ACT-06
Reusable Packaging Technical Design Criteria (Art. 11)
Defines technical requirements that packaging must meet to qualify as "reusable." Covers minimum trip counts, durability, hygiene standards, and collection system requirements.
Consequence: Sets the bar for what counts as reusable, which gates both the Art. 29 reuse targets and the large national reuse fee incentives (for example CITEO's reuse bonus, up to a full contribution discount for proven reuse systems).
Not Published
ACT-07
Deposit Return System Technical Requirements (Art. 50)
Defines minimum technical standards for DRS infrastructure, interoperability between national systems, and cross-border recognition of deposit markings.
Consequence: Shapes deposit-marking and interoperability requirements for beverage formats ahead of the January 1, 2029 all-27 DRS mandate; affects label artwork and cross-border SKU planning in the 9 member states without an operating DRS. No EPR fee effect.
Not Yet Started
ACT-08
Harmonized EPR Registration Format (Art. 44(14))
Required to establish a standardized registration format enabling producers to register across all 27 member states using a single data structure. Intended to reduce administrative burden of multi-country EPR compliance.
โ ๏ธ Statutory deadline of February 12, 2026 was MISSED. Not published as of late June 2026. Producers must continue registering individually in each member state using national PRO formats.
Consequence: Until adopted, every producer registers separately in each member state on national PRO formats, the biggest recurring admin cost for multi-country and non-EU sellers (27 registrations, 27 data structures). No fee-rate effect, pure compliance burden.
Overdue
ACT-09
Digital Product Passport Format & Minimum Data Fields (Art. 13)
Defines the technical specification for the Digital Product Passport (DPP) data carrier, minimum data requirements, and interoperability standards. Required on packaging from August 12, 2028.
Consequence: Determines the QR/data-carrier spec that must sit alongside (or carry) the 2028 harmonised label, including where a fee-paid symbol like the Green Dot may still appear (inside the QR only). Artwork and data-systems cost, no fee-rate effect.
Not Yet Started
Format Risk Screener
Quick recyclability and compliance risk lookup by packaging format.
Design for Recycling: Grade Ladder (preview)
PPWR Annex II grades packaging recyclability by weight (Grades A, B, C only; below 70 percent is non-recyclable). The per-category technical criteria are pending the design-for-recycling delegated act (ACT-02, due Jan 1, 2028), so the assignments below are provisional, for orientation only.
Market-access ladder: from Jan 1, 2030 packaging must reach at least Grade C to be placed on the EU market; from Jan 1, 2035 the recyclable-at-scale test applies; from Jan 1, 2038 only Grade A or B is permitted.
Grade A: 95%+
Largest EPR fee discounts. Clear PET bottles, natural HDPE, aluminium cans, glass, uncoated kraft board.
Grade B: 80%+
Moderate discount. PP tubs, mono-material PE flexibles where collection exists.
Grade C: 70%+
Minimum to stay on the market from 2030. Beverage cartons, some flexibles, coated fibre.
Below Grade C
Non-recyclable. Off the market from 2030. Multilayer laminates, PVC, carbon-black plastic, EPS.
Risk ratings reflect current best assessment based on PPWR text and JRC draft guidance. ACT-02 (DfR criteria) has not been finalized, so exact Grade A/B/C assignments are pending. PPWR Annex II defines only Grades A, B, and C; packaging below 70 percent recyclability is non-recyclable. Use for planning; verify against ACT-02 once adopted.
Clear PET Bottle (beverage)
Mono-material clear or light-blue PET, separable closure. Standard beverage bottle format.
EPR: Lower rate under eco-modulation. DRS: In scope in DE, NL, FI, SE, DK, EE, LV, LT, HR, RO, SK, HU, IE and others.
Grade A Likely
HDPE Rigid Container (natural/white)
Milk bottles, detergent bottles, shampoo containers in natural HDPE. Mono-material, sortable.
EPR: Lower eco-modulation rate. Favored format for DfR compliance.
Grade A/B Likely
Aluminum Beverage Can
Standard aluminum can. Highly recyclable, established collection infrastructure across EU.
EPR: Lower rate. DRS: In scope across most active DRS markets. PCR content achievable via closed-loop recycling.
Grade A Likely
Glass Bottle / Jar
Standard soda-lime glass packaging. Well-established recycling stream across EU.
EPR: Lowest fee rates in most markets. DRS scope varies, excluded from some DRS systems.
Grade A Likely
PP Rigid Container / Tub
Yogurt pots, margarine tubs, food containers in polypropylene.
EPR: Moderate eco-modulation rate. Clear/natural PP preferred. Label/sleeve compatibility important for grade.
Grade B Likely
Mono-Material PE Flexible Pouch / Film
Stand-up or lay-flat pouch in a single polyethylene family, no barrier layers or foil laminate.
EPR: Medium rate. Grade B in markets with flexible PE infrastructure; Grade C where collection is limited. Market-dependent.
Grade B/C, Market Dependent
Opaque / Dark-Pigmented PET Bottle or Container
PET packaging colored with dark or opaque pigments, including most black-pigmented containers.
FR: CITEO malus up to +100%. DE: Malus under Section 21 VerpackG. IT: High Corepla band. Carbon black prevents NIR sorting, high risk across EU.
Grade C / Non-Recyclable Risk
Multi-Layer Flexible Laminate / Foil Pouch
Stand-up or flat pouches combining PE/PP/PET layers with aluminum foil or EVOH barrier. Non-separable composite.
Highest risk format. Non-separable composite is effectively unrecyclable. ACT-02 expected to classify it as non-recyclable (below Grade C). Malus in FR, high band in IT. 2030 market-access risk is high.
Non-Recyclable Risk, 2030 Market Ban
Expanded Polystyrene (EPS), Food Contact
EPS foam trays, cups, boxes for food service or perishable packaging.
SUP Directive restrictions apply to some food-service EPS formats. Non-recyclable (below Grade C) risk under ACT-02. Limited collection infrastructure. High malus in eco-modulation systems.
Non-Recyclable Risk
PVC Packaging (clamshell, blister)
Rigid PVC clamshells and blister packs for retail consumer electronics, hardware, food.
PVC is incompatible with most plastic recycling streams. Below Grade C in draft JRC guidance. Design substitution to PET clamshell strongly recommended.
Below Grade C, Substitution Needed
PFAS-Coated Paper / Board (cups, wrappers, trays)
Paper cups, fast-food wrappers, bakery trays, microwave packaging with fluorinated grease-resistant coatings.
โ BANNED from Aug 12, 2026 if PFAS content exceeds 25 ppb individual / 250 ppb total. Test all grease-resistant paper and board formats immediately. Reformulation lead time: 12โ18 months.
BANNED Aug 2026
Composite Beverage Carton (aseptic / chilled)
Carton formats combining paperboard, PE layers, and aluminum foil (e.g., Tetra Pak, Elopak).
Recyclable in dedicated carton streams only. Grade C anticipated, composite structure impairs recyclability. Some markets lack dedicated carton collection.
Grade C Anticipated
Recycled Paperboard / Kraft Board Carton
Secondary and tertiary packaging in recycled paperboard. Widely collected. High PCR content often already present.
EPR: Lowest rates across all markets. Grade A likely. Barrier coatings (PE, wax) may reduce grade, specify barrier-free where possible.
Grade A Likely
Compostable PLA / Bio-Based Plastic
Packaging from polylactic acid or other bio-based compostable materials. Often used for cups, trays, cutlery.
Bio-based origin does not determine PPWR recyclability grade. PLA not recyclable in standard plastic streams. Permitted only for specific applications (ACT-05 pending). Italy TRIS notification may affect scope.
Pending ACT-05
Carbon-Black Pigmented Plastic
Any plastic packaging colored with carbon black pigment (black trays, containers, lids).
Carbon black absorbs NIR light, invisible to NIR sorting equipment. CITEO malus applies. ACT-02 expected to classify it as non-recyclable (below Grade C). Substitute with carbon-black-free alternatives.
Non-Recyclable Risk
Full-Body Shrink Sleeve on PET/HDPE
PVC or PET shrink sleeve applied to a PET bottle for decoration/branding.
PVC sleeves on PET bottles: contamination risk, downcycles bottle. PET sleeves: better compatibility. Specify PET sleeve with perforation for easy removal.
Grade C Risk (PVC sleeve)
Labelling Requirements
Consolidated view of PPWR packaging labelling: harmonized pictograms, deposit and reuse marks, the Green Dot transition, and surviving national marks. Evidence labels show how settled each item is.
Article 12 harmonized labelling. PPWR replaces the national label patchwork with a single EU label using pictograms for material composition and consumer sorting. The Commission implementing act that specifies the pictograms is due by August 12, 2026 [SIGNALED, not yet adopted as of June 2026]. The harmonized label then applies from August 12, 2028, or 24 months after the act enters into force, whichever is later [LOCKED date].
Key Labelling Dates
| Date | Requirement | Evidence |
|---|---|---|
| Aug 12, 2026 | Statutory due date for the Art. 12 labelling implementing act (pictograms and material-composition methodology). | SIGNALED |
| Aug 12, 2028 | Standalone Green Dot and other potentially misleading marks restricted once the harmonised label applies (Art. 12(8)). | SIGNALED |
| Aug 12, 2028 | Harmonized EU sorting pictograms become mandatory on consumer packaging; material-composition labelling applies. National labels may not be maintained alongside the EU label. | LOCKED |
| From 2028+ | Reusable packaging carries a reusability label; DRS-eligible containers carry deposit marking; QR or digital carriers may link to a Digital Product Passport where required. | SIGNALED |
What Changes
โป๏ธ Material and sorting pictograms
A harmonized pictogram conveys material composition and which bin the packaging belongs in, so consumers sort the same way EU-wide. Exact icons come from the Art. 12 implementing act.
๐ข Green Dot phased out as a standalone mark
The Green Dot loses standalone status. A symbol indicating EPR fees have been paid may only appear inside a QR code, not as a separate printed mark, once the harmonized label applies [SIGNALED, confirm against the final act]. In Portugal, the Green Dot stops applying to beverage containers after August 9, 2026 as Volta DRS marking takes over.
๐ต Deposit marking
Containers in scope of a deposit return system carry deposit marking regardless of EPR exemption status. Marking specifics vary by national scheme (for example Volta in Portugal, Pfand in Germany).
๐ช๐บ National marks during transition
Until the harmonized label applies, some national marks remain: France requires Triman and Info-Tri sorting instructions; Italy requires alphanumeric material codes (PP 5, PET 1) until the Aug 2028 transition. These cannot be maintained alongside the EU label afterward.
Pictogram artwork and minimum sizes are not final until the Art. 12 implementing act publishes. Treat label redesign specifications as provisional until then. This section will be updated when the act is adopted.
What's New
Recent PPWR developments, regulatory updates, and open issue movements. Updated June 30, 2026.
Jun 2026
Portugal Launches Volta Deposit Return System
Portugal's national deposit return system, Volta, went live on April 10, 2026, ahead of PPWR. A EUR 0.10 deposit applies to single-use plastic bottles and metal cans up to 3 litres (glass and beverage cartons are excluded for now), administered by SDR Portugal across roughly 2,500 return machines and 8,000 manual points. During a transition to August 9, 2026, Volta and Green Dot containers coexist; after that date only Volta-marked beverage containers are permitted and the Green Dot no longer applies to beverage containers. Source: Zero Waste Europe; TOMRA (April 2026).
May 2026
ACT-02 in Preparation: Recyclability Grade Criteria Still Being Developed
The ACT-02 delegated act on Design for Recycling and the Recyclability Grade A/B/C criteria is in preparation; the criteria and the JRC methodology are still being developed and the act is not yet published for public consultation. Key contested areas: flexible packaging grade boundaries, EVOH barrier layer treatment, and colorant thresholds. Adoption before the Aug 12, 2026 application date is not expected, so brands should treat DoC recyclability fields as provisional until ACT-02 is finalized (due Jan 1, 2028).
Apr 2026
Italy Files TRIS Notification 2026/0167/IT, Compostable Single-Use Food Service
Italy notified the European Commission under the TRIS procedure seeking exemptions from PPWR's restrictions on compostable single-use food-service packaging. EC standstill response expected approximately July 2026. Outcome will be watched closely by multiple member states with established compostable packaging industries (particularly in relation to Biorepack-registered formats).
Mar 2026
ACT-08 Statutory Deadline Missed: Harmonized EPR Registration Format Not Published
The European Commission missed its February 12, 2026 statutory deadline (Art. 44(14) PPWR) to adopt the harmonized EPR registration and reporting format (ACT-08), and as of late June 2026 it remains unpublished. Producers must continue registering separately in each member state using national PRO formats. No timeline for adoption has been announced. This is a material compliance burden for non-EU e-commerce sellers selling into multiple markets simultaneously.
Dec 2025
Environmental Omnibus Proposal: AR Requirement Suspension Until 2035
The European Commission's Environmental Omnibus proposal (COM/2025/982, December 2025) would suspend the Article 45(3) Authorized Representative (AR) appointment requirement for EU-established producers selling cross-border until January 1, 2035. Non-EU producers are excluded and must still appoint an AR by August 12, 2026. As of June 2026 the proposal remains in European Parliament committee, not adopted, with no June trilogue or plenary vote. Austria's AR requirement (zero de minimis) applies in full until any adoption and entry into force.
Feb 2026
Reuse Targets: Detailed Rules Still Pending
PPWR sets reuse targets for certain packaging categories (notably beverages and transport packaging) that apply from January 1, 2030, with further targets indicated for 2040. The headline reuse percentages are set in Article 29 (transport packaging 40% by 2030 and an endeavour of 70% by 2040; beverages 10% by 2030 and an endeavour of 40% by 2040). What remains pending is the Article 30 calculation-methodology implementing act (due June 30, 2027) defining how the targets are measured, along with qualifying formats and exemptions. No reuse implementing act has been confirmed as adopted on EUR-Lex as of mid-2026. Brands in beverage and e-commerce sectors should begin reuse system planning given 2030 lead times.
Ongoing
ACT-02 Watch: DfR Criteria Will Reshape EPR Fee Structures Across EU
ACT-02 (Design for Recycling criteria, Recyclability Grade A/B/C thresholds) remains the single most consequential piece of pending secondary legislation under PPWR. Its adoption will finalize which packaging formats fall below Grade C and cannot be placed on the market from 2030; set the technical basis for harmonized eco-modulation fee adjustments in all 27 member states (mandatory about 18 months after adoption, roughly mid-2029); and enable brands to finalize DoC recyclability fields. Brands with capital investment decisions dependent on recyclability grade outcomes should build flexibility into packaging redesign roadmaps.
๐ถ EU Packaging Fee Estimator
Estimate annual EPR compliance fees across EU member states. Two modes: portfolio-level (enter annual tonnage by material) or per-SKU (enter each packaging component). Rates from verified 2025/2026 PRO schedules. Eco-modulation is excluded from the portfolio estimate and offered as an illustrative layer in the per-SKU estimator; design attributes can move fees by 10 to 100 percent.
Enter annual tonnage by material for a given market. 12 categories reflecting how major EU PROs actually price packaging, plastic is split by format (rigid/flexible) and recyclability grade. Formula: Tonnes ร PRO base rate (โฌ/tonne) = annual fee. Eco-modulation adjustments (ยฑ10โ100%), SME flat rates, and SUP per-unit fees not applied.
โ๏ธ Annual Tonnage by Material
๐ช๐บ Countries to Compare
๐ฐ Estimated Annual EPR Fees
๐ถ
Enter tonnage to see results
Select countries and enter annual tonnes by material
โ ๏ธ Planning estimates only, not for compliance reporting. Rates are verified base fees from PRO schedules; eco-modulation (ยฑ10โ100%) excluded. Netherlands: Rigid Recyclable and Rigid Hard-to-Recycle show the same base rate, Verpact differentiates recyclability through eco-mod, not the base fee. Italy plastic rates from CONAI 9-band Corepla system. Germany and Belgium: compliance rates not public. France: CITEO 2026 official weight-based rates (the per-unit component is excluded here; use the Per-SKU Estimator to include it). CZ rates converted at 25.3 CZK/EUR; SE at 10.9 SEK/EUR. Sweden rates are exceptionally high due to mandatory kerbside expansion.
๐ Rate Data Sources & Coverage
13 countries with confirmed or indicative primary-source rates. 2 countries (DE, BE) do not publish compliance rates publicly. Italy (CONAI) and Netherlands (Verpact): plastic sub-categories confirmed from primary PRO sources. All other countries: rigid/flex sub-split estimated from published recyclable/non-recyclable rates.
| Country | PRO / Source | Year | Confidence | Notes |
|---|