Packaging legislation
From 12 August 2026, you must carry out a conformity assessment for every piece of packaging and, if the outcome is positive, draw up a declaration of conformity in which you, as the manufacturer, declare that the packaging complies with the new European packaging legislation: the PPWR ((EU) 2025/40 – Packaging and Packaging Waste Regulation). This EU law applies directly to everyone in the European Union, and national legislation is not necessarily required.
The PPWR prescribes a number of sustainability requirements for every type of packaging, with which manufacturers must demonstrably comply. Manufacturers must assess their packaging against these obligations and document the results. Once all requirements are met, a declaration of conformity can be signed. Current sustainability requirements cover the limitation of harmful substances, recyclability, compostability, minimization, and reusability. By 2030 at the latest, these will be supplemented by requirements regarding biological origin and the use of post-consumer recyclate in plastics. The obligations concerning recyclability and packaging minimization applicable up to 2030 are identical to those that were already in force prior to 12 August 2026: the so-called Essential Requirements.
The Essential Requirements mandate that the environmental impact of packaging be kept to a minimum. This must be documented in a packaging dossier, which also includes substantiation regarding material recovery. Many companies are currently focusing on future PPWR requirements, but it is important not to overlook the fact that you must already be able to demonstrate compliance with the Essential Requirements today. This evidence must be included in the packaging dossier.
In early 2028, the European Commission will publish the definitive European Design for Recycling guidelines for packaging. Based on these, you will determine the extent to which packaging is recyclable under the PPWR by assigning it a score of A, B, C, or D. From 2030 onwards, this score will determine whether the packaging may be placed on the market within the European Union. Until the PPWR classification comes into effect, packaging placed on the EU market must comply with essential packaging requirements. Recyclability is part of these requirements.
Recycle Checks and essential requirements
A Recycle Check is based on the knowledge available at the time of its creation. Insights, market conditions, recycling technologies, and regulations are constantly changing. Therefore, do not use an older Recycle Check to assess a package's recyclability in 2027 or to demonstrate compliance with essential requirements. Recycle Checks from previous years remain available for the sake of transparency.
You can, however, use the No Regrets Playbook. Read more about this playbook here.
You can find more information about the PPWR on this webpage. We keep this information up to date throughout the year.