What is PPWR?
The Packaging and Packaging Waste Regulation (PPWR) – Regulation (EU) 2025/40 – is the EU’s new rulebook for packaging. It replaces the old packaging directive and takes effect in all Member States on 12 August 2026, with no national transposition required. From that date, the same rules apply to a packaging manufacturer in Slovenia, a brand owner in Germany, and an importer in Poland alike.
PPWR moves packaging from waste policy into product compliance, making it closer in spirit to CE marking than to anything the industry has dealt with before.
What Does PPWR Cover?
There are five pathways for producers to meet the plastic reduction targets.
Recyclability grades
Starting in 2023, packaging must be considered recyclability Grade A, B or C. By 2038, packaging must fall under either Grade A or B.
Recycled content
Plastic packaging must meet minimum post-consumer recycled (PCR) thresholds by 2030.
Reuse targets
By 2030, 10% of packaging for beverages and 40% of transport packaging must be reusable. Starting in 2028, hotels, restaurants, and catering companies (HORECA) will be required to offer reusable take-out formats.
Empty-space caps
By 2030, the maximum filler ratio for grouped, transport, and e-commerce packaging will be 50%, including air cushions and bubble wrap.
The Declaration of Conformity (DoC) is the document of evidence that proves compliance with the above policies.
Who is Affected?
PPWR assigns obligations not by industry sector or company size, but by the role a company plays in the supply chain. A single company can hold more than one role simultaneously and where it does, the obligations stack.
To understand which roles apply to your business and what each requires, read our PPWR Roles and Obligations Blog.
Where Trayak can help: The EU Declaration of Conformity
The Declaration of Conformity (DoC) is the operational keystone of PPWR. It is the signed document where the manufacturer confirms that a piece of packaging meets the sustainability requirements of Articles 5 to 12. It is issued per packaging type, not per company; therefore, a blanket “all our packaging conforms” statement will not satisfy the regulation. Starting on August 12th, 2026, every piece of packaging on the EU market needs its own DoC, valid for five years for single use plastics and ten years for reusable packaging.
Every DoCs must be backed by a technical file maintained in accordance with Annex VII (Module A, Internal Production Control). The file must include substance test reports, recyclability scoring, recycled-content evidence, minimisation justification, label specifications, and supplier documentation. Surveillance authorities can request the technical file at any time, in any official EU language, and most Member States expect electronic delivery within ten business days.
Trayak Consulting can help your company assemble and maintain the data used for this document, so whether your customers, stakeholders, or surveillance authorities ask for it, your company is prepared to respond.
EcoImpact and PPWR
The commercial stakes are equally significant. Starting in 2027, EPR fees across the EU will be eco-modulated by recyclability grade. The design decisions a company makes in 2026 will shape its EPR cost base for the next decade.
In practice, this means companies need a single packaging dataset capable of feeding PPWR, CSRD, EPR and customer reporting in parallel. Once this is established in a software like EcoImpact, complying with regulations worldwide becomes a breeze.
Build it once. Run it as one system.
What do you need for PPWR compliance?
Disclaimer
This page reflects the text of Regulation (EU) 2025/40 as published in the Official Journal on 22 January 2025 and the Commission’s first official implementation guidance of 30 March 2026. Some operational details, including the Grade A/B/C recyclability methodology (delegated act due by 1 January 2028), the harmonised minimisation standard (Commission to request by 12 February 2027), and Member State surveillance practice (commonly described as a 10 business day window under the Regulation (EU) 2019/1020 framework), will be fully locked once the delegated and implementing acts arrive in 2027 and 2028. We will update this page as each delegated act is published.