The 5 Key Points to Understand the Packaging and Packaging Waste Regulation (PPWR)

The Packaging and Packaging Waste Regulation (PPWR) is a major European Union regulation that establishes harmonised rules for packaging placed on the EU market, with the objective of reducing environmental impact, improving recyclability, and accelerating the transition toward a circular economy. Proposed by the European Commission, it replaces the previous directive framework with directly applicable rules across all Member States, making compliance uniform and legally binding.

The PPWR is closely linked to the concept of the Digital Product Passport (DPP), as it explicitly anticipates the use of digital data carriers and structured product information systems to support traceability, compliance, and environmental transparency across the packaging lifecycle.

Building on its experience as an end-to-end supply chain transparency solution, Tilkal offers its analysis of the five key points to understand PPWR and to implement the actions that truly matter for compliance.

Contents: 1. What products are covered by the PPWR? 2. PPWR & Digital Product Passport (DPP) 3. Who is responsible for data and compliance? 4. What happens starting August 2026? 5. What are the thresholds for 2026 and beyond? 6. How can Tilkal help you? + FAQ

The Packaging and Packaging Waste Regulation (PPWR) is the EU’s new legal framework governing all packaging placed on the European market, regardless of material or sector. It aims to reduce packaging waste, increase recyclability, and harmonise rules across Member States.

In practice, it applies to all companies placing packaged goods on the EU market, including manufacturers, brands, and importers. It covers all packaging materials, introduces extended producer responsibility requirements, and progressively strengthens obligations around data reporting, recyclability performance, and substance restrictions.

The first operational phase begins around 2026, while the most detailed technical requirements will be progressively introduced between 2028 and 2035.

1. What products are covered by the PPWR?

One of the defining characteristics of the PPWR is its material-neutral and system-wide scope. It applies to all packaging placed on the EU market, regardless of whether it is made of plastic, wood, paper, cardboard, glass, metals, or composite materials. This includes both reusable and single-use packaging, as well as consumer, industrial, and transport packaging.

This broad coverage reflects the scale of the packaging challenge in Europe. According to Eurostat, the European Union generated more than 80 million tonnes of packaging waste in 2023, equivalent to nearly 178 kilograms per person. This figure illustrates why the regulation adopts a holistic approach rather than targeting individual materials in isolation.

Importantly, while all materials are included, the PPWR does not regulate packaging based on material preference. Instead, it focuses on performance criteria such as recyclability, reuse potential, and environmental impact. This means that plastic packaging is not excluded or singled out, but it is subject to additional scrutiny in certain areas due to its environmental footprint.

The result is a regulatory framework that treats packaging as a system rather than a material category, shifting the focus from “what packaging is made of” to “how packaging performs across its lifecycle.”

2. PPWR & Digital Product Passport (DPP)

The Digital Product Passport (DPP) concept plays an increasingly important role in the PPWR framework, even though it is not established as a standalone obligation within the regulation itself. Instead, the PPWR positions digital traceability as a core enabler of compliance and explicitly aligns with existing and future EU digital product policy frameworks.

The regulation clearly states that where EU law already requires a Digital Product Passport, that same passport should be used to provide relevant information under the PPWR. In particular, it specifies:

“where the packaged product is covered by Regulation (EU) 2024/1781 or other Union law requiring a digital product passport, that digital product passport should also be used for providing the relevant information under this Regulation.”

This creates a direct bridge between the PPWR and the broader DPP ecosystem, especially the framework established under the Ecodesign for Sustainable Products Regulation (ESPR). Rather than duplicating systems, the PPWR encourages integration, ensuring that packaging-related compliance data can be embedded into a unified digital product identity.

In practice, this means that packaging information—such as material composition, recyclability attributes, or regulatory compliance data—may increasingly be linked through digital data carriers such as QR codes or standardized identifiers. These systems are expected to be defined in detail through implementing acts, which will establish harmonised requirements for digital labelling and structured data exchange across the EU market.

Ultimately, the PPWR does not create a separate Digital Product Passport system for packaging. Instead, it anticipates interoperability with existing DPP frameworks, reinforcing the EU’s broader strategy of building a connected digital infrastructure for product sustainability information.

3. Who is responsible for data and compliance?

The PPWR establishes a clear but distributed model of responsibility across the packaging value chain. While multiple actors contribute to compliance, legal accountability ultimately rests with the entity that places the packaging on the European market.

Responsibility for data generation is primarily located upstream in the supply chain. Packaging manufacturers and material suppliers are expected to provide accurate and detailed technical information regarding composition, recyclability characteristics, and chemical substances. This information must be sufficiently robust to support downstream compliance obligations and must be maintained in a traceable and auditable format.

However, the responsibility for regulatory compliance lies with the economic operator placing the packaging on the EU market. This is typically the brand owner, the importer, or in some cases the manufacturer itself when selling directly. This entity must ensure that all packaging complies with PPWR requirements and that appropriate documentation is available in case of regulatory inspection.

This structure creates what can be described as a “distributed data, centralized liability” model. In practice, compliance depends heavily on the quality and availability of data provided by upstream suppliers, even though legal responsibility is concentrated at the level of the market operator.

The OECD has repeatedly highlighted that fragmented supply chain data is one of the main barriers to circular economy implementation, particularly in complex global value chains such as packaging.

As a result, many companies are already investing in digital traceability systems and data-sharing infrastructures to ensure that compliance can be demonstrated reliably. This shift is not only regulatory but also operational, as packaging data becomes a critical asset for market access in the EU.

4. What happens starting August 2026?

The date of 12 August 2026 marks the beginning of the first operational phase of the PPWR. However, it is important to understand that this does not correspond to the full application of all technical requirements. Instead, it represents the start of a transition phase in which companies must begin aligning their systems, data, and governance structures with the future framework.

At this stage, the focus is primarily on data, governance, and responsibility mechanisms rather than strict performance thresholds. Companies will be expected to significantly improve the way they collect, structure, and share packaging-related information across their supply chains. This includes data on material composition, volumes placed on the market, and the presence of substances of concern.

Extended Producer Responsibility (EPR) systems will also be reinforced and progressively harmonised across the European Union. This means that companies placing packaging on the market will increasingly be required to finance the collection and treatment of packaging waste, with financial contributions that reflect environmental performance.

According to the European Environment Agency, packaging waste recycling rates in the EU have improved over the last decade but remain uneven across Member States, with significant variation depending on material streams. This reinforces the need for harmonised reporting and accountability mechanisms.

Another important dimension of this phase is the preparation for future recyclability requirements. While no binding recyclability thresholds are fully enforced in 2026, companies are expected to prepare for the future introduction of harmonised performance classes and assessment methodologies.

Finally, the PPWR introduces stronger expectations around transparency for substances of concern. While detailed thresholds will be introduced later, companies are already expected to improve visibility into chemical composition across their packaging portfolio.

In essence, 2026 is not about full compliance with final rules, but about building the foundations of a compliant system.

5. What are the thresholds for 2026 and beyond?

A common misunderstanding about the PPWR is that strict numerical thresholds will apply immediately upon entry into force. In reality, 2026 represents a preparatory phase rather than a fully enforced performance regime.

At this stage, there are no general mandatory thresholds for recycled content or recyclability that apply across all packaging categories. Instead, the regulatory framework sets out a progressive trajectory toward binding targets that will be implemented in later phases, particularly from 2030 onwards.

• For recycled content, the most significant obligations concern plastic packaging, especially beverage bottles, where future targets are expected to reach significant levels by 2030. However, these requirements are not yet universally applicable in 2026 and remain part of the upcoming implementation phases defined by the European regulatory roadmap.
  

• Similarly, recyclability requirements are not yet enforced through mandatory performance classes in 2026. Instead, companies are expected to prepare for the introduction of harmonised recyclability assessment systems that will later determine whether packaging can be placed on the market without restrictions.
  

• Regarding substances of concern, there are no new harmonised quantitative thresholds introduced in 2026. However, regulatory pressure is increasing significantly, particularly for food-contact materials and substances such as PFAS. The European Chemicals Agency has identified thousands of substances under evaluation for restriction, reflecting the growing focus on chemical safety in packaging.
  

The overall picture is therefore one of gradual tightening. While 2026 does not introduce final performance obligations, it marks the beginning of a structured transition toward full circularity requirements by 2030 and beyond.

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• Recycled content (PCR) — NO binding percentages yet in 2026

The binding targets are later, mainly 2030 onward (first mandatory PCR thresholds for plastic packaging) and further increases toward 2040.

What applies in 2026:

• You must collect and declare recycled content data

• You must ensure traceability of material composition

• You must be able to prove future compliance readiness

• Recyclability — NO fixed % threshold yet enforced in 2026

The PPWR introduces a recyclability grading system (A–E), but, in 2026, the grading system is not yet fully enforced via binding design thresholds. Packaging must already be designed with recyclability in mind, assessed and documented, aligned with existing best practice methodologies.

Later milestones:

• 2028 → detailed recyclability criteria are defined via delegated acts

• 2030 → low-performing packaging (grades D/E) banned

• 2038 → only A–B allowed on the market

• Substances (hazardous materials / PFAS) — YES, this is the only area with real numeric limits in 2026

PFAS limits DO apply:

• 25 ppb → individual PFAS limit

• 50 ppb → total non-polymeric PFAS

• 50 ppm → total PFAS (including polymeric PFAS)

Heavy metals (lead, cadmium, mercury, chromium VI) remain limited at 100 mg/kg total concentration (existing EU framework reinforced).

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Conclusion

The Packaging and Packaging Waste Regulation represents a structural transformation of packaging governance in the European Union. It establishes a unified, material-neutral framework focused on performance, data transparency, and circularity.

While 2026 marks the beginning of operational implementation, the regulation will only reach full technical maturity in the following decade. Companies must therefore focus not only on compliance, but on building the data and traceability foundations required for long-term alignment.

How can Tilkal help you?

In a regulatory environment where compliance increasingly depends on data quality and traceability, companies need reliable systems to manage packaging information across complex, multi-tier supply chains.

Tilkal provides an end-to-end Supply Chain Data Hub that enables companies to collect, structure, and verify packaging data from upstream suppliers through to final market placement. By ensuring data integrity and interoperability, Tilkal helps organisations build a trusted foundation for regulatory compliance.

This becomes particularly critical under the PPWR, where obligations related to recyclability, substance transparency, and reporting require consistent and auditable data flows. Tilkal supports companies in transforming fragmented supply chain information into a unified and reliable compliance asset, while also preparing them for future requirements such as Digital Product Passport integration.

In short, Tilkal helps turn regulatory complexity into operational control.

FAQ

What products are covered by the PPWR?

The PPWR applies to all packaging placed on the EU market, regardless of material or use. This includes consumer, industrial, transport, reusable, and single-use packaging across all sectors.

Is the PPWR only about plastic packaging?

No. The regulation is material-neutral and applies equally to plastic, wood, glass, metal, paper, and composite packaging, although plastics are subject to additional specific requirements.

Will there be delegated acts under the PPWR?

Yes. The European Commission is empowered to adopt delegated acts that will define key technical aspects such as recyclability criteria, labeling formats, and data requirements.

What changes in August 2026 under the PPWR?

From this date, companies must strengthen data reporting, comply with enhanced EPR requirements, and improve transparency regarding packaging composition and substances.

Who is responsible for compliance under the PPWR?

The entity placing packaging on the EU market—typically the brand owner or importer—is legally responsible for ensuring compliance with the PPWR.

How can Tilkal help you for PPWR compliance?

Tilkal enables organisations to collect, structure, and verify packaging data across multi-tier supply chains, ensuring that information is reliable, auditable, and ready for regulatory use. This is particularly critical under the PPWR, where compliance depends on consistent data flows from raw material suppliers through to market operators.