Regulation (EU) 2025/40, known as the PPWR – Packaging and Packaging Waste Regulation, introduces a new European regulatory framework for packaging and packaging waste. It replaces Directive 94/62/EC and will be directly applicable in all Member States.
All packaging placed on the EU market
It applies to all packaging placed on the EU market, regardless of the material: paper, plastic, glass, metal, multi-material packaging and other formats.
Full packaging life cycle
The new rules cover design, minimisation, recyclability, reuse, refill, recycled content, labelling and waste management.
PPWR key dates and compliance timeline
The PPWR introduces a gradual implementation pathway, with obligations and targets phased in over time. However, some operational aspects are still being defined, including delegated acts, assessment methodologies and technical implementation guidance.
August 12, 2026
General application of the Regulation; PFAS ban for food-contact packaging; Declaration of Conformity requirement for each packaging type.
August 12, 2028
EU harmonised labelling: national labelling requirements, including those under former Article 219 of Legislative Decree 152/2006, will no longer apply.
January 1, 2030
All packaging designed for recycling; first reuse targets; bans on certain single-use packaging.
2035
Packaging must be effectively recyclable at scale.
2040
Strengthened reuse targets, including 40% for beverages, and recycled content targets, up to 65% for PET.
An evolving implementation framework
The PPWR introduces new requirements affecting packaging design, materials, communication and end-of-life management.
Minimisation
Packaging will need to be designed to minimise unnecessary weight, volume and empty space.
Restricted substances
The Regulation introduces limits and restrictions for certain substances, including PFAS in food-contact packaging and heavy metals.
Recyclability
Packaging must meet design-for-recycling criteria and later be recyclable at scale.
Recycled content
Minimum recycled content targets will apply to certain categories, particularly plastic packaging.
Reuse and refill
The PPWR introduces targets and conditions to support reuse and refill systems and reduce single-use packaging.
EU harmonised labelling
The Regulation introduces an EU-wide labelling system.
Manufacturer: the brand owner becomes responsible for packaging
One of the most significant changes concerns the role of the manufacturer. Under the PPWR, this is not only the entity that physically produces the packaging. It may also be the entity that has packaging, or a packaged product, designed or manufactured and places it on the EU market under its own name or trademark.
This means that the brand owner can no longer consider packaging to be the sole responsibility of the supplier. Even when the packaging is produced by third parties, the company marketing the product under its own brand must be able to demonstrate packaging compliance.
The manufacturer and the EPR producer may coincide, but they are not automatically the same entity. For private-label products, responsibility may also involve retailers as manufacturers. Suppliers will therefore need to be ready to collect and provide technical packaging data.
Manufacturer
It is responsible for packaging compliance and must be able to demonstrate it in the event of an inspection.
Producer EPR
It is the entity linked to registration, contribution and reporting obligations in the countries where the product is sold.
PPWR EU Declaration of Conformity and technical documentation
The PPWR requires the manufacturer to draw up an EU Declaration of Conformity for each packaging type and to keep the supporting technical documentation.
PPWR Declaration of Conformity (DoC)
It certifies that the packaging complies with the applicable requirements of the Regulation.
Technical documentation
It gathers supporting evidence on materials, substances, design, recyclability and recycled content, where applicable.
Documentation management and compliance checks
The documentation must be kept up to date and made available upon request by the competent authorities.
DoC FCM and DoC PPWR
The FCM Declaration of Compliance does not replace the PPWR EU Declaration of Conformity: they are separate documents and must coexist where both are applicable.
PPWR non-compliance risks
The Italian penalty framework specific to the PPWR is still being defined. However, by analogy with Legislative Decree 21/2005 on general product safety and Legislative Decree 194/2023 on market surveillance, possible consequences may include financial penalties, restrictive measures, withdrawal or recall of non-compliant packaging and, in the most serious cases, criminal liability.
It provides an overview of European regulatory developments in the packaging sector: from the transposition of Directive (EU) 2024/825 in Italy to the PPWR.
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