PPWR 2026: New EU Requirements for the Packaging Industry

Everything packaging manufacturers and exporters need to know about Regulation (EU) 2025/40 — deadlines, compliance requirements, and business impact.

What Is PPWR?

Regulation (EU) 2025/40, known as PPWR (Packaging and Packaging Waste Regulation), is the European Union's new law governing packaging and packaging waste. It officially replaces the previous Directive 94/62/EC.

The goal of PPWR is to harmonize packaging rules across the EU, reduce packaging waste, promote reuse and recycling, and cut dependence on virgin plastic - all in support of a circular economy.

Unlike the old directive, PPWR is a Regulation, meaning it takes direct legal effect in every EU member state without needing to be transposed into national law. In practice, this means exporters - and especially packaging manufacturers supplying the EU market - must meet the new requirements on the exact timeline set out below.

Scope: Which Packaging Does PPWR Cover?

PPWR applies to virtually all packaging placed on the EU market, including:

• Food-contact packaging
• Primary (sales) packaging - retail packaging sold directly to consumers
• Secondary (grouped) packaging - packaging that bundles multiple products together
• Transport packaging - cartons, pallets, stretch/wrap film

For manufacturers of woven PP bags and other industrial packaging serving agriculture, chemicals, animal feed, fertilizer, and building materials (such as PMP), PPWR will directly affect material selection, structural design, manufacturing processes, and the technical documentation required for each product.

Key Provisions of Regulation (EU) 2025/40 — and Their Business Impact

1. Stricter Limits on Substances of Concern (SoC), Especially PFAS

Effective August 12, 2026, all packaging must comply with new threshold limits on "Substances of Concern" (SoC). Food-contact packaging specifically must not exceed:

• 25 ppb for any single PFAS (Per- and Polyfluoroalkyl Substance)
• 250 ppb for the sum of all PFAS
• 50 ppm for the PFAS group, including polymeric forms

Business impact: Although most woven PP bags do not use PFAS in production, manufacturers still need to control the source of virgin and recycled resin, screen additives, inks, coatings, and surface-treatment chemicals, and work closely with suppliers to obtain full documentation proving raw materials meet the new limits. This ensures the entire packaging structure complies before export to the EU.

2. Mandatory Design for Recycling

By 2030, all packaging placed on the EU market must be designed to be recyclable. The regulation also caps the maximum empty space at 50% for grouped packaging, transport packaging, and e-commerce packaging - a rule that takes effect January 1, 2030 and includes void space filled with cushioning materials such as bubble wrap.

Business impact: This is actually an advantage for woven PP bags, since polypropylene (PP) is a highly recyclable material. Still, manufacturers need to optimize coatings, laminate layers, and accessories to make products easier to recycle after use. For BOPP bags or multi-layer packaging, recyclability must be re-evaluated against the EU's new criteria.

3. Mandatory Recycled Content

By 2030, plastic food-contact packaging must contain a minimum share of recycled plastic:

• 30% for packaging made primarily of PET
• 10% for packaging made of other plastics such as PP or PE (rising to 25% by 2040)

Business impact: This is the costliest compliance category. Packaging producers will need food-grade recycled resin blending lines, a traceable and certified recycled-plastic supply chain, and rigorous quality control to ensure packaging still meets durability and food-safety standards.

4. Labeling and Information Requirements

• By August 12, 2028: all packaging must carry a standardized EU waste-sorting label.
• By January 2030: packaging must display information identifying any Substances of Concern (SoC).

Business impact: Manufacturers will need to update printing systems and label designs to meet EU standards — a particularly important requirement for OEM products carrying a European customer's own brand.

5. Responsibility for the Declaration of Conformity (DoC)

Starting August 12, 2026, legal responsibility for issuing the Declaration of Conformity (DoC) falls on the "manufacturer" - defined as the entity that produces the packaging or owns the brand printed on it. Each packaging type requires only one DoC, but it must be accompanied by technical documentation including product description, drawings, applicable standards, test results, and risk assessment.

For packaging producers such as PMP, this means self-issuing and signing the DoC whenever they design their own packaging (not under a specific customer's brand) and sell directly into the EU market - including unbranded FIBCs sold without a customer-specific order. This document will be essential whenever an EU customer requests proof of compliance.

Conclusion: Key PPWR Deadlines to Plan Around

Regulation (EU) 2025/40 (PPWR) is more than a technical trade barrier for exports to the EU - it's a real test of how well domestic packaging manufacturers can upgrade their technology and governance. The critical milestones to track are:

• August 12, 2026 - SoC limits and Declaration of Conformity (DoC) obligations take effect
• 2028 - Mandatory EU waste-sorting labels
• 2030 - Design-for-recycling requirements and mandatory recycled-content thresholds

This is the decisive window for packaging manufacturers to invest in production upgrades and secure a competitive edge in the EU export market.