Every PPWR deadline, and the ones that can still move

PPWR enters into force

Regulation (EU) 2025/40 became binding on 11 February 2025, the date the Commission itself confirms. Most obligations trigger on later transitional dates, the main one being general application on 12 August 2026.

Article 44(14) implementing act due

The Commission's own deadline to adopt the implementing act fixing the registration and reporting format, 12 February 2026. It has not been adopted. Article 44(1) gives Member States 18 months from that act's entry into force to establish their national register, so that clock has not started. The Article 44 registration duty itself is part of general application on 12 August 2026.

PPWR general application

From 12 August 2026 the bulk of PPWR applies: substances of concern (Art. 5), manufacturer obligations (Art. 15), Declarations of Conformity (Art. 39), and producer registration / authorised representatives (Art. 44 & 45).

Recyclability obligation applies

From 12 August 2026 all packaging placed on the EU market must be recyclable (Article 6(1)). Three things land later and are often collapsed into this one: the design-for-recycling criteria, the binding A / B / C performance grades from 1 January 2030, and the recycled-at-scale limb from 1 January 2035.

Declarations of Conformity required

From 12 August 2026, every packaging placed on the EU market must ship with an EU Declaration of Conformity drawn up to the Annex VIII model template, asserting compliance with the eleven essential requirements in Annex II Part 1.

Article 12 implementing act due

The Commission had to adopt the implementing act fixing the harmonised pictograms and material codes by 12 August 2026. It has not been adopted and no draft exists, so the harmonised label will not exist on that date and national schemes (Triman/Info-tri, CONAI…) continue to apply. Artwork planning keys off this act: once it lands, every reference has to be re-laid-out.

Article 13(2) implementing act due

By 12 August 2026 the Commission had to adopt the implementing act establishing the harmonised labels for the receptacles that collect packaging waste. It has not been adopted. Those labels must correspond to the packaging labels of Article 12(6), whose act is missing too. Article 13(1) gives Member States until 12 August 2028, or 30 months from the adoption of this act — whichever is later — to affix them, and Article 45(2), point (a), puts their cost on producers' extended producer responsibility contributions.

Annex IV criteria and the perceived-volume ban

Since 12 August 2026, packaging must meet the Annex IV minimisation criteria, and features whose only purpose is to inflate perceived volume — double walls, false bottoms, non-essential layers — are banned. Article 10(2) states no date of its own, so it applies from general application. The reduction to minimum weight and volume, in Article 10(1), is a separate duty starting 1 January 2030.

Reuse rotation act due

By 12 February 2027 the Commission must adopt the delegated act setting the minimum number of rotations per reusable packaging format (Art. 11(2)).

National penalty regimes due

By 12 February 2027 Member States must have laid down the penalties applicable to infringements and notified them to the Commission. PPWR sets no EU-wide ceiling and no percentage-of-turnover formula: amounts are national — Germany, for instance, provides for 10,000–200,000 € from that date.

Design-for-recycling delegated act due

By 1 January 2028 the Commission must adopt the delegated acts establishing the design-for-recycling criteria and the recyclability performance grades of Annex II, how recyclability is assessed and expressed per packaging unit, and the framework for modulating extended producer responsibility fees by grade (Article 6(4)). None is adopted. It is the act the grade floor waits on: that floor applies from 1 January 2030, or 24 months from this act's entry into force, whichever is later.

Recycled-content derogations reviewed

Before 1 January 2028 the Commission reviews the derogations from the recycled-content requirements set out in Article 7(5), under Article 7(12).

Compostable packaging obligations

From 12 February 2028 the packaging formats designated in Article 9 — tea and coffee bags, sticky fruit labels, and single-serve coffee capsules where a Member State requires it — must be industrially compostable.

Article 24(2) implementing act due

By 12 February 2028 the Commission must adopt the implementing act setting the method for measuring the empty-space ratio. It is the date the operator duty keys off: Article 24(1) applies from 1 January 2030, or three years after that act enters into force, whichever is later — so any slippage here moves the 2030 date with it.

Harmonised labelling obligations

From 12 August 2028, or 24 months after the Article 12(6) implementing acts enter into force — whichever is later — packaging must carry harmonised material-composition and disposal pictograms. No annex carries those pictograms. Where another EU act mandates a digital product passport for the packaged product, the same data carrier must convey both sets of information; PPWR itself creates no such passport.

or 24 months after the Article 12(6) implementing act enters into force — whichever is later — Act not adopted (2026-08-15)

Deposit Return Systems operational

By 1 January 2029 every Member State must operate a Deposit Return System achieving at least 90% separate collection of single-use plastic and metal beverage containers up to 3 L (Art. 50). A Member State already above 80% over calendar year 2026 may request an exemption, due by 1 January 2028. Existing systems have until 2035 to align with Annex X.

Reusable packaging label

From 12 February 2029, or 30 months after the Article 12(6) implementing act enters into force — whichever is later — reusable packaging must carry the label identifying it as reusable (Article 12(2)). The same act governs the harmonised labelling due six months earlier under Article 12(1); it has not been adopted.

or 30 months after the Article 12(6) implementing act enters into force — whichever is later — Act not adopted (2026-08-15)

Recyclability performance grades bind

From 1 January 2030 the A / B / C recyclability performance grades become binding for the packaging categories listed in Annex II, and packaging below the grade C floor may no longer be placed on the EU market. Article 6 defines only grades A, B and C. Annex II Table 3 sets the thresholds: grade A from 95%, grade B from 80%, grade C from 70%, and below 70% the unit counts as technically non-recyclable. What is still missing is the Article 6(4) delegated act fixing the design-for-recycling criteria and the weighting behind that percentage.

or 24 months after the Article 6(4) delegated act enters into force — whichever is later — Act not adopted (2026-08-15)

Recycled content targets (plastic) apply

From 1 January 2030, or three years after the Article 7(8) implementing act enters into force — whichever is later — the minimum post-consumer recycled content set out in Article 7(1) applies to plastic packaging: 10% for contact-sensitive packaging other than PET, 30% for single-use plastic beverage bottles, 35% for other plastic packaging. Compliance is measured as an average per manufacturing plant and per year.

or 36 months after the Article 7(8) implementing act enters into force — whichever is later — Act not adopted (2026-08-15)

Reuse targets and refill obligations apply

From 1 January 2030, Article 29 reuse targets bind: 40% for transport packaging within the EU, 10% for alcoholic and non-alcoholic beverage sales packaging, 10% for HORECA. Refill stations should occupy ≈10% of the sales area in stores larger than 400 m² (Art. 30).

Annex V packaging-format bans

From 1 January 2030, the packaging formats listed in Annex V cannot be placed on the EU market — including SUP grouped/multi-pack outers, SUP packaging for unprocessed fruit or vegetables under 1.5 kg, SUP HORECA single-serve disposables and SUP single-serve hotel toiletries (Art. 25).

Empty-space ratio applies

From 1 January 2030, or 36 months after the Article 24(2) implementing act enters into force — whichever is later — grouped, transport and e-commerce packaging must keep empty space at or below 50% of its volume. The ratio does not apply to sales packaging, which stays under the Article 10 minimisation duty.

or 36 months after the Article 24(2) implementing act enters into force — whichever is later — Act not adopted (2026-08-15)

Packaging minimisation applies

From 1 January 2030 every packaging unit must be reduced to the minimum weight, volume and number of layers compatible with functionality and safety (Article 10). Until then the Commission guidance keeps EN 13428:2004 as the designated yardstick for sales packaging.

Article 6(5) implementing act due

By 1 January 2030 the Commission must adopt the implementing acts establishing the methodology for the recycled-at-scale assessment, category by category, and the thresholds that go with it. It is the act the 2035 limb waits on: packaging must also be recycled at scale from 1 January 2035, or five years after this act enters into force, whichever is later.

First per-capita waste-prevention milestone

By 31 December 2030 each Member State must reduce per-capita packaging waste by 5% compared with the 2018 baseline (Art. 43).

Recycled at scale

From 1 January 2035 packaging must also be recycled at scale — at least 55% at EU level for its Annex II category, 30% for wood — or five years after the relevant implementing acts enter into force, whichever is later.

or 60 months after the Article 6(5) implementing act enters into force — whichever is later — Act not adopted (2026-08-15)

Second per-capita waste-prevention milestone

By 31 December 2035 each Member State must reduce per-capita packaging waste by 10% compared with the 2018 baseline (Art. 43).

Grade B floor applies

From 1 January 2038, packaging must be at least grade B to be placed on the EU market — grade C no longer suffices. This is enacting text, not guidance: Article 6(3) states it, and the 2038 column of Annex II Table 3 marks grade C as no longer placeable on the market.

Second recycled-content threshold

Article 7(2) sets a second wave of recycled-content requirements for 2040. The figures are not confirmed on a primary source — the only published indication is “up to 65% for single-use plastic bottles”, a ceiling rather than a floor. Do not plan against a number.

or 36 months after the Article 7(8) implementing act enters into force — whichever is later — Act not adopted (2026-08-15)

Increased reuse targets

From 1 January 2040, the second wave of reuse targets in Article 29 binds, with higher percentages for transport, alcoholic and non-alcoholic beverage packaging.

Final per-capita waste-prevention milestone

By 31 December 2040 each Member State must reduce per-capita packaging waste by 15% compared with the 2018 baseline (Art. 43).