---
title: "PPWR Explained: EU Packaging Regulation Timeline | Ekoroll"
description: "PPWR (EU) 2025/40 has applied since 12 August 2026: what applies now, what follows from 2027 to 2040, who is responsible and what packaging buyers should do."
url: https://ekoroll.com/en/blog/ppwr-explained
lang: en
---

[Regulation](https://ekoroll.com/en/blog)15 min read

# PPWR Explained: What the EU Packaging Regulation Changes, and When

PPWR (EU) 2025/40 has applied since 12 August 2026: what applies now, what follows from 2027 to 2040, who is responsible and what packaging buyers should do.

Part of the guide: [EU Packaging Regulations for Horeca Businesses (2026 Guide)](https://ekoroll.com/en/blog/eu-packaging-regulations-horeca-2026-guide)

 [Mahdi Sadough](https://ekoroll.com/en/about)Founder & CEO, Ekoroll Reviewed 25 October 2026

![Café counter in morning light with a white and a kraft paper cup with bagasse lids, a bagasse clamshell and a kraft takeaway box, a reusable cup and a customer's glass jar behind them, and a checklist on a clipboard](https://ekoroll.com/media/blog/ppwr-explained.webp)

Key takeaways

-   The PPWR, Regulation (EU) 2025/40, is a directly applicable EU regulation that replaced the Packaging Directive and has applied since 12 August 2026; its obligations arrive in stages up to 2040.
-   Since 12 August 2026, food-contact packaging must stay below the PFAS limits, all packaging below the heavy-metal limit, and every packaging type needs an EU declaration of conformity backed by technical documentation.
-   The next dates for food service are 12 February 2027 (customers' own containers for takeaway), 12 February 2028 (a reusable takeaway option) and 1 January 2030 (the Annex V bans on certain single-use plastic formats and, unless the implementing rules come later, recyclability grades and plastic recycled content).
-   Under the PPWR the manufacturer carries the legal responsibility for compliance, and an importer or distributor that sells packaging under its own name or brand takes on the manufacturer's obligations, which matters for private label.
-   The PPWR does not ban paper cups as such, but from 2030 single-use packaging for dine-in is restricted if it is plastic or paper-based with more than 5% plastic by mass, such as PE-lined cups; compostability is not required for cups and containers.

The PPWR, Regulation (EU) 2025/40, is the EU’s single rulebook for packaging. It has applied since 12 August 2026, replaces the Packaging Directive and applies directly in every member state to all packaging placed on the EU market, wherever it was made. For food packaging buyers, three things already apply: PFAS limits for food-contact packaging, heavy-metal limits, and an EU declaration of conformity for every packaging type. The rest arrives in stages: customers’ own containers in 2027, a reusable takeaway option in 2028, and recyclability, recycled content and format bans in 2030.

This guide sets out the whole PPWR timeline from a food service point of view, who is legally responsible for what, what the regulation means for paper, bagasse and plastic packaging, which parts are still moving in Brussels, and an action plan by type of business. For the detail of the PFAS limits and how they are tested, see our guide to [PPWR-compliant, PFAS-free food packaging](https://ekoroll.com/en/blog/ppwr-compliant-pfas-free-packaging).

## What is the PPWR?

The Packaging and Packaging Waste Regulation is EU law that sets requirements for the design, composition, labeling and end of life of packaging, and obligations for the companies that make, import and sell it. It was published as Regulation (EU) 2025/40, entered into force on 11 February 2025 and has applied since **12 August 2026**.

Three features make it different from the rules it replaced:

-   **It is a regulation, not a directive.** The old Packaging Directive 94/62/EC had to be transposed into national law, and every country did it differently. The PPWR applies as written in all 27 member states, so a cup or container that complies in Germany complies in Italy and Poland too.
-   **It regulates the product, not only the waste.** Packaging is treated like other regulated products: it needs a conformity assessment, technical documentation and a declaration of conformity before it is placed on the market.
-   **It is phased.** Many obligations apply from fixed dates between 2027 and 2040, and several depend on delegated or implementing acts that the Commission is still adopting.

National systems do not disappear. Extended producer responsibility (EPR), deposit return systems and national laws such as Germany’s VerpackG continue, but they now operate inside the PPWR framework.

## The PPWR timeline: what applies when

The dates below are the ones that matter for food service packaging. Where the regulation says “or a set period after the relevant delegated or implementing act, whichever is later”, the date can move; this is noted in the table.

| Date | What applies | Who acts | What it means for food service |
| --- | --- | --- | --- |
| 11 Feb 2025 | Regulation enters into force | Commission | Preparation phase |
| **12 Aug 2026** | General application: PFAS limits for food-contact packaging (Art. 5), heavy-metal limit, conformity assessment, technical documentation and EU declaration of conformity, packaging and manufacturer identification; national EPR registration continues | Manufacturers, importers, distributors, producers | **Applies now.** Each packaging type needs documentation and PFAS evidence |
| 12 Feb 2027 | Customers’ own containers for takeaway drinks and ready-prepared food, at no higher cost than single-use (Art. 32); clearly visible customer information | HORECA final distributors | Counter process, hygiene rules and staff instructions |
| 12 Feb 2028 | Reusable takeaway option within a re-use system (Art. 33); tea, coffee and other beverage bags, soft single-serve units and sticky fruit labels must be industrially compostable (Art. 9) | HORECA final distributors (micro-enterprises exempt from Art. 33) | A reuse system next to single-use takeaway packaging |
| 12 Aug 2028 | Harmonized sorting label on packaging (Art. 12), or 24 months after the implementing act, whichever is later | Manufacturers | Artwork and print changes for printed packaging |
| 1 Jan 2029 | Deposit return systems for single-use plastic bottles and metal beverage containers up to 3 liters (Art. 50; exemptions apply) | Member states | Beverage sales: deposit rules for bottles and cans |
| 12 Feb 2029 | Label for reusable packaging, or 30 months after its implementing act | Manufacturers | Marking of reusable cups and containers |
| **1 Jan 2030** | Recyclable packaging within grades A to C (Art. 6); recycled content in plastic parts (Art. 7); packaging minimization (Art. 10) and a 50% maximum empty space in grouped, transport and e-commerce packaging (Art. 24); Annex V bans (Art. 25); reuse targets (Art. 29); aim to offer 10% of takeaway products in reusable packaging (Art. 33). Grades, recycled content and empty space apply later if their implementing rules come late | Manufacturers, fillers, final distributors | Hard-to-recycle formats and single-use plastic for dine-in are on their way out |
| 1 Jan 2035 | Packaging must also be recycled at scale (Art. 6), or five years after the implementing acts | Manufacturers | Recyclable in practice, not only in theory |
| 1 Jan 2038 | Only grades A and B remain allowed (Art. 6) | Manufacturers | Higher recyclability bar |
| 1 Jan 2040 | Higher recycled content and reuse targets | Manufacturers, final distributors | Second stage of the targets |

Two points are often misread. First, there is **no transition period** for new deliveries: packaging placed on the market from 12 August 2026 must comply when it is placed. Second, the Commission guidance confirms that **packaging placed on the market before 12 August 2026 may remain on the market** and does not have to be withdrawn.

## What applies since 12 August 2026

### PFAS limits for food-contact packaging

Packaging intended to come into contact with food must not contain PFAS at or above **25 ppb for any targeted PFAS**, **250 ppb for the sum of targeted PFAS** and **50 ppm for total PFAS including polymeric PFAS**. The limits apply to the concentration in the packaging itself, not to migration into the food, and there is no exception for recycled material. If total fluorine is above 50 mg/kg, the operator must be able to show how much of it is PFAS. The Commission guidance recommends a stepwise test approach that starts with total fluorine. Our [PFAS guide](https://ekoroll.com/en/blog/ppwr-compliant-pfas-free-packaging) explains the limits and the tests in detail.

### Heavy metals

The combined concentration of lead, cadmium, mercury and hexavalent chromium in packaging or its components must not exceed **100 mg/kg**. This limit existed under the old directive and now sits in the regulation. Our article on [heavy metals in food packaging](https://ekoroll.com/en/blog/heavy-metals-food-packaging-testing) explains the difference between content and migration testing.

### Conformity assessment and the declaration of conformity

Before packaging is placed on the market, the manufacturer must carry out a conformity assessment, draw up technical documentation and issue an **EU declaration of conformity**. In practice, this is one dossier per packaging type that shows how the packaging meets the substance, recyclability, minimization and labeling requirements that apply at that time. For recyclability, the conformity assessment is only required once the design-for-recycling delegated acts are in force; until then, packaging must meet the essential requirements of the old Packaging Directive and the related harmonized standards (EN 13427 to EN 13432). The technical documentation and the declaration must be kept for 5 years for single-use packaging and 10 years for reusable packaging, and handed to an authority within 10 days of a request.

This declaration is separate from **food-contact compliance** under Regulation (EC) No 1935/2004. Plastic layers need a written declaration of compliance under Regulation (EU) No 10/2011; for paper and board, documentation follows national rules and industry guidance. A cup or container sold for food needs both sets of documents.

### Identification and EPR

Packaging must carry information that identifies its type or batch and its manufacturer, and an importer adds its own contact details. Producers remain registered in the national extended producer responsibility (EPR) schemes of every member state where they make packaging available and pay into them; the harmonized PPWR producer registers follow as member states set them up in 2027 and 2028.

## Who is responsible: manufacturer, importer, distributor

The PPWR assigns obligations by role, so the first question for any buyer is which role they hold for each packaging item.

| Role | Who it is | Main obligations |
| --- | --- | --- |
| Manufacturer | The company that makes packaging, or has it designed or made, and places it on the market under its own name or trademark | Conformity assessment, technical documentation, declaration of conformity, marking; sole legal responsibility for the packaging’s compliance |
| Importer | A company established in the EU that places packaging from a non-EU country on the market | Checks that the manufacturer has done its part, adds its own contact details, keeps the declaration available |
| Distributor | Any company in the supply chain that makes packaging available after it is placed on the market | Checks that the packaging is marked and documented before selling it on |
| Producer (EPR) | The company that first makes packaging available in a member state | Registration and fees in each national EPR scheme |
| Final distributor | The business that hands packaged products to the end user, for example a café or a takeaway | Takeaway obligations (own containers, reuse offer), Annex V restrictions on site |

The rule that matters most for private label is this: **an importer or distributor that places packaging on the market under its own name or trademark takes on the obligations of the manufacturer.** A coffee chain that orders cups printed with its own brand, or a distributor selling a house brand of containers, therefore needs the full technical documentation from the factory, not only a commercial invoice. One exception protects small brands: when a micro-enterprise (fewer than 10 staff and an annual turnover of EUR 2 million or less) orders packaging under its own brand from a supplier located in the EU, the supplier is treated as the manufacturer.

## What the PPWR means for paper, bagasse and plastic

|  | Paper and board cups, bowls, boxes | Bagasse and molded fiber | Single-use plastic |
| --- | --- | --- | --- |
| PFAS limits (now) | Apply to coatings and grease barriers; ask for a test report per format | Apply; fluorinated grease-proofing was common in fiber products, so test evidence is essential | Apply where in food contact |
| Recyclability (2030) | Depends on the barrier and its share; design-for-recycling criteria are still to be adopted | Depends on the recycling criteria to be adopted for fiber | Depends on polymer, colors and design |
| Recycled content (2030) | Only for plastic parts; parts below 5% of the unit’s weight are exempt | Not applicable to fiber | 10% to 35% in plastic parts, by type |
| Annex V (2030) | Out of scope when plastic is an insignificant part and no more than 5% of the total mass | Out of scope when no plastic layer is used | Single-use plastic for dine-in and for portion packs on site is restricted |
| Compostability | Not required by the PPWR for these formats | Not required by the PPWR for these formats | Not applicable |

Three conclusions follow from the table:

-   **Paper is not banned, but the barrier is now the specification.** PFAS-free barriers are mandatory for food contact, and the plastic share decides whether a paper item counts as composite packaging for the Annex V restrictions and how it will be graded for recyclability. For dine-in from 2030, this is the difference between a PE-lined cup and a cup whose barrier is only a small share of its mass. A water-based coating can also be a polymer, so ask for the barrier type and its share of the total mass in writing, not only the coating name. Our comparison of [water-based and PE coatings](https://ekoroll.com/en/blog/water-based-coating-paper-cups-vs-pe) explains the difference.
-   **Compostable is not a compliance route.** The PPWR makes compostability mandatory only for a short list of items, such as tea and coffee bags, soft single-serve units and sticky labels on fruit, which must be industrially compostable. For cups, bowls and containers, the requirement is recyclability, and other packaging, including biodegradable plastic, must be designed for material recycling. A real compostability certificate remains a valid product property, but it does not replace PPWR documentation. See [compostable vs biodegradable packaging](https://ekoroll.com/en/blog/compostable-vs-biodegradable-packaging) for how those claims are defined.
-   **The Single-Use Plastics Directive still applies.** The PPWR does not replace it. Bans on plastic cutlery, plates, straws and EPS containers continue, and plastic cups and lids remain subject to national reduction measures and the cup marking. Our [EU plastic ban guide](https://ekoroll.com/en/blog/eu-plastic-ban-explained) covers those rules.

## What changes for cafés, restaurants and takeaway

The PPWR is the first EU law that sets obligations directly at the counter.

-   **From 12 February 2027: own containers.** HORECA businesses that sell takeaway drinks or ready-prepared food must let customers have them filled in their own container, at no higher cost and under no less favorable conditions than single-use packaging, and inform customers with clearly visible signs. This applies to micro-enterprises too.
-   **From 12 February 2028: a reusable option.** The same businesses must offer takeaway in reusable packaging within a re-use system, on terms no less favorable than single-use, and strive to offer 10% of these products in reusable packaging from 2030; member states may set higher targets. Micro-enterprises are exempt from this offer.
-   **From 1 January 2030: no single-use plastic for dine-in.** Annex V restricts single-use plastic packaging for food and drinks filled and consumed on HORECA premises, and single-use plastic portion packs for sauces, sugar, creamer and condiments served on site. Takeaway sales are outside these two entries, establishments without access to drinking water are exempt, and member states may allow derogations for micro-enterprises.

Germany has required a reusable alternative since 2023 under its Packaging Act (VerpackG) for takeaway food in single-use plastic containers and for drinks in single-use cups, with the smallest businesses allowed to fill customers’ own containers instead; other countries have similar national rules. The PPWR brings a common floor to all member states.

## What is still moving

The PPWR is in force, but several parts are still being written or adjusted:

-   **Delegated and implementing acts.** The design-for-recycling criteria and recyclability grades are due by 1 January 2028, and the harmonized labels depend on implementing acts. Until they exist, nobody can claim a final recyclability grade for a format.
-   **Commission guidance.** The Commission published its guidance document on the regulation in June 2026 (Notice C/2026/3084), and dedicated Annex V guidelines with examples are due by 12 February 2027. It explains, among other things, the PFAS test approach, the definitions of manufacturer and importer, the treatment of stock and the scope of Annex V. Guidance is not law, but national authorities follow it.
-   **Simplification.** On 10 December 2025 the Commission proposed, in the Omnibus VIII simplification package, to suspend the obligation for EU-established producers to appoint an authorized representative for EPR in other member states. On 21 October 2026 the Council agreed its negotiating position: producers may be exempted where they make less than 1 tonne of packaging per year available in that member state, with a safeguard for producers in breach of their EPR obligations and a review by the end of 2030. Negotiations with the European Parliament follow.
-   **Targeted exemptions.** In February 2026 the Commission adopted a delegated decision exempting certain operators from the reuse requirements for pallet wrapping and straps.

None of these changes affects the obligations that already apply: PFAS, heavy metals and the declaration of conformity.

## Five common misreadings

1.  **“The PPWR bans paper cups.”** Not as such. From 2030 it restricts single-use plastic for dine-in, including paper-based packaging with more than 5% plastic, and it sets recyclability requirements for all packaging.
2.  **“Compostable packaging is PPWR-compliant.”** Compostability is required only for a few items. Every other format must be recyclable by design from 2030, and all food-contact packaging must meet the PFAS limits now.
3.  **“The PPWR replaces national EPR.”** It does not. Producers still register and pay in each member state.
4.  **“Non-EU suppliers are not affected.”** The regulation applies to the packaging, wherever it was made. If the factory cannot document a format, its EU customer cannot place it on the market.
5.  **“Old stock must be thrown away.”** Packaging placed on the market before 12 August 2026 may remain on the market.

## PPWR action plan by type of business

### Café or restaurant

-   Ask your suppliers for the PFAS test reports and declarations for every food-contact item you buy.
-   Prepare a procedure for customers’ own containers before 12 February 2027: what you accept, how you check hygiene, how staff fill it.
-   List the single-use plastic items you use for dine-in and plan their replacement before 2030.

### Coffee chain or multi-site operator

-   Map every branded item: under your own trademark, you carry the manufacturer’s obligations.
-   Build a central file of declarations of conformity, test reports and technical documentation per item.
-   Pilot a reuse system before the 2028 obligation, so it works at scale when it becomes mandatory.

### Distributor or wholesaler

-   Check your role per item: importer for non-EU goods, manufacturer for house brands.
-   Make documentation a condition in supplier contracts: declaration of conformity, PFAS and heavy-metal reports, composition and food-contact declarations.
-   Register under EPR in every member state where you are the producer.

### Buyer sourcing from outside the EU

-   Ask the factory for the PPWR dossier per packaging type before the first order, not after shipment.
-   Confirm who marks the packaging and where the importer’s details go.
-   Agree in the contract which party updates the documentation when delegated acts change the requirements.

## A supplier checklist for PPWR documentation

For each packaging type, ask for:

-   **EU declaration of conformity** under the PPWR, with a reference to the technical documentation.
-   **PFAS test report** from an accredited laboratory against the PPWR limits, for the actual material and barrier.
-   **Heavy-metal test report** for lead, cadmium, mercury and hexavalent chromium.
-   **Food-contact documentation** under Regulation (EC) No 1935/2004, including a declaration of compliance under Regulation (EU) No 10/2011 for any plastic layer.
-   **Material composition** in writing, including the barrier type and its share of the total mass.
-   **Marking details:** type or batch identification and manufacturer details on the packaging or its documentation.
-   **Recyclability information** that is available today, while the official grading is still being defined.

For the wider sourcing process, see [how to choose a food packaging supplier](https://ekoroll.com/en/blog/how-to-choose-food-packaging-supplier), and for all the rules that apply to food service in one place, our [EU packaging regulations guide for horeca](https://ekoroll.com/en/blog/eu-packaging-regulations-horeca-2026-guide).

## PPWR documentation from Ekoroll

Ekoroll supplies [paper cups](https://ekoroll.com/en/products/eco-packaging/disposable-paper-cups), [kraft paper bowls](https://ekoroll.com/en/products/eco-packaging/kraft-paper-bowls-with-lids), [bagasse food containers](https://ekoroll.com/en/products/eco-packaging/bagasse-food-containers) and other food packaging manufacturer-direct to buyers in Europe. Our paper packaging uses a water-based, PFAS-free, PE-free barrier. The water-based coated paperboard passed PPWR (EU) 2025/40 tests for PFAS, total fluorine and heavy metals (lead, cadmium, mercury, hexavalent chromium); the SGS and Eurofins reports are available on request. Declarations and food-contact documentation are provided according to the final product specification and production route.

Send us your product list and target market, and we will match formats, send samples and share the documentation for each item. [Request a quote](https://ekoroll.com/en/contact) or browse the [catalog](https://ekoroll.com/en/catalogue).

_This article explains the regulation for buyers and is not legal advice. Check the current text of Regulation (EU) 2025/40 and national guidance for your market._

## Products in this article

-    [**Disposable Paper Cups**View product](https://ekoroll.com/en/products/eco-packaging/disposable-paper-cups)
-    [**Bagasse Food Containers**View product](https://ekoroll.com/en/products/eco-packaging/bagasse-food-containers)
-    [**Paper Bowls & Lids**View product](https://ekoroll.com/en/products/eco-packaging/kraft-paper-bowls-with-lids)

## Sources

1.  [Regulation (EU) 2025/40 on packaging and packaging waste (PPWR)](https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng) — EUR-Lex
2.  [Commission Notice C/2026/3084, Guidance document for Regulation (EU) 2025/40 on packaging and packaging waste (C(2026) 3702)](https://ec.europa.eu/transparency/documents-register/api/files/C\(2026\)3702_0/090166e52e8ff764) — European Commission, 2026-06-05
3.  [Packaging and packaging waste, legislative procedure summary](https://oeil.europarl.europa.eu/oeil/en/document-summary?id=1802233) — European Parliament, Legislative Observatory
4.  [Simplification: Council agrees negotiating stance to cut red tape for small packaging producers](https://www.consilium.europa.eu/en/press/press-releases/2026/10/21/simplification-council-agrees-negotiating-stance-to-cut-red-tape-for-small-packaging-producers/pdf/) — Council of the European Union, 2026-10-21
5.  [Commission Delegated Decision C(2026) 511 on exemptions from the reuse requirements for pallet wrapping and straps (Council document 6986/26)](https://data.consilium.europa.eu/doc/document/ST-6986-2026-INIT/en/pdf) — Council of the European Union, 2026-03-04
6.  [Directive (EU) 2019/904 on the reduction of the impact of certain plastic products on the environment (SUP Directive)](https://eur-lex.europa.eu/eli/dir/2019/904/oj/eng) — EUR-Lex

## Frequently asked questions

### ### What is the PPWR?

The PPWR is the EU Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40. It entered into force on 11 February 2025, has applied since 12 August 2026 and replaces the Packaging Directive 94/62/EC. Because it is a regulation, it applies directly in every EU member state, covers all packaging placed on the EU market wherever it was made, and phases in its requirements between 2026 and 2040.

### ### What applies under the PPWR right now?

Since 12 August 2026: the PFAS limits for food-contact packaging (25 ppb for any targeted PFAS, 250 ppb for their sum and 50 ppm for total PFAS including polymeric PFAS), the limit of 100 mg/kg for lead, cadmium, mercury and hexavalent chromium combined, an EU declaration of conformity with technical documentation for each packaging type and identification of the packaging and its manufacturer. Producers also remain registered in the national EPR schemes of each member state where they make packaging available.

### ### Does the PPWR ban paper cups?

Not as such. From 1 January 2030, Annex V restricts single-use plastic packaging for food and drinks filled and consumed on HORECA premises. According to the Commission guidance this includes composite packaging, such as paper-based packaging with more than 5% plastic, which covers many PE-lined cups. Under the regulation's definitions, a material that is an insignificant part and no more than 5% of the total mass does not make packaging composite. Takeaway use is outside this entry, and plastic cups remain subject to the Single-Use Plastics Directive.

### ### When do takeaway businesses have to accept customers' own containers?

From 12 February 2027, final distributors in the HORECA sector that sell takeaway drinks or ready-prepared food must offer customers the option to have them filled in their own container, at no higher cost and under no less favorable conditions than single-use packaging. From 12 February 2028 they must also offer a reusable packaging option within a re-use system and strive to offer 10% of these products for sale in reusable packaging from 2030; micro-enterprises are exempt from the reusable offer, but not from accepting own containers.

### ### Does the PPWR apply to suppliers outside the EU?

Yes. The PPWR applies to packaging placed on the EU market, whoever made it. The EU importer must check that a non-EU manufacturer has carried out the conformity assessment, drawn up the technical documentation and marked the packaging, and must add its own contact details. In practice a supplier in Türkiye or Asia has to deliver the declaration of conformity, the test reports and the documentation for each packaging type, or its EU customer cannot place the packaging on the market.

### ### Do I have to withdraw packaging stock bought before 12 August 2026?

No. The Commission guidance states that packaging placed on the market before 12 August 2026 may remain on the market and does not need to be withdrawn. There is no transition period for packaging placed on the market from that date: each new delivery must meet the requirements that apply at that moment.

![Mahdi Sadough](https://ekoroll.com/images/mahdi-sadough.webp)

Mahdi Sadough Founder & CEO, Ekoroll

Mahdi Sadough is the founder and CEO of Ekoroll. He brings a background in branding, packaging development and product innovation to practical fiber-based packaging systems for foodservice.

[LinkedIn](https://www.linkedin.com/in/sadough/) [About Ekoroll](https://ekoroll.com/en/about)

ekoroll.com/en/blog/ppwr-explained · sales@ekoroll.com · © 2026 Ekoroll

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Source: https://ekoroll.com/en/blog/ppwr-explained. Ekoroll — sales@ekoroll.com. Quotes and samples on request: https://ekoroll.com/en/contact