PPWR: what Regulation 2025/40 means for Polish companies from 12 August 2026

Key takeaways

• PPWR is Regulation (EU) 2025/40 – it applies directly in every EU country and replaces Directive 94/62/EC.
• The key date is 12 August 2026 – from that day most provisions apply (the regulation was published on 22 January 2025 and entered into force on 11 February 2025).
• PPWR covers the whole chain, not just packaging manufacturers – the definition of an “economic operator” (Article 3) also covers distributors, shops, online sellers and fulfilment/3PL operators. With the definition come the re-use obligations of Article 29.
• The hardest requirements mean physically changing the packaging: 40% reusable transport packaging from 2030 (Article 29), a maximum of 50% empty space (Article 24), minimum recycled content in plastic packaging (Article 7), and PFAS restrictions in food-contact packaging from 12 August 2026 (Article 5).

• What to do now: take stock of your own packaging and assess your readiness – we set out an orderly plan for the first 90 days at the end.

   

What is PPWR – and how does it differ from “just another directive”

PPWR governs the entire life-cycle of packaging: from design and material, through the way goods are packed, to re-use and recycling. The biggest difference from the previous legal position, however, concerns the form of the act. Directive 94/62/EC, in force since 1994, set targets, and each Member State implemented them through its own national law – hence the differences between markets that built up over the years. A regulation works differently: it applies directly and uniformly across the whole Union, without a national act as intermediary and with far less room for local interpretation.

For a company, this shifts the burden. Until now, “packaging and the law” was a matter for the legal department, dealt with once a year: reports, fees, records. PPWR moves part of these requirements to where decisions are made about what we actually carry and ship goods in – to operations, logistics and procurement.

When does PPWR apply: a timeline with dates from the source

The most common question is “when does PPWR apply”. The answer is not a single date but a sequence of thresholds:

• 22 January 2025 – publication of Regulation (EU) 2025/40 in the Official Journal of the EU.
• 11 February 2025 – the regulation enters into force.
• 10 June 2026 – the Commission’s interpretative guidelines on the substantive provisions of PPWR appear in the Official Journal of the EU (Commission Notice C(2026) 3702 of 5 June 2026, published as OJ C/2026/3084) – they cover, among other things, the re-use targets of Article 29.
• 12 August 2026 – general application of most provisions begins. On the same day Directive 94/62/EC is repealed and, among other things, the PFAS restrictions for food-contact packaging start to apply (Article 5).
• by 12 February 2028 – deadline for the European Commission’s implementing acts, including the methodology for calculating empty space (Article 24) and harmonised packaging labelling.
• 1 January 2030 – the hard thresholds arrive: 40% reusable transport packaging (Article 29), a maximum of 50% empty space (Article 24), minimum recycled content in plastic packaging (Article 7), the packaging recyclability requirement (Article 6) and the first packaging-waste reduction target – 5% per capita against 2018 (Article 43). For the recycled-content and empty-space thresholds there is a conditional date: 1 January 2030 or three years after the Commission’s implementing acts enter into force – whichever is later.
• 2035–2040 – further thresholds: waste reduction of 10% (2035) and 15% (2040), tighter recyclability requirements, and higher re-use and recycled-content targets (including working towards 70% re-use of transport packaging from 2040).

Although the “start date” is 12 August 2026, the most serious operational consequences are triggered by 1 January 2030. Just under four years is less than it sounds when what is at stake is rebuilding a packaging fleet and renegotiating logistics contracts.

Who does PPWR apply to – and why “this doesn’t apply to us” is the costliest sentence

In the Polish debate about PPWR, most attention goes to packaging manufacturers and to fees. The least goes to the link the rules will hit hardest in operational terms: distribution and logistics.

The obligations concerning the re-use of transport packaging do not stop with the manufacturer. Article 29 directs them at “economic operators”, a term the regulation defines broadly (Article 3(1)(12)): alongside manufacturers and importers it covers, among others, distributors, authorised representatives, final distributors and fulfilment service providers. Nor does the term serve a single article: the economic operator is the addressee of practically the entire regulation, from packaging design requirements through to labelling and reporting. What counts is whether you use transport packaging in trade within the Union – including pallets, collapsible plastic crates, boxes, trays, crates, IBC containers, as well as pallet wraps and straps.

Two situations are treated more strictly by the regulation than the 40% threshold. The first is transport between a company’s own sites and to linked or partner enterprises (Article 29(2)). The second is delivering products to another economic operator within the same Member State (Article 29(3)). In both, the packaging must be suitable for re-use within a re-use system – which is not the same thing as a closed loop. A re-use system can operate as a closed or an open loop; both models are defined in Annex VI, and Article 29 imposes neither. What does matter is who takes the delivery: paragraph 3 refers to an economic operator within the meaning of Article 3(1)(12), so a shipment to a professional end user – a company that buys goods for its own use and does not make them available further on the market (Article 3(1)(23)) – does not fall under that paragraph.

Take a simple example. A company manufactures no packaging and produces no goods – it buys products, picks orders and ships them in cardboard boxes and on pallets. In everyday terms, “there’s no factory, so PPWR doesn’t apply to us”. Within the meaning of the regulation, however, it is an economic operator using transport packaging – and it counts towards the re-use targets of Article 29. The later it notices this, the less time remains to change load carriers and renegotiate contracts with hauliers.

The regulation therefore also lands on the desks of the board and the operations department of a mid-sized trading, e-commerce or 3PL company – one hearing the acronym “PPWR” for the first time and assuming it is a suppliers’ problem. It is not.

What PPWR actually changes – from the packaging side, not the paperwork

The scale of the change is easiest to see in what physically happens to the packaging.

Re-use of transport packaging (Article 29). From 1 January 2030, at least 40% of transport packaging is to operate in a re-use system, and from 2040 economic operators are to work towards 70%. The rules are stricter for transport between a company’s own sites and to linked enterprises (Article 29(2)), and for delivering products to another economic operator in the same Member State (Article 29(3)): there, the packaging must be suitable for re-use within a re-use system. The system itself may run as a closed or an open loop – Annex VI describes both variants – and a delivery to a professional end user who does not make the goods available further on the market does not fall under paragraph 3. In practice this means moving away from “single-trip” carriers towards containers and crates circulating in a loop.

Empty space (Article 24). The maximum empty-space ratio in grouped, transport and e-commerce packaging will be 50%. That is the end of the large cardboard box half-filled with air and void fill. The Commission is to set the calculation methodology in an implementing act (by 12 February 2028), and packaging operating in a re-use system is exempt from this obligation.

Recycled content in plastic packaging (Article 7). Plastic packaging will have to contain a minimum share of post-consumer recycled material. From 2030 the thresholds include, among others, 30% for contact-sensitive packaging made mainly of PET, 10% for other contact-sensitive packaging, and 35% for other plastic packaging. Only post-consumer recycled material counts towards these targets; pre-consumer production waste does not.

PFAS in food contact (Article 5). From 12 August 2026, PPWR restricts the PFAS content of all packaging intended to come into contact with food: packaging in which PFAS reach or exceed the set thresholds may not be placed on the market; below those thresholds, the packaging remains permitted.

Recyclability and waste reduction (Article 6 and Article 43). All packaging is to be recyclable from 2030, and the amount of packaging waste per capita is to fall – by 5% (2030), 10% (2035) and 15% (2040) against the 2018 level. Formally this is a target imposed on Member States – but it will be delivered through the decisions companies make.

The re-use share, the empty-space limit and the recycled-content threshold cannot be met “on paper”. What has to change is what physically travels between the warehouse, the shop and the customer. That is why we talk about replacing packaging infrastructure.

The context of scale matters here too. Reusable packaging is a different calculation from single-use: a container of this class withstands up to 120 re-use cycles and 7–12 years of service (per Reusable Packaging Europe, factsheet 2022). Across the whole Union, the European Commission’s impact assessment puts the effect of PPWR at around €47.2 billion in savings by 2030 against costs in the region of €5.9 billion, around 18 million tonnes less waste and around 23 million tonnes less CO₂ emissions. These are, however, estimates at the scale of the whole EU, not a promise to any single company: at company level the calculation is directional – reusable packaging starts to be cheaper only from a certain point, which depends on volume, the number of cycles, distance and the return rate, not on a universal constant. The regulation itself was not conceived as cost for cost’s sake, but the burden of the first move falls on companies – and it falls now.

Why we look at PPWR as a manufacturer, not a lawyer

A lawyer will answer the question “what does the provision say”. We – as a manufacturer of reusable packaging, our business since 1985 – answer four different ones: which container exactly, how many cycles it will withstand, from roughly which year it starts to be cheaper than single-use, and where the trap is hiding in the technical specification. Let us be clear from the outset: returnable packaging is not a “buy once, own forever” deal – the fleet wears out, and replacing it is a real, recurring cost that has to be counted alongside washing and return transport. That is why we give the point of cost advantage directionally, for a specific process, and never as a single universal number. These questions decide whether PPWR compliance will be a cost for a company or a chance to cut transport costs over the longer horizon.

Nor is this an exclusively Polish matter, or an exclusively regulatory one. Henning Wilts of the Wuppertal Institut, one of the more recognisable voices in the circular economy, points out that we need to reduce consumption, strengthen re-use systems and, above all, keep more plastic in circulation (remarks of 11 July 2023 on the Zukunftswissen.fm podcast; source: wupperinst.org/a/wi/a/s/ad/8184). PPWR translates that direction into hard deadlines.

The first 90 days: what to do before your competitors do

You do not need a ready-made strategy for 2030 to start well. A well-ordered quarter is enough.

1. Days 1–30: packaging inventory. Map what you really use in transport and in grouped packaging – pallets, cardboard boxes, film, crates, trays – and mark which items come into contact with food. Without this map, every further decision is guesswork.
2. Days 30–60: classification against PPWR. Assign each packaging stream to the relevant requirement: re-use (Article 29), empty space (Article 24), recycled content (Article 7), PFAS (Article 5). Separately, mark the points where Article 29 covers you as an economic operator using transport packaging – for example in the role of a distributor or shipping operator.
3. Days 60–90: readiness assessment and gap plan. Work out where the 2030 threshold will mean changing the load carrier and where a correction will be enough. If you compare the cost of single-use packaging against returnable, count honestly on both sides: for single-use it is a purchase every year plus the product fee (EPR); for returnable – buying the fleet, replacing it later, plus washing and return transport. The result of such a calculation reads “from which year returnable starts to pay off”, never “payback in X months”. Before you buy anything, measure that gap – it is cheaper than a hasty replacement of the packaging fleet.

If you want to compress that quarter into a single afternoon, start with the PPWR readiness audit – it walks you through these questions step by step. Once you have the results, head to the PPWR knowledge hub, where we gather further analyses and tools.

Frequently asked questions (FAQ)

What is PPWR? PPWR is Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste. It applies directly across the whole Union and replaces Directive 94/62/EC.

When does PPWR apply? The regulation was published on 22 January 2025 and entered into force on 11 February 2025. Most provisions apply from 12 August 2026. The hardest thresholds (re-use, empty space, recycled content) take effect from 1 January 2030.

Who does PPWR apply to? The whole packaging chain, not only packaging manufacturers. The obligations to re-use transport packaging rest on “economic operators” within the meaning of the regulation (Article 3) – including distributors, final distributors, online sellers and fulfilment/3PL operators.

Does PPWR apply to my company if I only distribute or ship goods? Yes. If you distribute packaging or ship goods in it, you are an economic operator within the meaning of Article 3(1)(12) – and it is at economic operators that the regulation directs its obligations, regardless of whether you manufacture anything. A separate question is how your packaging counts towards the 40% target of Article 29: only transport packaging that is reusable packaging operating within a re-use system counts towards it, and some formats are expressly excluded from the obligation (Article 29(4) – including cardboard boxes and packaging for dangerous goods).

How does PPWR differ from EPR (extended producer responsibility)? They are two different things that operate in parallel, not interchangeably – but the boundary between them does not run where it is usually drawn. EPR is a mechanism for financing waste management, while PPWR sets requirements for the packaging itself (design, re-use, recycled content) – except that PPWR also regulates EPR itself. Chapter VIII of the regulation requires producers to register in the national producer register and to report annually (Article 44 – without an entry in the register, packaging may not be made available on the market of the Member State concerned), establishes extended producer responsibility itself together with the costs covered by producers’ financial contributions (Article 45), and sets the rules for producer responsibility organisations (Article 46). What PPWR does not set is the level of EPR fees – those depend on national implementation (in Poland: the draft UC100 act, still being finalised), so specific EPR amounts today are forecasts, not regulatory fact. We expand on this in a separate article: EPR vs PPWR.

What happens to Directive 94/62/EC? It is repealed on 12 August 2026 and replaced by PPWR.