EU Packaging and Packaging Waste Regulation
Regulation (EU) 2025/40 -- replacing the Packaging Directive with directly applicable, harmonised rules for every company that places packaging on the EU market.
The EU Packaging and Packaging Waste Regulation is a new law that changes how every company selling products in Europe must think about packaging. If you manufacture, import, distribute, or sell packaged goods in any EU country, this regulation applies to you -- whether you are a multinational food brand or a small e-commerce retailer shipping from a single warehouse.
Until now, EU packaging rules were set by a directive from 1994, which each country interpreted differently. That created 27 sets of rules, making compliance expensive and inconsistent. The new regulation replaces all of that with a single, directly applicable rulebook. There is no national transposition -- the same obligations apply identically in every Member State from the application date in August 2026, with major targets phased in through 2030, 2035, and 2040.
In practical terms, the regulation requires companies to use minimum amounts of recycled plastic in their packaging, design packaging so it can actually be recycled, shift certain packaging formats to reusable systems, and stop using specific single-use formats entirely. It also limits how much empty space you can leave in a shipping box, bans hazardous substances like PFAS from food-contact packaging, and introduces mandatory digital labelling through QR codes.
The penalties for non-compliance are set by each Member State but can include fines, product withdrawal from the market, and import restrictions. Beyond direct enforcement, the regulation also restructures Extended Producer Responsibility fees so that companies using hard-to-recycle packaging pay significantly more. In short: packaging design is now a regulated compliance function, not just a marketing or logistics decision.
Switzerland is not an EU member state and is not directly bound by the PPWR. However, any Swiss company that exports packaged products to the EU market, operates subsidiaries in EU countries, or supplies packaging materials to EU-based manufacturers will need to ensure their packaging meets PPWR requirements. EU importers and distributors are responsible for compliance, and they will increasingly push these obligations upstream to their Swiss suppliers.
Switzerland's own packaging regulations -- primarily governed by the Ordinance on Beverages and the voluntary recycling system coordinated by Swiss Recycling -- cover some overlapping ground but do not mandate recycled content percentages, design-for-recycling grades, or digital labelling. Swiss companies serving EU markets should conduct a gap analysis now, particularly around recycled content sourcing, recyclability documentation, and QR-code labelling infrastructure, to avoid disruptions when the general application date arrives in August 2026.
The EU generates over 84 million tonnes of packaging waste annually -- a figure that grew 20% in a decade and is projected to rise further without intervention. The old Packaging Directive (94/62/EC) relied on national transposition, producing a patchwork of 27 different rule sets that fragmented the single market and failed to curb waste growth.
PPWR replaces that directive with a directly applicable regulation. This is a fundamental shift: one set of rules, one compliance standard, no national variations. For the first time, the EU mandates specific recycled content percentages, sector-specific reuse targets, design-for-recycling criteria graded by recyclability performance, and outright bans on wasteful single-use formats.
The regulation sits at the intersection of the European Green Deal, Circular Economy Action Plan, and the broader push toward a zero-pollution economy. It works alongside the EU Battery Regulation, the Ecodesign for Sustainable Products Regulation (ESPR), and the Digital Product Passport framework to create a comprehensive circularity regime across product categories.
For businesses, the impact is immediate and cross-functional: R&D must redesign packaging for recyclability, procurement must secure recycled material supply, operations must implement reuse systems, marketing must update labels, and legal must navigate harmonised EPR obligations across every Member State where products are sold.
| PACKAGING CATEGORY | BY 2030 | BY 2040 |
|---|---|---|
| Contact-sensitive PET (excl. single-use beverage bottles) | 30% | 50% |
| Single-use PET beverage bottles | 30% | 65% |
| Contact-sensitive plastic packaging (non-PET) | 10% | 25% |
| Non-contact-sensitive plastic packaging | 35% | 65% |
Post-consumer recycled (PCR) content. Measured as percentage of plastic weight. Verified through mass-balance or physical traceability.
Select your company type for tailored compliance guidance.
Conduct a full packaging portfolio audit: catalogue every SKU by material type, contact-sensitivity, and current recycled content to identify gaps against 2030 targets.