Regulation (EU) 2025/40

The EU PPWR Implementation Roadmap.

The Packaging and Packaging Waste Regulation (PPWR) is now law. As of February 11, 2025, the grace period for e-commerce has begun. Here is everything you need to know to stay compliant.

Implementation Timeline

Feb 11, 2025

Entered into Force

The regulation officially replaces the former directive.

Aug 12, 2026

Mass Application

Empty space and performance standards become mandatory.

Aug 2028

Harmonized Labeling

Mandatory material labels & QR codes on all packaging.

2030

Circular Economy Targets

Mandatory reuse options at checkout and elevated recycling thresholds.

Void Space Optimization

Article 24

• Deadline: Aug 12, 2026

The European Union is introducing strict limits on under-filled shipping containers. By mid-2026, the Empty Space Ratio in e-commerce and transport packaging must not exceed 40%.

  • Filling material (bubble wrap, air cushions, etc.) counts as empty space.
  • Calculation: (Outer package volume - Net product volume) / Outer package volume.
  • Failure to optimize box sizes can lead to logistics fines and sales bans.

Circular Recyclability

Article 6

• Baseline Goal: 2030

From 2030, all packaging placed on the EU market must be Recyclable by Design. This applies to every component, from the tape to the ink used on labels.

  • By 2030, materials must be separable and compatible with sorting streams.
  • Plastic packaging must meet minimum recycled content thresholds (e.g., 35% for PET).

Digital Transparency

Article 12

• Deadline: Aug 2028

Consumer transparency is being digitized. By late 2028, harmonized labeling and QR-based digital product passports will be required.

  • QR codes must link to a Digital Product Passport (DPP) with material composition.
  • Standardized sorting pictograms across the whole EU (no more country-only logos).

Mandatory Reuse

Article 29

• Baseline Goal: 2030

Online sellers are required to integrate circularity at the point of sale. Specific mandates for e-commerce become increasingly rigorous through the end of the decade.

  • By 2030, online sellers must offer a reusable shipping option at checkout.
  • Specific reuse targets for transport packaging will scale through 2040.

National Roadmap

Until the EU PPWR enters full force in late 2026, you must comply with established national environmental laws. Explore detailed guides for each key market.

Germany: VerpackG

Covers LUCID registration and Dual System licensing requirements. Strict zero-threshold policy: You must register even for a single package. SMEs are only exempt from costly audit declarations.

Key Deadlines

  • Initial Forecast (HPM1): Dec 31
  • Year-End Actuals: May 15

France: AGEC Law

Focuses on the mandatory Triman logo, Info-Tri sorting labels, and CITEO compliance. No volume exemptions: simplified flat-rate reporting (~€80/year for <10k units) is offered, but registration remains strictly mandatory.

Key Deadlines

  • Year-End Actuals: Feb 28
  • *Varies slightly by PRO

Spain: RD 1055/2022

Covers the Ministry Registry and mandatory pictograms. Zero de minimis threshold—registration applies from the first box. Foreign sellers must legally appoint a local Authorized Representative.

Key Deadlines

  • Annual Declaration: Q1 (Feb-Mar)
  • *Depending on SCRAP

SME Compliance Scope: Applicability & Exemptions

Small business?
The regulations still apply.

A common misconception is that Extended Producer Responsibility (EPR) and PPWR only apply to large-scale enterprises. In reality, the EU has established almost universal accountability.

Micro-EnterprisesArticle 29

Defined as <10 employees and <€2M turnover. You get lighter administrative burdens, but zero exemptions from sustainability standards.

Weight ThresholdsArticle 29(3)

Limited exemptions from reuse targets only apply if you use <1,000kg of packaging annually and meet the micro-enterprise definition.

EPR RegistrationArticle 39

There is no volume threshold for EPR registration. Even if you ship one box to Germany or France, you must be registered with a PRO.

Access Full Text of Regulation (EU) 2025/40

Start your compliance audit today.

Don't wait for the August 2026 application window. Set up your material catalog now and see your void space ratios before they become a legal liability.

Legal Disclaimer: For informational purposes only. Not legal advice. Regulations change frequently; consult a specialist for binding guidance.