Nathalie Vernin

Regulation (EU) no. 2025/40 of 19 December 2024, known as ‘PPWR’, was published in the Official Journal on 22 January 2025. The regulation comes into force on 11 February 2025 and will apply from 12 August 2026.
All packaging and materials are covered by these obligations.

 

The objectives and main actions of the regulation are as follows:

  • Reduce the production of packaging waste.
  • Promote a circular economy for packaging in a cost-effective way.
  • Encourage the uptake of recycled content in packaging.
  • Harmonise rules within the EU

 

Here are the main subjects covered by the regulation:

 

  • REDUCING PACKAGING AND WASTE :

Minimisation and restrictions on certain packaging formats

By no later than 1 January 2030, packaging must be designed in such a way that its weight and volume are reduced to the minimum necessary to ensure its functionality, taking into account its shape and the material of which it is made.
Packaging that does not comply with the performance criteria defined in Annex IV will be banned. This applies in particular to packaging designed to increase the apparent volume of the product, including double walls, false bottoms and unnecessary layers.

 

Harmonised standards will be drawn up to define the calculation and verification method for reducing packaging to a minimum by 12 February 2027 at the latest. These will specify, for the most common types and formats of packaging, the appropriate maximum weight and volume limits and, where appropriate, the maximum thickness and empty space.

 

For grouped / transport / e-commerce packaging, the empty space must be reduced to the minimum necessary to ensure the functionality of the packaging (empty space rate < 50%). Air cushions, bubble wrap and sponge fillers are considered to be empty packaging.

 

On 12 February 2028, the Commission is empowered to adopt implementing acts to establish the method for calculating the empty space rate, taking into account the specific characteristics of packaging.

From 1 January 2030, single-use cosmetic packaging in hotels will be banned. There will also be a ban on bundled plastic packaging used at the point of sale, designed as convenience packaging to encourage consumption.

 

  • RECYCLABILITY :

All packaging designed for recycling by 2030 and recycled at scale by 2035

By 1 January 2030, all packaging placed on the market must be designed for recycling.

To achieve this, design criteria for recycling by packaging category and performance classes A, B and C will have to be established by delegated act before 2028, based on standards.

By 1 January 2035, all packaging placed on the market must be recyclable at scale (annual quantity of recycled materials >55% in the EU).

To achieve this, a method for assessing recycling at scale will have to be established by implementing act before 2030.

 

  • RECYCLED PLASTIC CONTENT :

Minimum recycled plastic content obligations by 2030 and 2040 for all packaging containing plastics

The plastic part of a packaging must contain a minimum percentage of recycled content, from post-consumer recycling, by type and format of packaging detailed in table 1 of Annex II, calculated as an average per manufacturing plant, and per year: (compostable packaging not concerned).

From 1 January 2030, the minimum recycled content must be :

  • 30% for contact-sensitive packaging (including cosmetic packaging) whose main component is polyethylene terephthalate (PET)
  • 10% for contact-sensitive packaging made from plastic materials other than PET
  • 35% for other plastics

From 1 January 2040:

  • 50% for contact-sensitive packaging (including cosmetics packaging) whose main component is polyethylene terephthalate (PET)
  • 25% for contact-sensitive packaging made from plastic materials other than PET
  • 65% for other plastics

No later than 31 December 2026, the Commission shall adopt delegated acts to define sustainability criteria for material recycling technologies and implementing acts establishing the method for calculating and verifying the percentage of recycled content.

 

  • SUBSTANCES PRESENT IN PACKAGING :

Reduce negative impacts on the reuse and recycling of materials or on chemical safety

SVHC substances must be minimised in packaging.
The Commission, assisted by ECHA, must prepare a report on the presence of substances of concern in packaging by 31 December 2026 in order to assess the risk to human health and the environment and the need for further restrictions.

The sum of lead/cadmium, mercury and hexavalent chromium in packaging and packaging components must not exceed 100mg/kg.

 

  • RE-EMPLOYMENT :

Reuse targets for beverages, food and EICs

There are no targets for household cosmetic packaging. However, there is an obligation for professional packaging:

Transport or sales packaging used to transport products within the EU:

  • 2030: 40% of all packaging to be reusable packaging covered by a re-use system
  • 2040: 70% of all packaging should be reusable packaging from a re-use system.
    e.g. pallets, collapsible plastic boxes, boxes, trays, buckets, drums, cans, etc.

No later than 30 June 2027, the Commission will adopt implementing acts establishing the method for calculating the re-use targets. Economic operators shall submit a report containing, for each calendar year, data on the achievement of the re-use targets to the competent authority.

 

  • HARMONISED MARKINGS :

Labelling requirements for sorting and reuse instructions

A key measure of the PPWR is the harmonised labelling of packaging and bins to make it easier for consumers to dispose of packaging waste correctly. By 12 August 2028 at the latest, packaging placed on the market will have to bear a harmonised label containing information on the materials from which it is made, to make it easier for consumers to sort it.

Implementing acts must be adopted no later than 12 August 2026 to define a harmonised label and specifications for labelling requirements and formats, and to establish a method for identifying the materials that make up the packaging.

Reusable packaging placed on the market from 12 February 2029 will have to bear a label informing users that the packaging is reusable.

Neo Cosmetics can help you find and select the right packaging. To find out more: https://www.neo-cosmetique.fr/co-conception/

 

Sources :

Documents :

  • Webinar FEBEA : CYCLE PPWR#3 PUBLICATION DU RÈGLEMENT 24 JANVIER 2025
  • COSMED : document EU –REGLEMENT SUR LES EMBALLAGES ET LES DECHETS D’EMBALLAGES
  • RÈGLEMENT (UE) 2025/40 DU PARLEMENT EUROPÉEN ET DU CONSEIL du 19 décembre 2024 relatif aux emballages et aux déchets d’emballages, modifiant le règlement (UE) 2019/1020 et la directive (UE) 2019/904, et abrogeant la directive 94/62/CE.

https://eur-lex.europa.eu/legal-content/FR/TXT/?uri=OJ:L_202500040