PPWR.how · https://ppwr.how/blog/Downloaded copy · 2026-10-16 · information, not legal advice
Analysis
PPWR, read closely.
Longer pieces on the questions packaging teams actually ask — each one tied to the article it interprets and the official source it relies on.
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The six PPWR packaging format bans from 1 January 2030 (Annex V)
From 1 January 2030, Article 25 bars six packaging formats for specific uses: plastic multipack wraps, plastic for small fresh-produce packs, single-use plastic for dine-in HORECA, HORECA portion packs, hotel miniatures and very lightweight plastic bags. Here is each point, its exceptions, and the 5 % plastic rule from the Commission's guidance.
Art. 25Annex VArt. 70(4)
Empty space in sales packaging from 12 February 2028: PPWR Article 24(4) explained
From 12 February 2028, whoever fills sales packaging must keep empty space to the minimum needed for function and product protection. There is no fixed percentage for sales packs, void fill counts as empty space, and settling products are judged at filling. Here is how Article 24(4) differs from the 50 % rule for transport and e-commerce packaging.
Art. 24Art. 10Annex IV
Compostable packaging under PPWR Article 9: what must, may and may not be compostable
From 12 February 2028, tea and coffee bags, soft single-serve pads and fruit stickers must be industrially compostable; Member States may require compostability for capsules and thin carrier bags; and everything else, biodegradable plastics included, must be designed for material recycling. Here is the three-way split and how to prove it.
Art. 9Art. 3(1)(1)(f)–(g)Art. 12(1)
Who is the 'producer' under PPWR EPR? Registers, reporting and authorised representatives
PPWR separates the manufacturer, who makes the pack compliant, from the producer, who pays for its waste where it is first made available. Here is how to find the producer, what registering and reporting involve under Article 44, and where the authorised-representative duty of Article 45(3) stands after the Omnibus proposal.
Art. 3(1)(15)Art. 44Art. 45
The PPWR labelling act is late. What that changes for your packaging artwork
The implementing act defining the EU sorting label was due on 12 August 2026 and has not been adopted. Because Article 12 applies 24 months after that act at the earliest, the 2028 date is now a floor. Here is what is already in force, what can wait, and what to prepare.
Art. 12Art. 14Art. 15(5)–(6)
PPWR PFAS limits for food-contact packaging: the three numbers and the Commission's test route
Since 12 August 2026, food-contact packaging over three PFAS thresholds cannot be placed on the EU market. Here is what each limit measures, the stepwise test the Commission recommends, and what happens to stock you already hold.
Art. 5(5)Annex VII
Does packaging have to be recyclable now? What PPWR Article 6 requires since August 2026
Article 6(1) has applied since 12 August 2026, but the A/B/C grading has not started. The Commission's guidance explains which test you are held to today, when grading begins, and when the conformity assessment for recyclability becomes due.
Art. 6Annex II
How PPWR changes the Single-Use Plastics Directive: Article 67 and its dates
Article 67 of the PPWR amends the Single-Use Plastics Directive in five places: which law prevails, the PET bottle recycled-content targets, reporting, and three new market bans covering XPS food and drink containers, luggage shrink wrap, plastic loose-fill chips and multipack rings. The new bans apply from 12 February 2029.
Art. 67Art. 71Directive 2019/904