PPWR packaging design: what the EU packaging regulation means for your packs

What is the PPWR, and what does it mean for packaging design?

The EU Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, is the EU law that sets binding rules for how packaging sold in the EU is designed, made, labelled and recovered. It entered into force on 11 February 2025 and applies from 12 August 2026 (Regulation (EU) 2025/40 on packaging and packaging waste). For packaging design, recyclability, material use, pack size and labelling become legal requirements rather than brand choices.

It is a regulation, not a directive, so it applies directly in every member state and replaces the 1994 packaging directive. Most design requirements take effect in 2030. Packs that reach shelves in 2030 are being briefed and designed now.

Conclusion: The deadline is 2030. The design decisions are being made today.

Why does the PPWR matter for brands, not just packaging engineers?

The PPWR matters for brands because it limits the things that make a pack recognisable: material, finish, shape, size and label space. Those are often a brand's most valuable distinctive assets, the cues shoppers use to find you in a second.

A metallic finish, an oversized carton or a layered structure may each have to change. If engineering makes those changes alone, a brand can end up compliant but unrecognisable. Run them as design decisions instead, and the brand can come out clearer.

The PPWR also arrives alongside the EU green claims rules. One governs what the pack is made of. The other governs what the pack says about it.

Which PPWR requirements affect packaging design?

Six requirements in the PPWR shape design directly (Regulation (EU) 2025/40):

1. Recyclable design. From 2030, all packaging must meet design-for-recycling criteria and be graded A, B or C. Packaging below grade C may not be sold. From 2035, packaging must also be recycled at scale, not only in theory. The Commission is due to set the detailed criteria for each material by 2028.

2. Minimisation. Weight and volume must be cut to the minimum the pack needs to work. Features that only make a product look bigger, such as double walls and false bottoms, are not allowed. From 2030, grouped, transport and e-commerce packaging may have no more than 50 per cent empty space.

3. Recycled content. From 2030, plastic packaging must contain minimum shares of recycled plastic. The shares are 30 per cent for contact-sensitive PET, 10 per cent for other contact-sensitive plastics, 30 per cent for single-use beverage bottles and 35 per cent for other plastic packaging. Higher targets follow in 2040.

4. Substances. From 12 August 2026, PFAS in food-contact packaging are restricted above set limits.

5. Labelling. Harmonised labels showing material composition, matched by labels on waste bins, become mandatory from August 2028 at the earliest.

6. Restricted formats and reuse. From 2030, some single-use plastic formats are banned, such as packaging for small quantities of fresh fruit and vegetables and miniature toiletries in hotels. Reuse targets also apply to transport packaging and some beverage packaging.

What are the PPWR deadlines?

The PPWR deadlines are spread across 2025 to 2040. Most design rules apply from 1 January 2030.

Date What changes 11 February 2025 Regulation enters into force 12 August 2026 Regulation applies; PFAS limits for food-contact packaging August 2028 (earliest) Harmonised material labels 1 January 2030 Recyclability grades A–C, minimisation, 50% empty-space limit, recycled content, format restrictions 2035 Packaging must be recycled at scale 2040 Higher recycled-content targets

Several dates depend on secondary legislation the Commission still has to adopt. Check its published timeline before you fix a redesign plan.

What do people get wrong about the PPWR?

The most common mistake is treating 2030 as a starting point. A typical redesign takes many months to brief, test, approve and roll out. Packs redesigned in 2027 without the PPWR in mind may need redesigning again.

Other common mistakes:

• "Technically recyclable is enough." The grades and the at-scale test mean a pack must work in real sorting and recycling systems.

• "Paper is automatically safe." Paper-based packaging is assessed against the same criteria. Coatings, laminates and mixed materials affect the grade.

• "Compliance gives us a green story." Meeting the PPWR does not give you permission to make environmental claims. Those fall under separate rules.

• "The figures in that article are right." Figures from earlier drafts still circulate. Work from the adopted text.

When should a brand start acting on the PPWR?

A brand should act on the PPWR now if it sells packaged goods in the EU and plans redesigns, launches or range reviews before 2030. The rules cover packaging sold on the EU market wherever it is made, so brands outside the EU are covered too.

Food and FMCG brands are most exposed. So are brands with large plastic ranges, food-contact formats or e-commerce shipments. The more products in a portfolio, the more each material decision multiplies across packs.

How does IW Agency see the PPWR as a design brief?

At IW Agency, we see the PPWR as a design brief as much as a compliance task. We frame it in three parts: material, memory and message.

• Material is what the law decides: substrate, weight, volume, recyclability.

• Memory is what the shopper uses to find you: colour, shape, logo and the cues that make you recognisable.

• Message is what the label still has room to say once mandatory information takes its place.

Our view is that material can change a great deal if memory is protected on purpose. A pack that loses its foil but keeps its colour, shape and logo still gets chosen. A pack that keeps its foil but loses its place in the shopper's memory does not.

This is hardest across a portfolio. Since 2007, we have worked with Arla to evolve its product portfolio. In a portfolio of that size, one change of material ripples through every format. That is where a brand design system earns its keep. It lets you change materials across the range without losing what makes each pack recognisable.

Conclusion: Change the material. Protect the memory.

What does this mean for your brand?

• Audit packs against the PPWR now. List every format by material, recyclability risk and size, then flag the packs that touch your most important assets.

• Name the assets you will defend. Decide which colours, shapes and marks must survive any change of material, and which can flex.

• Bring design in early. Material choices made in procurement shape the pack for years. Put brand and design in the room when they are made.

• Plan label space for 2028. Harmonised material labels need room on the pack. Design that room into your system before it is taken from you.

• Keep claims and compliance separate. Check every environmental claim against the green claims rules, whatever the pack is made of.

Frequently asked questions

Does the PPWR apply to companies outside the EU?

Yes. The PPWR covers packaging placed on the EU market, whoever made it. Obligations fall on manufacturers, importers and distributors.

Does the PPWR ban plastic packaging?

No. The PPWR bans some single-use plastic formats from 2030 and sets minimum recycled content for plastic packaging. Plastic remains allowed if it meets the requirements.

Is the PPWR already in force?

Yes. The PPWR entered into force on 11 February 2025 and applies from 12 August 2026. Most design requirements take effect from 1 January 2030.

Does the PPWR replace national packaging rules?

The PPWR replaces the 1994 packaging directive and harmonises the core rules across the EU. Member states still run collection systems and producer responsibility schemes.

Do we need to redesign every pack?

Not necessarily. Many packs need only material or size adjustments. An audit shows which packs need a full redesign and which need small changes.

Where should you start with PPWR packaging design?

Start by separating what must change from what must stay. The PPWR decides much about materials, but a brand that knows its distinctive assets can change them and stay recognisable. If you want to talk about how your packaging can meet the PPWR and still get chosen, write to us at hello@iwagency.com.

Sources

• Regulation (EU) 2025/40 on packaging and packaging waste — Official Journal of the European Union, 2025