Act Early = Legal Certainty
PPWR-compliant mono-material jars already meet key requirements today. Early conversion helps avoid future redesigns and audit risks.
The European Packaging Regulation PPWR
An opportunity for sustainable plastic packaging
As a manufacturer of primary packaging materials made of plastic, H&K Müller considers it its duty to provide its customers with comprehensive information about the relevance and implications of the new European Packaging Regulation (PPWR).
We see education and transparency as a central part of our business policy and social responsibility: from explaining legal requirements and framework conditions to providing declarations of conformity and practical support in implementing the new regulation. Our goal is to give our customers peace of mind and support them in using packaging solutions that not only comply with legal requirements but also contribute to a sustainable circular economy.
Legal basis & key passages
The PPWR establishes binding requirements throughout the entire life cycle of packaging—from design and labeling to waste treatment. It defines recyclability as the compatibility of packaging with collection, sorting, and large-scale recycling.
„For the purposes of this Regulation, the term “recyclability” means the compatibility of packaging with waste management and treatment through design, based on separate collection, sorting into separate waste streams, large-scale recycling, and the use of recycled materials to replace primary raw materials.“
Obligations for distributors under the PPWR
Declaration of Conformity / Technical Specification
According to Art. 17 and 24 PPWR, a conformity assessment procedure must be carried out for each packaging. This includes:
- a technical product specification (material, composition, intended use),
- a declaration of conformity confirming compliance with the regulation,
- an obligation to retain the documentation for at least ten years.
Recyclability and Substance Limits
Under Art. 6 PPWR, packaging must be designed so that it can be recycled within existing collection and sorting systems. In particular, mono-material packaging is advantageous.
Additionally, Art. 5 PPWR defines strict limits for hazardous substances: heavy metals such as lead, cadmium, mercury, and hexavalent chromium are strictly limited. For food contact materials, new limits will apply from 2026, and from 2030 PFAS will be banned entirely.
Labeling Obligations from 2028
From August 12, 2028, comprehensive labeling obligations (Art. 11–13 PPWR) will apply. Packaging must then include information about:
- the material composition,
- the recyclability,
- instructions for separate collection.
Recycled Content Quotas from 2030 (planned)
Recycled content quotas are foreseen in the current version of the PPWR under Article 7 starting in 2030. The share of recycled content will be gradually increased. The EU will decide by 2028 on possible exemptions for critical sectors (food and pharmaceuticals) and whether bio-based plastics will count toward these quotas.
No Deceptive Packaging / Empty Space Limitation (max. 50%)
According to Art. 9 and 17 PPWR, packaging must be designed so that its weight and volume are reduced to the minimum necessary.
It must not increase the perceived volume of the product through double walls, false bottoms, or unnecessary layers (Article 9, paragraphs 1 and 2).
From 2030, the empty space ratio of any box may not exceed 50%.
Opportunities & Recommendations under the PPWR
How to simplify processes, reduce costs, and strengthen your sustainability profile with PPWR-compliant solutions – especially through mono-material plastic jars and screen-print labeling.
Mono-material + Screen Printing: Future-proof and Efficient
Uniform material systems simplify conformity assessment, documentation, and recycling. Direct screen printing replaces labels – no additional adhesives, no backing material, no interference with sorting processes.
100% Mono-material
Label-free thanks to Screen Printing
Design-for-Recycling
PCR-ready (from 2030)
Simplified Conformity Assessment
Homogeneous materials reduce verification efforts. No complex composite analyses, clearly documentable composition.
Labeling without Labels
Direct screen printing ensures required markings are durable and recycling-friendly – without adhesives or backing material. This improves sortability and design-for-recycling.
Strong in Sustainability Communication
“Recyclable, label-free, mono-material” – clear messages strengthen brand trust and facilitate CSR reporting.
Flexible for Recycled Content Quotas
Mono-material setups are PCR-ready. Quotas can be met gradually without production changes.
Reduce Costs, Streamline Processes
Fewer components, fewer suppliers, fewer inspections. Long-term savings in licensing and handling costs through improved recyclability.
Deadlines according to the current version of the PPWR (as of September 2025)
2025
Enforcement of PPWR
On February 12, 2025, the new European recycling regulation PPWR came into force.
2026
conformity assessment requirement
From August 12, 2026: Mandatory conformity assessment for all packaging, documentation of recyclability and freedom from harmful substances.
2028
Extended labeling requirements
From August 12, 2028: Extended labeling requirements (material, recyclability, disposal instructions).
2030
Mandatory recycled content quotas
1. Ban on non-recyclable packaging 2. Mandatory recycled content quotas for non-critical areas (exceptions for food and pharmaceuticals are expected) 3. Limitation of empty space/ban on deceptive packaging 4. Ban on PFAS in food packaging
Frequently asked questions about the European Packaging Regulation PPWR
What does the abbreviation PPWR mean?
The abbreviation PPWR stands for “Packaging and Packaging Waste Regulation” (PPWR, EU 2025/40). This is the new European packaging regulation that came into force on February 12, 2025. It will apply immediately and uniformly in all EU member states from August 12, 2026, following a transition period. The PPWR replaces the previous Packaging Directive 94/62/EC.
What are the main objectives of the PPWR?
- Reducing packaging waste in the EU
- Promoting reuse and recyclability
- Uniform standards for design for recycling
- Introduction of recycled content quotas
- Protecting consumers from misleading volumes and harmful substances
What distinguishes the PPWR from the previous Packaging Directive?
The previous Packaging Directive 94/62/EC had to be transposed into national law by the individual member states. This led to different interpretations of the directive depending on the member state. The PPWR, on the other hand, is a regulation and applies directly in all EU countries without any national leeway.
When do the new PPWR requirements come into effect?
- From August 12, 2026: Conformity assessment procedures for all packaging, proof of recyclability and freedom from harmful substances
- From August 12, 2028: Extended labeling requirements (material, recyclability, disposal instructions).
- From 2030: Mandatory recycled content quotas in plastic packaging, empty space limited to max. 50%, ban on PFAS in food contact materials.
Where can I find the text of the PPWR law?
The original text of the PPWR is available on the official website of the European Union here!
What are the obligations of packaging distributors under the PPWR?
Declaration of Conformity & Technical Specification (Art. 17, 24)
A conformity assessment procedure must be carried out for each packaging, and its results must be documented in a technical product specification and a declaration of conformity. In this document, the manufacturer or importer confirms compliance with, among other things, recyclability and substance limits, and from 2030 onward, with recycled content requirements.
Recyclability & Substance Limits compliance (Art. 5, 6)
Recyclability (Art. 6):
Packaging must be designed to allow separate collection, sorting, and large-scale recycling (Design-for-Recycling). Mono-material packaging fulfills these requirements particularly well.
Substance Limits (Art. 5):
The materials used must not exceed limits for substances such as lead, cadmium, Cr(VI), and mercury; for food contact materials, additional PFAS limits/bans apply.
Labeling Obligations applicable from 2028 (Art. 11–13)
From August 12, 2028, extended consumer information will be mandatory, including material composition, recyclability, and instructions for separate collection. EU-wide harmonized symbols and pictograms will be introduced.
Recycled Content Quotas to be demonstrated from 2030 (Art. 7)
From 2030, minimum shares of recycled content will apply to certain plastic packaging. Details and definitions (e.g., PCR/PIR) are not yet final and will be specified through implementing acts (clarification expected by 2028).
Empty Space Limitation to max. 50% (Art. 9, 17)
Packaging must not create a misleading impression of volume; the ratio between contents and empty space must be observed (typically: max. 50% empty space). The goal: material reduction and consumer protection.
What role does the recyclability of packaging play in the PPWR?
The PPWR defines recyclability in Art. 3 No. 38 as the design of packaging that enables separate collection, sorting, and large-scale recycling. The aim here is to substitute primary raw materials with secondary raw materials (recyclates).
What do the new labeling requirements under the PPWR mean?
From 2028 onwards, packaging must clearly indicate the material composition, recyclability, and disposal methods for the respective packaging. EU-wide binding symbols and pictograms will be introduced.
What is meant by recycled content quotas or recycled material usage quotas in the context of the PPWR?
From 2030, plastic packaging must contain legally defined minimum proportions of post-consumer recycled material (PCR). The quotas will be gradually increased up to and including 2040. The extent to which food and pharmaceutical packaging or packaging made from bio-based raw materials will be affected will be clarified by the European Parliament in 2028.
Why is monomaterial packaging particularly advantageous in relation to the PPWR?
Single-material packaging—such as all plastic containers from H&K Müller—is particularly advantageous in terms of the PPWR, as it can be easily recycled from existing waste streams. In addition, it can be combined with recycled materials (PCR/PIR) on a pro rata basis in order to meet the recycled content quota that will become mandatory from 2030.
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