Understanding European packaging regulations

The regulation was adopted in April 2025.
It provides for a gradual implementation between 2025 and 2030, depending on the specific requirements (recyclability, reuse, recycled content, etc.).

All manufacturers, distributors, and entities placing packaging on the market in the European Union are affected.
This also includes brands that import or export packaged products within the EU.

Not directly. However, all Swiss manufacturers or distributors, as well as those from other countries wishing to market their products in the European Union, will have to comply with the requirements of the PPWR. Switzerland is therefore indirectly affected.

– The recyclability of packaging,
– The integration of recycled materials,
– The reuse of packaging,
– A regulated system of exemptions.

Starting in 2030, all packaging will have to be designed to be recyclable.
This pillar requires that packaging placed on the market be effectively recyclable:
Either through mono-material design (e.g., all PE or all PP),
Or through compatibility with the existing industrial sorting and recycling systems in each country.

Member States must develop or strengthen their collection, sorting, and recycling infrastructures so that packaging can actually be recycled in practice, not just in theory.

In France, there is a tool provided by Citéo called Tree Citeo. Once the information is entered, the tool will indicate the recyclability rate.

Today, in Europe, there is no harmonization regarding the recyclability rate of packaging. The PPWR mentions the creation of a common tool that will be used by all entities placing packaging on the EU market. This tool will ensure consistency of recyclability rates across all countries concerned by the PPWR.

The recycled content pillar aims to incorporate more recycled materials into packaging in order to:
– Limit the use of virgin raw materials,
– Reduce pressure on natural resources,
– And encourage the gradual phase-out of single-use packaging.

The recycled material used must come from post-consumer plastics (i.e., recovered after use by consumers, and not from industrial scraps), preferably from within the European Union.

Strict traceability of materials is required, supported by recognized certifications.
Temporary exemptions may be granted if the supply of recycled material is deemed insufficient.

Mechanical recycling is preferred, as it is a conventional process, low in energy consumption, and widely implemented in Europe. However, the quality can sometimes be limited and problematic for food use, except for PET.

By 2030, non-food plastic packaging must contain 35% PCR recycled material.
Food packaging (sensitive packaging) must contain 10% recycled material, provided it has no impact on food safety. It will be up to the companies placing the products on the market to prove this.

By 2040, non-food plastic packaging must contain 65% PCR recycled material.
Food packaging (sensitive packaging) must contain 50% recycled material, provided it has no impact on food safety. It will be up to the companies placing the products on the market to prove this.

In February 2028, the Commission will reassess the possibility of using bio-based material only if there is not enough recycled material available. This bio-based material will be intended for sensitive contact packaging.

– Packaging for infant food products and medical products for children
– Transport packaging for hazardous products
– Packaging that poses a risk to human health
– All packaging in which the percentage of plastic is below 5%

Starting from January 1, 2030, all transport packaging or sales packaging used for the transport of products, including in the context of e-commerce, must be reusable, with at least 40% of the total of such packaging falling under a reuse system.

The packaging concerned may take the form of pallets, foldable plastic boxes, boxes, trays, crates, large bulk containers, buckets, drums, and jerrycans, regardless of their size and the materials they are made of, including flexible formats or pallet packaging or straps used to stabilize and protect products placed on pallets during transport.

Starting from January 1, 2032, all packaging specifically designated for transport must be 100% reusable, provided that it is not intended for end consumers.

– Transport packaging for hazardous products
– Transport packaging for large machinery, equipment, and goods (specific packaging)
– Flexible formats for the transport of packaging with direct contact with foodstuffs and animal feed
– Packaging for medical or pharmaceutical products

At first glance, bio-compostable packaging is not prohibited under the PPWR, provided that such packaging complies with certain restrictions. In addition to being compostable, it must also be recyclable in order to avoid disrupting the recycling system or degrading the material..

The PPWR requires EU Member States to progressively reduce the volume of packaging placed on the market, using 2018 as the reference year.
By 2030 = a 5% reduction
By 2035 = a 10% reduction
By 2040 = a 15% reduction

On February 12, 2032, the Commission will review the established targets and assess the need to include specific objectives for certain packaging materials. All types of packaging are concerned, including those that are recyclable or reusable.

The regulation prohibits, except in specific cases, packaging containing more than 40% empty space compared to the product.
Manufacturers will have to justify the product-to-packaging ratio through a technical analysis proving that the packaging is sized to the strict minimum necessary.

– For packaging with special protection (fragile, hazardous)
– For products with an irregular shape
– When product grouping is intended to reduce environmental impact

Certain single-use packaging will be prohibited starting January 1, 2030.
– Single-use plastic packaging for grouped products
– Packaging for fresh, unprocessed fruits and vegetables
– Single-use plastic packaging for on-site consumption (fast food, cafeterias, etc.).
– Single-use portions in restaurants
– Single-use packaging designed for accommodations (shampoo bottles, lotion, or sachets for soap bars).
– Very lightweight plastic bags (very thin bags for bulk products), except for plastic bags necessary for hygiene reasons, or when they help prevent food waste. The goal is to replace these single-use solutions with reusable or deposit-return packaging.

As part of the PPWR, the European Union plans to ban packaging containing PFAS, particularly those intended for food contact. Starting from August 12, 2026, it will be prohibited to place packaging containing PFAS on the EU market if they exceed a threshold defined by the regulation.

PFAS (per- and polyfluoroalkyl substances) are synthetic chemical compounds that have been used for many years in industry, particularly for their non-stick, waterproof, and heat-resistant properties. PFAS are “forever chemicals” that persist in the environment and have a harmful impact on humans.

Threshold excluding polymeric PFASs
25 ppb for each PFAS
250 ppb for total PFASs

Threshold with polymeric PFAS
50 ppm per PFAS

The PPWR introduces new labeling requirements aimed at harmonizing information on packaging. These measures are intended to facilitate sorting by consumers, promote reuse, and strengthen environmental transparency.

Providing information on packaging will be essential. The information to be indicated will include: the composition and origin of the material, whether the packaging is compostable or biodegradable, whether it is suitable for home composting, whether it contains recycled or bio-based material, sorting instructions, or how to reuse the packaging if it is not part of a deposit-return system. The EU will need to agree on a harmonized communication for the information that will be mandatory on packaging.

Category A –Excellent recyclability (≥ 95%)
– Transparent PET bottles without coloring, with a detachable label and high-density polyethylene (HDPE) cap.
– Uncoated aluminum cans, such as beverage cans.
– Unlaminated corrugated cardboard packaging, without varnish or metallic inks.

These packaging materials are easily recyclable in current infrastructures and produce high-quality secondary raw materials.

Category B – Good recyclability (≥ 80%)
– Colored PET bottles (for example, green or blue), with a standard adhesive label.
– Polypropylene (PP) pots used for dairy products, with an aluminum seal.
– Cardboard packaging with a thin layer of plastic (for example, for food cartons).

These packaging materials are recyclable, but some components may require specific treatments.

Category C – Average recyclability (≥ 70%)
– Multilayer plastic pouches (for example, PET/PE) used for chips or coffee.
– Plastic-coated cardboard packaging with a polyethylene layer, such as certain juice cartons.
– Expanded polystyrene (EPS) trays used for meat or fish.

These packaging materials present recycling challenges due to their complex composition or the presence of materials that are difficult to separate.

Category D – Low recyclability (< 70%)
– Black plastic packaging (often not detectable by optical sorting systems).
– Metallized pouches used for snacks or coffee.
– Packaging with non-separable components (for example, metal caps on plastic bottles).

These packaging materials are difficult to recycle with current technologies and may disrupt recycling streams.

Category E – Non-recyclable
– PVC packaging or packaging containing substances of concern such as PFAS.
– Complex composite packaging (for example, a mix of plastic, aluminum, and paper) that cannot be separated.
– Packaging containing additives or colorants that disrupt recycling.

These packaging materials are not recyclable in existing infrastructures and are generally destined for incineration or landfill.