EU Packaging and Packaging Waste Regulation (PPWR) FAQ

1. What Is the PPWR?

On January 22, 2025, the European Union officially published the Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40, or PPWR) in the Official Journal of the European Union.

Upgraded from the former Packaging and Packaging Waste Directive (Directive 94/62/EC), the PPWR applies directly throughout the EU as a regulation and establishes uniform, mandatory legislative requirements for packaging placed on the EU market.

It integrates requirements concerning:

• Limits on hazardous substances
• Recycled content
• Recyclability grades (A–E)
• Packaging minimisation

These requirements form a management framework covering the entire packaging life cycle.

For the first time in the packaging sector, it also turns recycled-content targets from voluntary goals into mandatory requirements, with phased targets for different types of plastic packaging.

2. What Is the Scope of the PPWR?

This Regulation applies to all packaging and packaging waste, regardless of the material used or the setting in which the packaging is used.

This includes packaging used in:

• Industry
• Other manufacturing
• Retail or distribution
• Offices
• Services
• Households

3. What Are the Main Provisions of the PPWR?

The PPWR's principal packaging requirements are set out below.

Article 5 — Requirements for Substances in Packaging

Packaging placed on the market must minimise the presence and concentration of substances of concern in the packaging material or any of its components in order to reduce adverse environmental impacts.

For example, the total concentration of the four heavy metals lead, cadmium, mercury, and hexavalent chromium must not exceed 100 mg/kg (0.01%).

Article 6 — Recyclable Packaging

All packaging placed on the market must be recyclable.

Recyclability thresholds will be phased in from January 1, 2030:

• Packaging that does not achieve recyclability grade C (i.e., below 70%) may not be placed on the EU market.
• From January 1, 2038, the threshold will be raised further to grade A or B.

Article 7 — Minimum Recycled Content in Plastic Packaging

From January 1, 2030, plastic packaging placed on the EU market must contain a specified minimum percentage of recycled content recovered from post-consumer recycled (PCR) waste.

The European Commission will establish the detailed calculation and verification rules through delegated acts by December 31, 2026.

Article 8 — Biobased Feedstock in Plastic Packaging — If Applicable

By February 12, 2028, the European Commission must review technological developments and the environmental performance of biobased plastic packaging.

Based on that review, it may submit legislative proposals covering matters such as sustainability requirements and targets for the use of biobased feedstock.

Article 10 — Packaging Minimisation

From January 1, 2030, packaging must be designed so that its weight and volume are reduced to the minimum necessary to ensure its functionality.

The maximum empty-space ratio for e-commerce packaging must be below 50%.

Article 11 — Reusable Packaging — If Applicable

The European Commission will establish, through delegated acts, a minimum number of rotations for commonly used reusable packaging. The specific deadlines will be those stated in the official delegated acts.

This provision applies only to packaging specifically designed for reuse.

Cardboard boxes and ordinary plastic packaging are generally single-use packaging and therefore are usually not covered.

Article 12 — Labelling of Packaging

By August 12, 2026, the European Commission will adopt implementing acts establishing harmonised labels and specifications for labelling requirements and formats.

Packaging placed on the market must comply with the standards set out in those implementing acts.

From August 12, 2028, the EU will require packaging labels to use a harmonised format and include information such as:

• Material composition
• Recycled-plastic or biobased-plastic content
• Reusability

4. What Are the Roles of the Various Economic Operators Under the PPWR?

The main roles under the PPWR are as follows:

• Manufacturer: An entity that manufactures packaging or has packaging designed or manufactured under its own name or trademark.
• Importer: An entity established in the EU that places packaging from a third country on the EU market.
• Producer: An entity that makes packaging available for the first time within the territory of a Member State.
• End user: Any natural or legal person residing or established in the EU to whom a product is supplied, either as a consumer or as a professional end user in the course of their industrial or professional activities, and who does not make the product available on the market again in the form in which it was supplied.

Responsibilities By Role

5. If You Are an Importer or Consumer in the EU, What Responsibilities Do You Have Under the PPWR?

Under the PPWR definition of an end user, whether you are a company or an individual, if you receive a product and do not place it on the market again in the form in which it was imported, you are an end user and generally have no EPR reporting obligation.

The specific circumstances are as follows:

Private Final Consumer

If you are a private final consumer (an individual who does not resell the product), you do not need to register for or report EPR.

Importer or Distributor Importing Goods for Resale

If you are an importer or distributor importing goods for resale, your role is that of a Producer, and you must complete EPR registration and annual reporting for the relevant orders in the Member State.

Importer Using Goods for Its Own Activities

If you are an importer but use the goods you receive in your own industrial or professional activities and do not resell them, you are an end user and generally incur no new EPR obligations.

However, responsibility for EPR at the import stage must still be determined under the rules of the relevant Member State.

JLCMC Compliance Support

In all cases, JLCMC will provide you with a compliant Declaration of Conformity (DoC) and related compliance documents so that you can complete the required compliance checks at the import stage.

6. Do Importers or End Users Also Need to Prepare Packaging-Material Test Reports Themselves?

No. Under the PPWR, responsibility for preparing the technical documentation (Annex VII) and the EU Declaration of Conformity (DoC) rests with the manufacturer.

As an importer or end user, your main obligations are to:

• Verify the compliance documents provided by the manufacturer.
• Where applicable, fulfil your own EPR obligations.

You generally do not need to prepare packaging-material test reports yourself.

If your Member State or downstream customer has additional requirements, you may ask JLCMC to provide further supporting compliance documentation.

7. What Actions Has JLCMC Taken to Comply with the PPWR?

To ensure that the packaging materials used by JLCMC meet the requirements, we have primarily taken the following actions:

1. Collect compliant test reports from packaging-material suppliers, and prepare and retain technical documentation according to the packaging-material list as required.
2. Draw up the EU Declaration of Conformity.
3. Complete EPR registration and annual reporting in the relevant countries.

EU_DOC_Technical_Documentation-2026-8-26

Disclaimer:

This document has been compiled on the basis of the PPWR and the related FAQs published by the European Commission.

It is provided for compliance reference only and does not constitute legal advice.

Certain PPWR details, such as delegated and implementing acts, methods for calculating recycled content, and minimum reuse rotations, are still being developed.

For implementation, please refer to the official EU legislation and consult your customs broker or compliance adviser.