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Packaging compliance services for the PPWR Regulation

Prepare your packaging for PPWR Regulation (EU) 2025/40 with TÜV SÜD compliance assessments, laboratory testing and technical documentation support.

Prepare your packaging for PPWR Regulation (EU) 2025/40 with TÜV SÜD compliance assessments, laboratory testing and technical documentation support.

The PPWR Regulation at a glance

  • Applies from 12 August 2026

    The PPWR Regulation applies across the EU from 12 August 2026 and introduces new requirements that will take effect progressively through to 2040.
  • Regulation (EU) 2025/40 

    The PPWR replaces the Packaging and Packaging Waste Directive (PPWD) with rules that apply directly in every EU Member State.
  • Covers all packaging 

    The PPWR covers packaging and packaging waste of every material and origin.
  • EU Declaration of Conformity 

    PPWR technical documentation and an EU Declaration of Conformity are required before packaging is placed on the EU market.
  • 2030 is a key milestone 

    From 2030, specific recyclability requirements will apply, together with minimum recycled-content requirements for certain plastic packaging.

Frequently asked questions (FAQs)

  • What is the PPWR Regulation?

    The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, governs packaging and packaging waste. It entered into force on 11 February 2025 and applies across the EU from 12 August 2026. It replaces Directive 94/62/EC, the PPWD, and introduces harmonised requirements that apply directly in every EU Member State.

    The PPWR covers all packaging and packaging waste, regardless of material or origin. It introduces obligations concerning the EU Declaration of Conformity and PPWR technical documentation, recyclability and recycled content, PFAS restrictions for food-contact packaging, heavy-metal limits for all packaging, harmonised labelling and extended producer responsibility (EPR).

  • Who does the PPWR Regulation apply to?

    The PPWR creates obligations throughout the packaging value chain, depending on the organisation’s role, its activity within the EU market, and the type of packaging.

    Packaging manufacturers must ensure that packaging design, materials and documentation meet the applicable PPWR requirements.

    Brand owners and producers must review packaging choices, supplier data, labelling, EPR obligations and evidence of compliance.

    Importers must verify the compliance of packaging or packaged products before placing them on the EU market.

    Distributors and retailers must check compliance, labelling and mandatory information before making products available.

    E-commerce businesses and fulfilment service providers must take steps to minimise packaging, clarify responsibility and carry out checks on the responsible economic operators. 

  • How does the PPWR differ from the PPWD?

    The PPWR is a directly applicable and binding EU regulation replacing the PPWD, a directive which was interpreted differently by each member state. The main changes include:

    • Reuse and refill targets for specified packaging types and sectors.
    • Mandatory minimum recycled content for certain plastic packaging.
    • Stricter design-for-recycling criteria and recyclability requirements.
    • A more harmonised EPR framework with eco-modulated fees.
    • EU-wide harmonised labelling for recyclability, separate collection and disposal information.
    • Stronger market surveillance, enforcement and penalties across the EU.
  • What are the main PPWR requirements for businesses?

    Businesses must maintain PPWR technical documentation and an EU Declaration of Conformity, supported by evidence such as test reports, recyclability assessments, supplier declarations, material data, recycled-content evidence, labelling information and EPR data. From 2030, packaging must meet defined recyclability performance grades, while certain plastic packaging must contain minimum levels of recycled material, for example 30% for single-use plastic beverage bottles.

    Packaging minimisation supports the per-capita packaging-waste reduction targets of 5% by 2030, 10% by 2035 and 15% by 2040. Food-contact packaging is subject to PFAS limits of 25 ppb for an individual substance, 250 ppb for the sum of PFAS and 50 ppm for total PFAS, including polymeric PFAS. All packaging is also subject to a 100 mg/kg limit for the combined concentration of lead, cadmium, mercury and hexavalent chromium. Harmonised PPWR labelling and EPR registration, reporting and eco-modulated fees complete the framework.

  • What are the key PPWR dates and deadlines?

    The PPWR applies from 12 August 2026. The next key deadlines are 12 August 2028 for harmonised labelling and 2030 for recyclability, recycled content and reuse. Businesses should use 2027 to prepare for the EU labelling requirements and emerging packaging-data obligations as implementing rules are defined.

    Compostability requirements for certain packaging formats also apply from 2028. Further requirements on recycled content, reuse, waste reduction and recyclability performance will be phased in between 2035 and 2040.

    • Review the PPWR timetable early to understand the implications for packaging design, material selection, labelling, data management and compliance documentation. 

     

  • Why is PPWR compliance important?

    PPWR compliance is important because the Regulation introduces binding packaging requirements across the EU. These affect market access, packaging design, material selection, supplier data management, and documentation. Businesses that delay preparation risk redesign delays, gaps in the EU Declaration of Conformity and technical documentation, EPR reporting problems, customer scrutiny and enforcement action.

  • How can TÜV SÜD help businesses comply with the PPWR?

    As an independent third party, TÜV SÜD supports businesses throughout their PPWR compliance journey with:

    • Packaging-portfolio readiness assessments against applicable PPWR requirements.
    • Laboratory testing for recyclability, recycled content, PFAS and heavy metals through sustainability testing services.
    • Design-for-recycling assessments against the criteria in Annex II.
    • Support with technical documentation and the EU Declaration of Conformity.
    • Assistance with EPR data management.
    • Regulatory monitoring of delegated acts, implementing acts and guidance.

    These services complement our circular economy and recycled-content certification services, supporting a consistent sustainability strategy across the value chain.

  • Does the PPWR apply to UK businesses?

    The EU's Packaging and Packaging Waste Regulation (PPWR) applies to UK businesses only when they place packaged goods on the EU market or the Northern Ireland market. It does not apply to domestic sales made strictly within Great Britain (England, Scotland, and Wales).

How to prepare for PPWR compliance

Technical documentation and an EU Declaration of Conformity have been required since 12 August 2026 for packaging placed on the EU market. If these are not yet in place, closing that gap is the first priority. Next comes readiness for the 2027, 2028 and 2030 deadlines.

Preparing early with TÜV SÜD offers three practical benefits:

  • Independent readiness review: Third-party identification of gaps in packaging, materials, supplier data and documentation.
  • Compliance testing: Assessment of recyclability, recycled content, substances and labelling through testing and compliance expertise.
  • Clear priorities across EU markets: A practical roadmap for organising tests, evidence, supplier data and documentation in your target markets.
Pictogram in .SVG for Person Certificate

The PPWR is fundamentally changing how packaging is designed, assessed and managed in the EU. Businesses that prepare now will be better placed to meet future requirements, reduce risk and seize the opportunities of a more circular economy.

Davide Trecchi

Sustainability Expert, TÜV SÜD

Our PPWR compliance services

TÜV SÜD turns PPWR requirements into practical action through readiness assessments, testing and technical documentation.

  • PPWR readiness assessment

Assess your packaging portfolio against applicable PPWR requirements, considering packaging type, material, intended use, destination markets and your role in the supply chain. Identify priority gaps and define an action plan for testing, evidence collection or redesign.

  • Packaging testing and material analysis

Assess packaging materials against PPWR technical requirements, including recyclability, recycled content, substances of concern, PFAS, heavy metals and compostability. Results provide evidence for checking supplier declarations and supporting compliance decisions.

  • Design-for-recycling assessment

Review packaging formats, material combinations, labels and closures against the recyclability criteria in Annex II. Identify potential improvements before redesign or market launch.

  • Technical documentation and EPR data

Prepare evidence supporting PPWR compliance and the EU Declaration of Conformity. Organise data for extended producer responsibility, eco-modulated fees and reporting across EU markets.

  • Regulatory monitoring and support

Stay informed about future delegated and implementing acts and guidance that will supplement the PPWR. TÜV SÜD helps translate updates into practical implications for your packaging portfolio and plan the next compliance steps.


Start with a structured PPWR readiness assessment

Initial readiness assessment

For businesses that need a clear starting point for meeting requirements already in force and preparing for upcoming PPWR deadlines.

  • Risk-based sampling of high-priority packaging
  • Coverage of PPWR requirements applicable to your portfolio
  • Screening for substances of concern, including PFAS
  • Identification of recyclability and recycled-content gaps
  • Mapping EPR obligations in target EU markets
  • Evidence checklist showing compliance status

Comprehensive compliance roadmap

For businesses that need a more detailed assessment covering advanced PPWR obligations and sector-specific requirements.

  • Full portfolio recyclability assessment against the criteria in Annex II
  • Recycled content verification methodology based on EN 15343
  • Assessment of reuse and refill targets
  • Preparation for the Digital Product Passport
  • PPWR labelling-readiness roadmap
  • Alignment of compliance requirements across the supply chain

Assessment outcome

Depending on the selected scope, you will receive a practical roadmap for planning tests, collecting evidence, redesigning packaging, aligning suppliers and preparing documentation.

Timeline of the EU PPWR Regulation

  • 2025 | Entry into force

The PPWR entered into force following publication in the Official Journal of the European Union.

  • 2026 | General application and first obligations

Since 12 August 2026, the PPWR has applied directly across the EU. Packaging placed on the market must be covered by technical documentation and an EU Declaration of Conformity, and must meet the substance restrictions, including PFAS limits for food-contact packaging.

  • 2027 | Preparing for labelling and packaging data

Prepare for harmonised EU labelling and packaging-data obligations as the implementing rules are defined.

  • If an EPR scheme is identified on packaging, that identification must be digital. 
  • Final distributors offering hot or cold drinks in takeaway packaging must provide a system for customers to bring their own container to be filled. 
  • 2028 | Harmonised packaging labelling introduced

Harmonised EU labelling applies from 12 August 2028 at the earliest, or 24 months after the Commission’s implementing acts enter into force, whichever is later. Those acts were due by 12 August 2026 and are still pending. Compostability obligations for certain packaging types, like tea and coffee bags, other single-serve tea and coffee units, and sticky labels on fruit and vegetables also take effect during 2028. 

  • 2030 | Key recyclability and recycled-content milestone

Packaging placed on the EU market must meet recyclability requirements. Recycled-content requirements apply to specified plastic packaging (subject to the Commission’s secondary legislation).

  • 2035–2040 | More stringent requirements

Further recycled-content, reuse, waste-reduction and recyclability-performance requirements will be phased in.

Next steps towards PPWR compliance

The PPWR has applied since 12 August 2026. Substance restrictions and conformity documentation are already mandatory. Requirements for labelling, recyclability and recycled content follow from 2028 and 2030.

TÜV SÜD supports you as an independent third party through PPWR readiness assessments, laboratory testing and preparation of PPWR technical documentation. We also offer sustainable product and Ecodesign for Sustainable Products Regulation services for a consistent compliance strategy.

Start your compliance journey with TÜV SÜD

Speak to our experts to assess your packaging against PPWR requirements and plan the next steps for the 2028 and 2030 deadlines.

Contact us now


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