Compliance

Packaging and Packaging Waste Regulation

EU regulation replacing the packaging directive, setting recyclability, reuse and labelling requirements that phase in over several years.

Aliases: PPWR, Packaging Regulation, Regulation (EU) 2025/40, 包装与包装废弃物法规

What changed in legal form

The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, replaced Directive 94/62/EC. The change from directive to regulation matters: a regulation applies directly in every member state, so the minimum requirements stop diverging at national level.

It entered into force in 2025 and applies from 12 August 2026, with many substantive obligations staged afterwards through delegated acts and transition periods.

The obligations that reach sellers

Design for recyclability, with performance grades defined over time
Limits on empty space and on unnecessary packaging for e-commerce shipments
Labelling with material composition and a harmonised sorting mark
Minimum recycled content for plastic packaging, phased by product group
Reuse and refill targets for certain transport and retail packaging
Reporting on packaging placed on the market

For an online seller the empty-space and labelling rules are the first to bite, because they apply to the shipping box and mailer, not only to the retail pack.

The timeline problem

Almost nothing here is a single date. Recyclability grades, design-for-recycling criteria and the labelling format arrive through delegated acts. Reuse targets differ by packaging type. This is why the regulation should be treated as a programme rather than an event: each obligation needs its own owner and its own readiness check.

Sellers who register under EPR schemes already report packaging volumes; the PPWR adds design and labelling conditions on top of that reporting. Substance limits on packaging interact with REACH, and information duties connect to the digital product passport as that framework matures.

What to do now

Map every packaging component per SKU: retail pack, inner protection, shipping box, tape, label
Measure empty space in current shipment configurations
Ask suppliers for material composition and recycled content evidence
Track delegated acts rather than waiting for national transposition, since there will be none

Interaction with ESPR

The ESPR sets the framework for product-level sustainability requirements, while the PPWR does the same for packaging. They share data logic, and the passport workstream will eventually carry packaging information alongside product information for the same SKU.

Primary source: Regulation (EU) 2025/40.

FAQ

When does the PPWR apply?

It applies from 12 August 2026, after entering into force in 2025. Specific obligations, including recyclability grades and labelling formats, phase in later through delegated acts.

Does the PPWR apply to shipping boxes?

Yes. E-commerce packaging, including shipping boxes, mailers and filler, falls within scope, and the empty-space limits apply to the total packaging of the shipped item.

Does PPWR replace national EPR registration?

No. [EPR](/wiki/epr) registration and fee payment remain national. The PPWR harmonises design, labelling and reporting requirements but does not create a single EU register.

What is the empty space rule?

It limits the proportion of empty space in transport and e-commerce packaging, with the aim of cutting material use and vehicle volume. The detailed calculation method is set through implementing acts.

How does PPWR relate to ESPR?

They are parallel frameworks. [ESPR](/wiki/espr) covers product sustainability requirements and the product passport; the PPWR covers packaging design, composition and waste, including packaging data that may feed the same passport.