On January 22, 2025, the European Union officially published the Packaging and Packaging Waste Regulation (EU) 2025/40, also known as PPWR. This regulation will fully replace the existing Directive 94/62/EC on August 12, 2026, becoming the primary EU legislation for the management of packaging and packaging waste.

The PPWR systematically integrates requirements for hazardous substance limits, recycled material content, recyclability grading (Grades A-C), and packaging reduction targets, establishing a comprehensive lifecycle management framework for packaging. For the first time in the packaging sector, the content of recycled materials is upgraded from a voluntary target to a mandatory requirement, with phased specific targets set for different types of plastic packaging. The specific requirements are as follows:

Specific Requirements

Substance Requirements in Packaging (Article 5)

Heavy Metal Limits

Identical to the requirements of Directive 94/62/EC, effective from February 11, 2025.

Total content of lead, cadmium, mercury, and hexavalent chromium must not exceed 100 mg/kg (Pb+Cd+Hg+Cr(VI) ≤ 100 mg/kg). Products subject to this regulation must also meet the requirements of (EC) No. 1907/2006 (REACH) Annex XVII or (EC) No 1935/2004 concerning Food Contact Materials (FCM) and articles.

PFAS Limits in Food Contact Packaging

New requirements effective from August 12, 2026:

• Any single PFAS substance less than 25 ppb (excluding PFAS polymers);
• Total of individual PFAS substances less than 250 ppb (excluding PFAS polymers); and
• Total of all PFAS substances less than 50 ppm (including PFAS polymers).

If total fluorine exceeds 50 ppm, manufacturers or importers must provide downstream entities with proof of PFAS or non-PFAS fluorine content.

CIRS Testing Services

• Heavy Metal Content Testing;
• PFAS Content Testing;

Recyclability of Packaging (Article 6)

Recyclability Requirements

All packaging placed on the market must be recyclable, with phased targets for recyclability to be achieved. From January 1, 2030, only packaging that reaches Grade C or higher in recyclability can be marketed; from January 1, 2038, the entry requirement will be raised to Grade B.

(The European Commission will adopt delegated acts by January 1, 2028, to establish standards for 'recyclable design' and recyclability performance levels.)

Exemption Categories:

• Direct contact packaging for pharmaceuticals and veterinary medicines;
• Packaging for certain medical devices, infant-related foods, and foods for medical uses;
• Packaging used for the transportation of hazardous goods; and
• Sales packaging made from light wood, cork, textiles, rubber, ceramics, porcelain, or wax.

Minimum Recycled Content in Plastic Packaging (Article 7)

Minimum Recycled Content Requirements

From January 1, 2030, any plastic part of packaging placed on the market must contain recycled components from post-consumer recycled (PCR) plastic waste. The regulation categorizes plastic packaging into four types and sets minimum recycled content percentages.

(The European Commission will adopt delegated acts by December 31, 2026, to establish methods for calculating and verifying the proportion of recycled content derived from post-consumer plastic waste.

Exemption Categories: 

• Direct contact packaging for pharmaceuticals;
• Packaging for certain medical devices;
• Packaging for infant and children's food, and food for special medical purposes;
• Packaging for the transportation of hazardous goods; compostable plastic packaging;
• Plastic components that constitute less than 5% of the total packaging weight;
• The addition of recycled content that results in the product not complying with the requirements of (EC) 1935/2004 for food contact plastics.

Bio-based Materials in Plastic Packaging (Article 8)

Bio-based Material Requirements

Before February 12, 2028, the European Commission will review the technical development and environmental performance of bio-based plastic packaging and propose legislative recommendations regarding:

• Sustainability requirements and usage targets for biobased materials in plastic packaging;
• The possibility of substituting post-consumer recycled plastic materials with biobased plastic materials.

Compostable Packaging (Article 9)

Compostability Requirements

Before February 12, 2028, two specific types of packaging may be exempt from the recyclability requirements but must meet industrial composting standards and, if required by Member States, home composting standards:

• Breathable bags for tea, coffee, or other beverages;
• Adhesive labels used for fruits and vegetables.

The European Commission will require the European standards organization to develop or update harmonized standards with detailed technical specifications for compostable packaging by February 12, 2026.

Packaging Minimization (Article 10)

Packaging Minimization Requirements

By January 1, 2030, manufacturers or importers must ensure that the design of packaging placed on the market minimizes weight and volume to the necessary minimum to maintain its functionality, considering the packaging's shape and materials, unless:

• The packaging design is protected under specific legislation for appearance design or international agreement-registered trademarks;
• The packaged product or beverage benefits from a geographical indication protected under EU law.

By February 12, 2027, the European Commission should request the European standards organization to develop or update harmonized standards at its discretion, specifying methods for calculating and measuring packaging minimization requirements. For most common types and formats of packaging, specify maximum appropriate weight and volume limits, and discretionary regulations on wall thickness and maximum void space.

Reusable Packaging (Article 11)

Packaging Reuse Requirements

From February 11, 2025, packaging placed on the market that meets all the following conditions can be considered reusable:

• Designed and marketed for multiple uses.
• Capable of being reused as many times as possible under normal usage conditions.
• Complies with applicable consumer health, safety, and hygiene requirements.
• Can be emptied or unloaded without damaging its further functionality and reusability.
• Can be emptied, unloaded, refilled, or reloaded while maintaining the quality and safety of the packaged product, ensuring compliance with applicable safety and hygiene requirements, including food safety.
• Capable of being reprocessed while maintaining its ability to perform its intended function.
• Allows labeling and provides information about the product characteristics and the packaging itself, including any relevant instructions and information to ensure product safety, proper use, traceability, and shelf life.
• Can be operated without jeopardizing the health and safety of those responsible for emptying, unloading, refilling, or reloading.
• Meets specific requirements for recyclable packaging so that it can be recycled when it becomes waste.

Before February 12, 2027, the European Commission will establish minimum reuse cycles for the most commonly reused packaging through delegated acts.

Packaging Labeling (Article 12)

Labeling Requirements

Before August 12, 2026, the European Commission will establish a unified label and specifications for labeling requirements and formats through delegated acts. Packaging placed on the market must comply with the standards set by the implementing acts and achieve phased implementation according to the timeline shown below.

CIRS Testing Services

With the formal effectuation of the PPWR, the EU's control over packaging is becoming stricter. As an internationally recognized testing, inspection, and certification body, CIRS possesses advanced capabilities in heavy metal and PFAS testing, helping suppliers, manufacturers, and downstream buyers in the packaging industry actively comply with regulatory requirements, strategically plan new packaging designs, and ensure compliance.

If you need any assistance or have any questions, please get in touch with us via test@cirs-group.com.