PPWR 03 - When Should I Take Action?

12 August 2026 Is Not the End. It Is the Beginning

Whenever a new European regulation appears, the first question is almost always:
“When does it apply?”
For PPWR, the short answer is:
12 August 2026.

Regulation (EU) 2025/40 entered into force on 11 February 2025 and generally applies from 12 August 2026. As an EU Regulation, it is directly applicable across Member States rather than requiring national transposition as a directive would.

But for a company, this is only the legal answer. The more important question is:
“When should we start preparing?”
And the answer is very different:
Now.

Why? Because PPWR is not implemented through a single change made on a single day. The Regulation establishes a timetable extending over several years. Some obligations become relevant immediately. Others arrive in 2028. Deposit return systems have an important milestone in 2029. And in 2030, some of the most significant requirements concerning packaging design, recyclability, recycled content, minimisation and reuse converge. PPWR should therefore be viewed as a transformation process, not as a single deadline.


The Timeline Companies Need to Remember

We will not turn this article into a list of dozens of legislative deadlines. For a company, a few major milestones matter most.

2026 – PPWR Becomes an Operational Reality
12 August 2026 is the general date of application. From this point, PPWR becomes the directly applicable European framework for packaging and packaging waste, while transitional provisions keep certain elements of the previous regime in place for defined periods.

For companies, 2026 should be the year when the question:
“What is PPWR?”
becomes:
“Where does PPWR affect us?”

Packaging inventories, internal responsibilities, documentation, suppliers and the markets where products are placed should already be under review.

2028 – The Technical Rules Become Clearer
By 1 January 2028, the Commission is required to adopt the delegated acts establishing the Design for Recycling criteria and the methodology associated with recyclability performance grading.

Harmonised labelling requirements also become increasingly important around this period, although the actual application of certain requirements depends on the adoption of implementing acts.

For industry, 2028 should not be the year when analysis begins. It should be the point at which many companies are checking and adjusting preparations already underway.

2029 – Deposit Return Systems
By 1 January 2029, Member States must, subject to the conditions and exemptions established by PPWR, have deposit return systems for certain single-use beverage containers.

For beverage producers, retailers, recyclers and collection-system operators, this is more than an administrative issue. It affects material flows, the quality of collected material and the availability of recycled feedstock.

2030 – The Major Packaging Milestone
This is where companies need to pay particular attention. 1 January 2030 is one of the most important PPWR milestones.

Several major requirements converge around this date:
• recyclability requirements for packaging;
• minimum recycled-content levels for certain plastic packaging;
• empty-space limits for certain types of packaging;
• stricter packaging-minimisation requirements;
• restrictions on certain single-use packaging formats;
• reuse targets for certain packaging categories.

This is why 2030 must not be treated as a distant deadline. Packaging that needs to change by 2030 will not begin its redesign on 1 January 2030. It will need to be assessed, tested, validated, industrialised and integrated into the supply chain beforehand.


This Is Where the Real Problem Appears

Suppose you manufacture or use packaging. You have:
- a raw-material supplier;
- a converter;
- moulds or equipment;
- product testing;
- customer-approved specifications;
- contracts;
- inventories;
- labelling;
- logistics.

Changing packaging may mean changing an entire chain of processes.

That is why the idea:
“We still have until 2030.”
can become very dangerous.

In reality:
2026–2028 is the period in which preparation for 2030 needs to be built.

The technical research prepared for this article highlights exactly this issue: packaging development cycles mean that waiting for every piece of secondary legislation to be finalised can dramatically reduce the time available for redesign.

Are Some Rules Still Not Final?
Yes.

And this is one of the most important characteristics of PPWR. The Regulation establishes the direction, many of the targets and the main deadlines.

However, certain technical details still need to be defined or supplemented through:
• delegated acts;
• implementing acts;
• harmonised standards;
• technical methodologies.

Areas with such dependencies include detailed Design for Recycling criteria, the methodology for calculating and verifying recycled content, and certain elements of harmonised labelling.

This creates a genuine dilemma for companies:
“How can we prepare if we do not yet know every detail?”
Our answer is:
Do not make irreversible decisions based on rules that are not yet final. But do not wait to begin the analysis. These are two very different things.


How Should a Company Prepare?

PPWR does not have to be implemented in one step.

Step 1 – Understand
Identify which obligations are relevant to your company's activities.

Step 2 – Build an Inventory
What packaging do you use or place on the market?
What materials are used?
How much does it weigh?
What recycled content does it contain?
Where is it marketed?

Step 3 – Talk to Your Suppliers
Do not assume that all the information you will need already exists. Ask about materials, recycled content, recyclability, documentation and anticipated changes.

Step 4 – Assess Your Packaging
Identify packaging that could become problematic under the requirements expected around 2030.

Step 5 – Prepare the Documentation
PPWR compliance will not only mean having correctly designed packaging. Companies will also need to be able to demonstrate compliance.

Step 6 – Implement and Monitor
Make the necessary changes and continue monitoring the European acts that will supplement PPWR. This is, in essence, the practical implementation pathway identified in the technical analysis prepared for this part of the guide.


A Mistake Many Companies Could Make

Confusing uncertainty about some details with uncertainty about the overall direction.
- Not every methodology is final.
- Not every secondary act has been adopted.
- But the overall direction is already very clear.
- Packaging must become more recyclable.
- The use of recycled material will increase.
- Unnecessary packaging must be reduced.
- Reuse will play a greater role.

And demonstrating compliance will become part of normal business operations.

Waiting until the final piece of legislation is published could mean losing the most valuable resource companies currently have: time to prepare.


From Your Company's Perspective

What Should You Understand?
PPWR does not have one single deadline. It is a phased process extending over several years.

What Should You Check?
Do you know exactly:
• what packaging you use;
• what materials it contains;
• who your suppliers are;
• what documentation you already have;
• where the packaging is placed on the market;
• which packaging formats may require changes?

What Should You Do Now?
Start the assessment. This does not mean redesigning every package tomorrow. It means knowing what may need to be redesigned and how long that process could take.


In Brief

• 12 August 2026 is the general date of application of PPWR.
• Implementation does not end in 2026; requirements are introduced progressively.
• 2028 is an important milestone for the development of the technical framework around recyclability and other requirements.
• 2029 brings a major milestone for deposit return systems.
• 2030 is one of the most important operational milestones for industry.
• Some technical details still depend on secondary legislation.
• Companies do not need to wait for every detail to be final before beginning their assessment.
• The most valuable resource companies have today is time. Use it.


Coming Next

We have established when companies should start preparing. Now we can move to what is probably the most practical question in the entire series:

What Do I Need to Change About My Packaging?
In Part IV, we will examine three central PPWR concepts:
Design for Recycling. Recyclability. Packaging reduction.
And, above all, we will address the question every company should be asking:
“Will the packaging I use today still be allowed on the EU market in 2030?”


Sources

• Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste – EUR-Lex
• Regulation (EU) 2025/40 – Official Text
• European Commission – Packaging and Packaging Waste Regulation (PPWR)
• European Commission – Packaging Waste