Strengthened packaging requirements take effect in the EU: changes for business

On 12 August, a new regulation on packaging and packaging waste – PPWR – began to apply in the European Union. It covers all types of packaging regardless of material, intended use or country of origin.

The regulation entered into force back on 11 February 2025, but its general application began only now. The document replaced a 1994 directive and established uniform rules for all EU countries.

From now on, manufacturers and importers must confirm compliance of packaging with current requirements, prepare technical documentation and an EU declaration of conformity. The obligations also extend to foreign companies that supply packaged goods to the European market, including Ukrainian exporters.

One of the key changes is a ban on selling in the EU packaging that comes into contact with food and contains per- and polyfluoroalkyl substances – PFAS – in concentrations equal to or exceeding the limit values set by the regulation. These persistent chemical compounds may be used to protect packaging from grease, water and contamination.

Packaging must also comply with restrictions on the content of lead, cadmium, mercury and hexavalent chromium. Their total concentration must not exceed 100 mg per kilogram of packaging or its components.

For consumers, the new rules do not require replacing or discarding existing packaging. Control will be exercised through manufacturers, importers, sellers, supply chain documentation and market surveillance authorities.

The remaining requirements will be introduced gradually by the European Union. Key next steps include:

• from 2028 – harmonised labelling of packaging composition, provided the necessary implementing acts are in force by then;
• from 2030 – mandatory design of packaging for recycling, minimum recycled plastic content and restrictions on certain types of single-use packaging;
• from 2030 – no more than 50% empty space in transport, grouped and e-commerce packaging;
• from 2035 – requirement for packaging to be recycled at industrial scale;
• from 2038 – only packaging with the highest recyclability classes will be allowed on the market.

The aim of the regulation is to reduce the amount of unnecessary packaging, increase reuse and recycling of materials and harmonise requirements across the EU single market.

Based on materials from: European Commission; Official Journal of the European Union