PPWR: Packaging and Packaging Waste Regulation
Identify the obligations that apply to your company and plan your PPWR compliance pathway with Tentamus
Regulation (EU) 2025/40 on packaging and packaging waste, known as the PPWR – Packaging and Packaging Waste Regulation, introduces new requirements for companies that manufacture, import, distribute or place packaging and packaged products on the European market.
The PPWR entered into force on 11 February 2025 and will generally apply from 12 August 2026, with further obligations being introduced progressively until 2040.
Companies will need to verify packaging compliance, collect data and information along the supply chain, carry out any necessary testing and prepare appropriate documentary evidence.
Through its network of laboratories and consulting companies, Tentamus combines analytical, technical and regulatory expertise to support companies throughout their PPWR compliance journey.
What’s is new
Regulation (EU) 2025/40 marks a significant change in European legislation on packaging and packaging waste. The PPWR replaces the previous Directive 94/62/EC and introduces a regulatory framework that is directly applicable in all Member States, with the aim of harmonising requirements and responsibilities across the European market.
For companies, compliance will not be limited to the characteristics of the final packaging, but will involve the entire packaging management process: design, material selection, supplier relationships, collection of technical data, analytical testing and preparation of documentation.
The main areas regulated by the PPWR include:
- restrictions on PFAS, heavy metals and other restricted substances;
- recyclability and design for recycling;
- minimum recycled content;
- reduction of weight, volume and empty space;
- reuse and refill requirements;
- restrictions on certain single-use packaging formats;
- compostability requirements;
- harmonised labelling at European level;
- traceability and exchange of information along the supply chain;
- conformity assessment;
- technical documentation and the EU Declaration of Conformity.
The different requirements will apply progressively and according to different deadlines. It will therefore be necessary to identify the applicable obligations by considering the company’s role in the supply chain, the type and intended use of the packaging, and the market in which it is sold.
The PPWR will have a tangible impact on several corporate functions, including quality, regulatory affairs, procurement, research and development, production, sustainability and packaging design. In many cases, companies will need to review packaging already in use, verify the information received from suppliers and address any technical, documentary or analytical gaps.
Which companies does it apply to?
The PPWR does not apply only to packaging manufacturers. It involves economic operators that manufacture, import, distribute or place packaging and packaged products on the European Union market.
The Regulation applies to all types of packaging, regardless of the material used, including packaging intended for sales, grouping, transport and e-commerce. Its scope therefore includes, among others, food, cosmetic, pharmaceutical, commercial and industrial packaging made of plastic, paper and cardboard, glass, metal, wood or composite materials.
The obligations vary according to the role performed in the supply chain.
Packaging manufacturers and producers
They must verify that packaging complies with the applicable requirements for design, composition, restricted substances and performance. The PPWR also establishes specific obligations relating to conformity assessment, technical documentation and the EU Declaration of Conformity.
Importers
Operators that bring packaging or packaged products from non-EU countries onto the European market must verify, before placing them on the market, that the Regulation’s requirements have been met and that the required documentation is available.
E-commerce and logistics operators
The PPWR also covers packaging used for online sales, delivery and transport. Packaging minimisation, the reduction of empty space and the requirements applicable to shipping packaging are particularly relevant to these operators.
Brand owners and private-label companies
Companies that market packaging or packaged products under their own name or trademark may assume the role of manufacturer and the related responsibilities. It is therefore essential to clarify their role, collect reliable information from suppliers and verify the available evidence.
Distributors and retailers
They must ensure that packaging made available on the market bears the required information and is accompanied by the applicable documentation, taking action if any elements emerge that may indicate non-compliance.
Timeline and deadlines
The PPWR provides for the progressive application of requirements, with obligations entering into force at different times between 2026 and 2040.
Understanding the Regulation’s timeline is essential to plan compliance activities correctly, avoid operational issues and structure the compliance pathway in good time.
| 11 February 2025 | Entry into force of Regulation (EU) 2025/40. |
| 12 August 2026 | The first obligations under the Regulation begin to apply, including:
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| 12 February 2027 | From 2027, the requirements relating to refill systems in the HORECA sector begin to apply. By this stage, several delegated acts and operational guidelines are also expected on:
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| 12 February 2028 | The following requirements enter into force:
The Regulation also introduces increasingly stringent criteria against overpackaging, with particular attention to unnecessary packaging and excessive empty space. |
| 12 August 2028 | The new European rules on harmonised packaging labelling become applicable. Labels must facilitate:
Digital systems such as QR codes and paperless information tools will also be introduced. |
| 1 January 2030 | Some of the PPWR’s most impactful requirements will enter into force from 2030:
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| 2035–2038 | From 2035, only packaging that is recyclable at scale will be permitted. |
| From 2038 | Only packaging in the highest recyclability classes may be placed on the market. |
| 2040 | The Regulation provides for further increases in:
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Challenges for the Food Sector
For food companies, complying with the PPWR means rethinking packaging while balancing environmental objectives, food safety, product preservation and industrial feasibility. The new requirements will progressively affect materials, formats, procurement processes and the information exchanged along the supply chain.
From 12 August 2026: chemical safety and packaging compliance
From 12 August 2026, specific limits for PFAS in food-contact packaging will apply. The PPWR also regulates the total concentration of lead, cadmium, mercury and hexavalent chromium in packaging.
Companies will need to assess the information received from suppliers by considering materials, composition and risk level. Where necessary, testing for PFAS, total fluorine and heavy metals can provide technical evidence to support compliance.
The placing of packaging on the market must also be supported by a conformity assessment, technical documentation and the EU Declaration of Conformity. This will require closer collaboration between packaging manufacturers, suppliers, packers, brand owners, importers and retailers.
From 2027: extended producer responsibility
The PPWR strengthens obligations connected with extended producer responsibility by requiring registration in national systems, data reporting and contributions towards packaging waste management costs.
Companies that market products in several European countries will need to verify the obligations required in each market and properly organise the collection and transmission of information.
From 2028: harmonised labelling
Packaging will have to bear a harmonised label containing information on material composition to facilitate correct disposal. Specific information will also be required for reusable packaging and packaging subject to deposit and return systems.
Food companies will need to coordinate these requirements with the information already displayed on packs and with food labelling obligations, while managing often limited space and packaging intended for different markets.
From 2030: packaging recyclability, reduction and circularity
From 2030, a set of requirements designed to transform the design and use of packaging will apply:
- design for recycling according to harmonised criteria;
- classification of packaging according to recyclability performance;
- minimum percentages of recycled material for certain types of plastic packaging;
- minimisation of weight and volume;
- reuse targets for specific types of packaging;
- restrictions on certain single-use formats;
- obligations relating to refill and reuse solutions.
For the food sector, the challenge will be to reconcile these objectives with safety, barrier properties and product shelf life. The review of multilayer structures, coatings, adhesives and other components must not compromise food protection.
Any reduction in the amount of material used must also be assessed carefully. Shelf-life studies can support the development of new formats or lightweight materials by verifying that packaging optimisation does not increase deterioration and food waste.
For plastic packaging that comes into contact with food, the use of recycled material must also comply with the applicable food contact materials (FCM) legislation. It will therefore be necessary to verify the origin, quality and suitability of materials, as well as the documentation provided by suppliers.
From 2035 and 2040: progressively stricter requirements
From 2035, packaging must be recyclable at scale, as well as meeting design-for-recycling criteria.
From 2040, the recycled content and reuse targets for the types of packaging concerned will increase further. Companies must therefore plan a progressive compliance pathway, monitoring the development of technical criteria and implementing provisions.
Tentamus solutions for compliance
PPWR compliance requires a combination of regulatory assessment, knowledge of materials, collection of information along the supply chain and any necessary analytical testing.
By combining specialised laboratories and consulting expertise, Tentamus supports companies in defining a compliance pathway tailored to their role, the characteristics of their packaging and the applicable requirements.
Food packaging is among the categories most affected by the PPWR, particularly with regard to the presence of PFAS and other hazardous substances, the safety of food contact materials and the need to reduce packaging without compromising product quality and preservation.
The PPWR does not replace the legislation applicable to food contact materials and articles. Food companies must therefore integrate the new environmental requirements with the existing obligations concerning packaging safety and suitability.
Through the expertise of its laboratories, Tentamus supports food manufacturers, packaging companies, retailers and supply chain operators with:
- PFAS and total fluorine testing
Article 5 of the PPWR introduces specific limits for the presence of PFAS in food-contact packaging, applicable from 12 August 2026.
Tentamus supports companies through targeted tests for PFAS and the determination of total fluorine, based on the characteristics of the packaging and the available information on the materials used. - Heavy metal testing
The PPWR establishes requirements relating to the presence of lead, cadmium, mercury and hexavalent chromium in packaging or its components.
Tentamus performs tests to determine these metals, supporting companies in verifying their concentrations in materials and collecting the necessary analytical evidence.
The tests are defined by considering the packaging composition, the materials used and the information available along the supply chain. - Food contact material and migration testing
For packaging intended to come into contact with food, the sustainability requirements introduced by the PPWR must be assessed together with the provisions applicable to food contact materials and articles.
Tentamus performs food safety and migration tests on packaging materials intended to come into contact with food, supporting companies in verifying the suitability of materials and assessing potential interactions between packaging and food.
Testing may also be necessary when packaging is modified to reduce its weight or volume, or when new materials, components or design solutions are introduced. - Shelf-life studies for packaging optimisation
Reducing packaging must not compromise product safety, quality or shelf life.
Shelf-life studies make it possible to assess the effects of packaging changes and verify that the new packaging continues to provide adequate protection and preservation conditions.
The studies can support projects aimed at:- reducing the amount of material used;
- optimising packaging weight and volume;
- assessing alternative materials or formats;
- verifying the performance of the new packaging;
- maintaining product quality and safety;
- preventing deterioration and food waste.
PPWR training provides a practical and structured overview of Regulation (EU) 2025/40, enabling the corporate functions involved to understand its requirements, responsibilities and timelines.
The session covers:
- the regulatory context and the objectives of the Regulation;
- the parties involved and their respective responsibilities;
- the main obligations for companies;
- deadlines and application timelines;
- the impact on different corporate functions and business processes.
The training has an indicative duration of 1.5–2 hours and may involve quality, procurement, research and development, production, marketing, legal and sustainability teams.
The PPWR provides for the progressive publication of delegated and implementing acts that will define methodologies, technical criteria and application procedures for numerous requirements.
The regulatory update service allows companies to monitor over time:
- regulatory developments;
- the publication of implementing acts;
- new relevant provisions;
- deadlines to be scheduled;
- potential impacts on business activities and packaging.
The assessment translates the PPWR’s general requirements into concrete obligations for the individual organisation.
The activity begins with an analysis of the company, its role in the supply chain and the types of packaging it uses or places on the market. The existing situation is then compared with the Regulation’s requirements to identify critical issues, missing information and priorities for action.
- Analysis of the company’s context and activities.
- Identification of the roles performed in the supply chain.
- Review of the types of packaging handled.
- Identification of the applicable requirements.
- Verification of the available information and documents.
- Identification of gaps and potential critical issues.
- Definition of priorities and relevant deadlines.
At the end of the activity, a Final Report is issued describing the assessments carried out, summarising the applicable provisions and focusing on the obligations relevant to the company and its sector.
We support companies in designing and implementing their packaging conformity assessment system by defining processes, responsibilities and technical documentation. The service also includes organising information from the supply chain and suppliers to ensure structured management of the documentary evidence required by the PPWR.
- Analysis of internal roles and responsibilities.
- Mapping of information flows along the supply chain.
- Definition of the information to be requested from suppliers.
- Structuring of the conformity assessment procedure.
- Organisation of technical evidence.
- Support in preparing or updating technical documentation.
- Support in preparing the EU Declaration of Conformity.
The consulting service includes assessing the completeness and consistency of the technical documentation relating to packaging manufactured directly by the company or purchased from suppliers.
The verification may cover:
- EU Declarations of Conformity for packaging;
- conformity assessment procedures;
- technical data sheets for individual packaging components;
- declarations and information provided by suppliers;
- test reports used to demonstrate compliance with the applicable requirements;
- additional technical evidence required by the Regulation.
The activity identifies missing documents, incomplete information or elements that require further investigation. It can also support the company in defining the documentary requests to be sent to its suppliers.
Tentamus supports companies in assessing the environmental impacts of packaging and potential optimisation solutions through recognised methods and tools.
The service may include:
- Life Cycle Assessment (LCA) studies and assessment of impacts throughout the life cycle;
- Carbon Footprint calculation;
- development of Environmental Product Declarations (EPDs);
- identification of the main areas for improvement;
- production of data and evidence to support sustainability strategies and environmental communication.
These activities make it possible to assess the environmental performance of packaging based on measurable data, preventing decisions such as reducing material or replacing a component from shifting impacts from one stage of the life cycle to another.
The results can also provide a technical basis to support specific and verifiable environmental claims, in accordance with the applicable regulatory framework.
From 27 September 2026, the provisions introduced by Directive (EU) 2024/825 will apply, strengthening consumer protection against greenwashing and misleading environmental communication. Companies will need to pay greater attention to environmental claims used on packaging and in communication materials, avoiding statements that are generic, inadequately substantiated or based on unverifiable data.
Terms such as “green”, “ecological”, “sustainable”, “environmentally friendly” or “nature-friendly” may not be used unless a recognised environmental performance relevant to the claim can be demonstrated. Particular attention must also be paid to sustainability labels, climate-neutrality claims and claims that refer only to part of the product or packaging but are presented as applying to the entire product.
Tentamus supports companies in reviewing green claims and defining environmental communication that is consistent with the packaging’s actual characteristics, the available evidence and the applicable regulatory framework.
The service may include:
- verification and review of environmental claims displayed on packaging, products, websites, brochures, commercial materials, etc.;
- analysis of the documentation and evidence used to support them;
- assessment of the risk associated with environmental statements based on compliance with current green claims legislation.
The assessment of claims may be based on evidence such as Eco Labels, LCA studies, Carbon Footprints, EPDs, supply chain data, certifications and analytical results.
Tentamus support for different sectors
Food & beverage
PFAS, total fluorine and heavy metal testing, migration testing, food contact material safety and shelf-life studies for packaging optimisation.
Cosmetics and personal care
Verification of packaging materials and documentation, assessment of the applicable requirements and support in managing information received from suppliers.
Pharmaceutical and medical
Technical and documentary assessments to integrate PPWR requirements with product safety, protection and stability needs.
Detergents and home care
Support in verifying packaging composition, restricted substances and technical documentation.
Retail and private label
Analysis of brand owner responsibilities, supplier mapping, verification of available evidence and support with conformity assessment.
Packaging manufacturers
Assessment of applicable requirements, laboratory testing and support in preparing the information to be provided to customers along the supply chain.
HORECA and accommodation facilities
Support in complying with PPWR requirements specific to restaurants, bars, takeaway businesses, hotels and accommodation facilities: verification of food packaging and food contact material requirements, PFAS testing, introduction of refill and reuse systems, assessment of alternatives to single-use formats and management of the new restrictions envisaged from 2030.
Why Tentamus
- Integrated analytical and regulatory expertiseA single network that combines regulatory interpretation, technical assessment and laboratory testing.
- Support throughout the entire processFrom initial packaging mapping to producing the evidence needed to document compliance.
- Food packaging expertiseSpecialist expertise in food contact material safety, migration testing and shelf-life studies.
- National and international networkWe are a global network of laboratories and consulting companies serving the quality, safety and compliance needs of products and organisations.
FAQ
When does the PPWR apply?
The Regulation entered into force on 11 February 2025 and will generally apply from 12 August 2026. Further requirements will progressively apply in subsequent years, according to different deadlines.
Which companies does the PPWR apply to?
The PPWR applies to companies that manufacture, import, distribute or place packaging and packaged products on the European market. Obligations vary according to the role performed in the supply chain.
Does the PPWR also apply to companies that sell products under their own brand?
Yes. Under certain conditions, a company that markets packaging or a packaged product under its own name or trademark may be considered a manufacturer and assume specific responsibilities regarding compliance and documentation.
Does the PPWR also apply to food packaging?
Yes. Food packaging is subject both to the general PPWR requirements and to specific provisions, including limits on PFAS. The rules concerning materials and articles intended to come into contact with food also remain applicable.
What limits does the PPWR introduce for PFAS?
From 12 August 2026, food-contact packaging may not be placed on the market if it contains PFAS at concentrations equal to or above the limits established by the Regulation, measured through targeted analyses, total PFAS or total fluorine under the specified conditions.
Is a supplier declaration sufficient to demonstrate compliance?
It depends on the requirement, the reliability and completeness of the documentation, and the level of risk associated with the packaging. In some cases, it may be appropriate to verify the information through laboratory testing or additional technical evidence.
What testing may be required?
Depending on the material and intended use, testing for PFAS, total fluorine and heavy metals may be required, in addition to food safety and migration testing for food-contact packaging.
What is the EU Declaration of Conformity required by the PPWR?
It is the document through which the manufacturer declares that the packaging complies with the applicable requirements of the Regulation. It must be supported by an appropriate conformity assessment and the relevant technical documentation.
Who is responsible for the EU Declaration of Conformity?
Responsibility lies with the manufacturer identified in accordance with the definitions and conditions established by the Regulation. The correct attribution of this role must be verified by considering the relationship between the packaging producer, the brand owner and the parties that place it on the market.
How should a portfolio comprising many types of packaging be managed?
It is advisable to begin by mapping the portfolio and, where technically possible, grouping packaging into homogeneous families according to materials, structure, intended use and supplier. This activity makes it possible to establish priorities and define a verification plan proportionate to risk.
How can Tentamus support compliance?
Tentamus combines technical-regulatory consulting and laboratory testing. Support may include training, regulatory updates, assessments, gap analysis, specific evaluations, hazardous substance testing, migration testing, shelf-life studies and support in structuring the conformity assessment system.