PPWR — Regulation (EU) 2025/40 on packaging and packaging waste
Regulation (EU) 2025/40, of 19 Dec 2024, on packaging and packaging waste. It harmonises recyclability, recycled content, labelling and EPR; it repeals Directive 94/62/EC. It applies to textile packaging.
Context
The PPWR (Packaging and Packaging Waste Regulation) is the new binding, directly applicable rule that replaces Directive 94/62/EC of 1994 and harmonises EU-wide the requirements on packaging and packaging waste. For the textile sector it directly affects individual garment-protection poly bags, hangtags and labels, e-commerce boxes and packaging, retail store packaging and service bags.
Regulatory identification
Regulation (EU) 2025/40 of the European Parliament and of the Council, of 19 December 2024, published in the OJEU Series L 2025/40 on 22 January 2025. Canonical ELI `http://data.europa.eu/eli/reg/2025/40/oj`. It amends Regulation (EU) 2019/1020 (market surveillance) and Directive (EU) 2019/904 (single-use plastics). It fully repeals Directive 94/62/EC. Legal basis Art. 114 TFEU (internal market).
Scope and free movement (Art. 4)
«Only packaging that complies with the provisions of this Regulation shall be placed on the market. Member States shall not prohibit, restrict or impede the placing on the market of packaging that complies with the sustainability, labelling and information requirements laid down in Articles 5 to 12 or pursuant to those Articles.»
Essential requirements (Chapters II and III)
Requirements for substances present in packaging. The sum of lead, cadmium, mercury and hexavalent chromium shall not exceed 100 mg/kg (Art. 5.4). PFAS restriction in food-contact packaging applicable from 12 August 2026 (Art. 5.5).
Recyclable packaging. By 1 January 2030 all packaging placed on the market must be designed for recycling and graded by recyclability performance class A, B or C (Annex II table 3). By 1 January 2038, minimum class B.
Minimum recycled content in plastic packaging. By 1 January 2030: 30 per cent food-contact PET, 10 per cent non-PET contact, 30 per cent SUP bottles, 35 per cent for the rest. By 1 January 2040 the thresholds rise (50/25/65/65 per cent).
Packaging minimisation. Design that reduces volume and weight to the minimum necessary; prohibition of packaging with double walls, false bottoms and unnecessary layers intended solely to increase the perceived volume.
Reusable packaging from 11 February 2025. Cumulative design, health, hygiene and traceability requirements for multiple rotations.
EU-wide harmonised labelling with easy-to-understand pictograms. From 12 August 2028 (or 24 months after the implementing acts) a harmonised label on material composition to facilitate consumer sorting.
Articulation with ESPR
Recital 9 specifies the articulation with Regulation (EU) 2024/1781 ESPR: «this Regulation complements Regulation (EU) 2024/1781 [...], under which packaging is not presented as a specific product category. Nevertheless, it should be recalled that the delegated acts adopted on the basis of Regulation (EU) 2024/1781 may set additional or more detailed requirements on packaging for specific products». The ESPR textile delegated act may set additional or more detailed textile packaging requirements that add to the PPWR baseline.
Timeline
Adoption
Adopted by the European Parliament and the Council.
OJEU publication
OJEU Series L 2025/40.
Entry into force
Twenty days after publication.
General application
General application deadline + food-contact PFAS restriction.
Harmonised labelling (Art. 12)
Material composition label mandatory.
Recyclability and recycled content
Design for recycling class A/B/C + minimum recycled content percentages for plastic.
Recyclability class B
Only class A or B packaging may be marketed.
Higher recycled content
50/25/65/65 per cent plastic recycled content.
Applied case
A textile brand that markets garments in the EU market via physical store + e-commerce packs each garment in an individual polyethylene poly bag and ships it to the customer in an e-commerce cardboard box. The PPWR applies in a phased manner.
Packaging inventory (12 Aug 2026 · Art. 4 + Annex I). Map the scope: primary packaging (garment poly bag, hangtag), secondary packaging (multipack boxes in store), tertiary packaging (e-commerce boxes, pallets). Each category is subject to specific requirements.
Substances of concern (12 Aug 2026 · Art. 5). Verify with the packaging supplier that the sum of lead, cadmium, mercury and hexavalent chromium does not exceed 100 mg/kg in any of the packaging. If the brand packs textile cosmetics or food accessories subject to contact, verify the PFAS restriction applicable from 12 Aug 2026.
Minimisation design (1 Jan 2030 · Art. 10). Redesign e-commerce boxes to reduce volume and weight to the minimum necessary without affecting protection. Express prohibition of double walls, false bottoms and unnecessary layers intended solely to increase the perceived volume.
Recyclability (1 Jan 2030 · Art. 6). Poly bags and e-commerce boxes must be designed for recycling and graded by recyclability performance class A, B or C under Annex II table 3. By 1 Jan 2038, minimum class B.
Recycled content (1 Jan 2030 · Art. 7). Food-contact polyethylene poly bags must contain a minimum of 10 per cent post-consumer recycled content. Non-contact poly bags, a minimum of 35 per cent. Calculated as an average per manufacturing plant and year.
Harmonised labelling (12 Aug 2028 · Art. 12). Each packaging must carry a harmonised label with pictograms on material composition to facilitate consumer sorting. For e-commerce, labelling does not apply to transport packaging or packaging subject to deposit-return systems.
Common mistakes
The PPWR does NOT replace textile EPR: they are complementary regimes over different waste flows.
The PPWR regulates packaging and packaging waste (poly bag, hangtag, e-commerce box). Textile EPR regulates textile waste itself (garments and footwear at the end of their useful life). A European textile brand is subject to BOTH regimes in parallel: it pays packaging EPR for the packaging it places on the market and pays textile EPR for the garments it places on the market.
Not all textile packaging is fully subject: there is a limited exemption for textiles in sales packaging.
Recital 34 exempts «sales packaging made of lightweight wood, cork, textile, rubber, ceramics or porcelain» from the minimum plastic recycled content percentages of Art. 6.10. This does NOT exempt textile packaging from the other requirements (sustainability, labelling, EPR, minimisation). Each category accounts for less than 1 per cent of the weight of packaging placed on the Union market according to the recital itself.
The harmonised label in Art. 12 is NOT merely informative: it is based on binding EU-wide pictograms.
From 12 August 2028, packaging will carry a harmonised label containing information on material composition based on easy-to-understand pictograms, including for persons with disabilities. Harmonisation prevents Member States from imposing additional national labels that conflict. It is binding labelling with a penalty regime, not voluntary information.
Reusable packaging is not exempt from the PPWR: it has its own reinforced regime (Art. 11).
From 11 February 2025, packaging placed on the market as reusable must meet cumulative requirements on design (conceived for multiple rotations), health-hygiene-food safety (where applicable), traceability (Art. 11.1.g instructions for use, tracking and useful life) and reconditioning (Art. 11.1.f under Annex VI part B). A textile brand that opts for reusable bags must document compliance in the technical documentation of Annex VII.
E-commerce is NOT exempt from the PPWR: it has reinforced rules.
The Parliament Resolution of 10 Feb 2021 cited in recital 8 expressly called for «packaging reduction measures and targets, also in e-commerce» and
«improving recyclability and minimising packaging complexity»
. Art. 12.1 second paragraph specifies that for e-commerce packaging the harmonised labelling obligation «does not apply to transport packaging or to packaging subject to deposit, return and take-back systems», but the other requirements (recyclability, recycled content, minimisation, EPR) apply fully.
Frequently asked questions
What is the PPWR?
Regulation (EU) 2025/40 on packaging and packaging waste, of 19 December 2024, published in the OJEU Series L 2025/40 on 22 January 2025. It is a binding, directly applicable EU-wide rule that harmonises requirements on sustainability, recyclability, recycled content, labelling and extended producer responsibility for all packaging in the Union. It replaces Directive 94/62/EC.
When does the PPWR enter into force and from when does it apply?
It entered into force twenty days after its publication on 22 Jan 2025. General application starts on 12 August 2026. There are phased specific obligations: food-contact PFAS restriction (12 Aug 2026), harmonised labelling (12 Aug 2028), mandatory recyclability and plastic recycled content (1 Jan 2030), recyclability class B (1 Jan 2038), higher recycled content percentages (1 Jan 2040).
Which textile packaging does the PPWR apply to?
It applies to all packaging placed on the Union market regardless of the material (recital 10). For the textile sector it directly affects individual garment poly bags, hangtags and labels, e-commerce boxes and packaging, retail store packaging and service bags. There is no general textile sectoral exclusion. The only limited exemption is for sales packaging made of lightweight wood, cork, textile, rubber, ceramics or porcelain in relation to the minimum recycled content percentages (recital 34).
How much recycled content must a poly bag have in 2030?
Under Art. 7.1: 30 per cent if it is food-contact PET, 10 per cent if it is non-PET contact, 35 per cent if it is non-contact (the typical case of the textile poly bag). Calculated as an average per manufacturing plant and year. By 1 Jan 2040, the percentages rise to 50/25/65 per cent respectively (Art. 7.2).
How does the PPWR articulate with textile EPR?
They are complementary regimes over different waste flows. The PPWR regulates packaging and packaging waste (poly bag, hangtag, e-commerce box). Textile EPR regulates textile waste itself (garments and footwear at the end of their useful life). A textile brand is subject to both regimes in parallel: it pays packaging EPR for the packaging it places on the market and pays textile EPR for the garments it places on the market.
How does the PPWR articulate with the ESPR?
Recital 9 PPWR makes it explicit: «this Regulation complements Regulation (EU) 2024/1781 [ESPR] [...] under which packaging is not presented as a specific product category. Nevertheless, it should be recalled that the delegated acts adopted on the basis of Regulation (EU) 2024/1781 may set additional or more detailed requirements on packaging for specific products». The ESPR textile delegated act may set textile-specific packaging requirements that add to the PPWR baseline.
Does the PPWR require a Digital Product Passport for packaging?
The PPWR does not establish a specific or binding packaging DPP as of the date of adoption. It does introduce harmonised labelling with pictograms and standardised digital data carriers (Art. 12.1 fourth paragraph: «packaging placed on the market that contains substances of concern shall be marked through digital, standardised and open technologies»). Integration with a horizontal DPP or a textile DPP will depend on future ESPR delegated acts and on the development of the horizontal digitalisation framework COM(2025) 504.
Fuentes oficiales
- European Parliament and Council · OJEU Series L 2025/40 of 22.1.202519 dic 2024Binding directly applicable Regulation
- European Parliament and Council · OJEU20 dic 1994Standard repealed by PPWR
- European Parliament and Council · OJEU5 jun 2019Amended standard in force
- European Parliament and Council · OJEU20 jun 2019Amended standard in force
- European Parliament and Council · OJEU OJ L of 28.6.202413 jun 2024Complementary articulated standard
