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PPWR became applicable on 12 August 2026. A week on, the practical picture is clearer than the noise that preceded it. Regulation (EU) 2025/40 entered into force on 11 February 2025 and replaced the packaging directive with a directly applicable instrument, removing much of the divergence between Member States that made multi-market packaging portfolios so awkward to manage. What did not happen on 12 August is the thing most often expected: packaging did not suddenly have to contain recycled content. Those targets start in 2030.
What actually took effect
Two things matter immediately. First, the regime itself: a regulation applies directly, without national transposition, which changes how compliance questions are answered across markets. Second, restrictions on per- and polyfluoroalkyl substances in food-contact packaging took effect on the same date.
The PFAS restriction is the one requiring action now rather than in 2030. It affects barrier coatings and grease-resistant paper above all, but the verification exercise is worth running across the portfolio. A supplier declaration citing a basis is worth having; a declaration citing nothing is not.
The recycled content calendar
Minimum recycled content applies from 1 January 2030, or three years after the relevant implementing acts are enacted, with higher thresholds from 1 January 2040.
| Packaging category | 2030 | 2040 |
|---|---|---|
| Single-use PET beverage bottles | 30% | 65% |
| Other contact-sensitive packaging, primarily PET | 30% | 50% |
| Contact-sensitive packaging, other plastics | 10% | 25% |
Four years to the first threshold sounds comfortable. It is not, seen from the supply side. Annual growth in circular production in Europe fell from 13.6% in 2022 to 1.2% in 2024, and EU recycling capacity contracted by around one million tonnes by the end of 2025. The material that has to fill the 2030 targets must come from plants whose investment decisions are being taken now.
The remaining deadlines
- 12 February 2027 — delegated acts on minimum rotations for reusable packaging.
- 1 January 2028 — deadline for delegated acts setting design-for-recycling criteria.
- 12 February 2028 — implementing acts on the empty space calculation methodology.
- 12 August 2028 — harmonised labelling requirements apply.
- 1 January 2030 — packaging must be designed for recycling.
The sequence reveals the logic of the regulation: framework and substance restrictions first, methodologies and criteria next, hard quantitative thresholds last. A company treating 2030 as the date to start work will be adapting its portfolio when the feedstock market is at its tightest.
What to require from suppliers now
- A declaration of conformity with the PFAS restrictions for food-contact packaging, stating the basis rather than the conclusion alone.
- Recycled content data per article number, even where it is currently zero. Without a baseline there is no path to 30%.
- A recyclability assessment of the construction. RecyClass reported passing 500 such evaluations on 21 July 2026, so a documented body of comparable assessments now exists.
- The origin of the recyclate, including whether it comes from mechanical or chemical recycling. That distinction will matter for verification.
Realistic expectations for the coming months
The first months of a large regulation rarely look like the schedule. Some implementing acts are still missing and enforcement practice has yet to settle. Expect neither an immediate wave of inspections nor business as usual.
The sensible posture for the rest of 2026 is to put data and specifications in order rather than to redesign the portfolio against criteria whose wording is unknown. Design-for-recycling criteria are due in delegated acts by 1 January 2028; rebuilding a pack now on assumptions about their content risks paying for the work twice.
Frequently asked questions
Since when does PPWR apply?
Regulation (EU) 2025/40 entered into force on 11 February 2025 and has applied since 12 August 2026. As a regulation it applies directly in all Member States, without national transposition.
Did packaging have to contain recycled content from 12 August 2026?
No. Minimum recycled content applies from 1 January 2030, or three years after the relevant implementing acts, with higher thresholds from 2040. What did take effect on 12 August 2026 includes restrictions on PFAS in food-contact packaging.
What recycled content will PET bottles require?
Single-use PET beverage bottles face 30% in 2030 and 65% in 2040. Other contact-sensitive packaging made primarily from PET: 30% and 50%. Contact-sensitive packaging from other plastics: 10% and 25%.
Read next
- Food-grade rPET certification: EFSA, FDA, ASTM, ISO
- Post-consumer recyclate (PCR): what it is and how rPET, rHDPE and rPP are produced
- ISCC PLUS and mass balance: how the system actually works
Sources: Regulation (EU) 2025/40 on packaging and packaging waste, together with European Commission guidance and FAQs; Plastics Europe, “The Circular Economy for Plastics 2026”; RecyClass announcement of 21 July 2026.