When did the PPWR come into force? Timetable for the implementation of changes for businesses

The PPWR formally came into force on 11 February 2025, but most of its provisions will apply from 12 August 2026. This is a key distinction for businesses: the regulation already forms part of EU law, but businesses have a transition period to prepare their packaging, documentation, procurement processes and sales strategies. The European Commission confirms that the Packaging and Packaging Waste Regulation 2025/40 entered into force on 11 February 2025 and will, in principle, apply from 12 August 2026.

In practice, there is no single, short answer to the question „When does PPWR come into effect?”. For the legal department, the most important date is 11 February 2025. For operations and compliance — 12 August 2026. For the board, procurement, marketing and product development — the years 2030, 2035, 2038 and 2040, as that is when the most important requirements regarding recyclability, recycled content, packaging reduction and environmental targets come into force.

PPWR – entry into force and application of the provisions

The most common mistake in interpreting the PPWR is to confuse two concepts: the entry into force and the application of the provisions.

The entry into force of the PPWR means that the regulation has become part of EU law. The application of the PPWR marks the point from which specific obligations begin to take effect for businesses and the market.

The PPWR is a regulation, not a directive. This means that it does not require traditional transposition into national law, as was the case with many previous environmental regulations. The provisions will apply directly in the Member States, although enforcement practices, registration systems and penalties will continue to be linked to national administrative mechanisms.

For businesses in Poland, this means that they should not wait solely for the Polish implementing legislation. The PPWR is an EU legal act that sets out common requirements for packaging on the EU market.

Key dates for the PPWR at a glance

The timeline below sets out the key milestones that should be included in the plan of any company launching packaged products onto the European Union market.

Date	What's going on?	Significance for the company
22 January 2025.	Publication of Regulation (EU) 2025/40 in the Official Journal of the EU	The start of the final preparatory period
11 February 2025.	Entry into force of the PPWR	The regulation becomes part of EU law
12 August 2026.	General date of application of the PPWR	Companies should have well-organised documentation, processes and packaging assessments
2027–2028	Clarification of certain requirements, methodologies and implementing acts	It’s time to make technical adjustments to the systems and documentation
2029	The growing importance of collection and reporting schemes, including certain obligations relating to beverage packaging	Companies should have data on the weights, materials and flows of packaging
2030	One of the key stages of PPWR: recyclability, recycled material, restrictions on certain formats, minimisation of packaging	Problematic packaging may need to be changed
2035	Strengthening recycling requirements in practice and waste reduction	It is not only the packaging design that will matter, but also the actual scale of recycling
2038	Tightening of the permissible recyclability classes	Lower-grade packaging may be forced out of the market
2040	Higher targets for recycling, reuse and the reduction of packaging waste	A packaging strategy must be long-term

The European Commission states that the PPWR is intended to cover all packaging and packaging waste, regardless of material or origin, and to introduce requirements regarding the production, composition, reuse and recovery of packaging.

2025: The PPWR is now in force as a piece of legislation

The year 2025 marks the formal launch of the PPWR. The regulation was adopted as Regulation (EU) 2025/40 and entered into force on 11 February 2025.

For businesses, this did not yet mean full compliance with all obligations, but it marked the start of a period during which they should review their packaging, suppliers, labelling, procurement processes and exports. This stage is particularly important for businesses that have long product design cycles, use bespoke packaging or sell in several EU markets.

Example: if a company launches a new product range in 2026, it should not design the packaging based on the old guidelines, as some of the PPWR requirements will be in force during the product’s time on the market.

12 August 2026 – a key date for businesses

The key operational date is 12 August 2026. From that date, the PPWR is to be applied in principle. This is the point at which companies should have the basic elements of compliance in place: knowledge of the packaging used, documentation from suppliers, a risk assessment, the allocation of internal responsibilities and a change management plan.

This does not mean that all the target requirements will come into full effect on 12 August 2026. Some of the obligations will be implemented in stages. However, this does not alter the fact that, from that date, the PPWR will cease to be merely a strategic issue and will become a tangible part of day-to-day packaging compliance.

Companies wishing to check their readiness before that date should start by PPWR audit. This analysis makes it possible to assess packaging in terms of its design, composition, recyclability, labelling and compliance with environmental and legal requirements.

2027–2028: time to refine the methods and carry out technical preparations

The years 2027–2028 will be a period during which some of the technical and organisational requirements will be clarified. For companies, this is a time to organise their data, implement procedures and prepare for the requirements that will come into effect in subsequent stages.

During this period, the following will be particularly important:

– technical documentation for packaging,
– information on the material composition,
– confirmation from suppliers,
– information on recycled material,
– assessment of substances of concern,
– preparation for labelling requirements,
– monitoring sales in foreign markets,
– the link between PPWR and the obligations under BDO, LUCID and packaging schemes in other countries.

If a company engages in international sales, it should combine the PPWR with an analysis of local packaging requirements. In this regard, the following is helpful: compliance with packaging requirements in EU markets, particularly for businesses selling packaged products outside Poland.

2029: data, collection and packaging systems are becoming increasingly important

The year 2029 will be particularly significant for companies operating in sectors covered by collection, reporting and settlement schemes for selected types of packaging. The PPWR reinforces the importance of data on packaging: its weight, material, intended use and method of placing on the market.

For businesses, the practical implication is simple: without reliable data on packaging, it is impossible to manage the PPWR schedule safely. A company should know how much packaging it places on the market, which material fractions it uses, where the products end up, and who is responsible for reporting.

This stage is particularly important for e-commerce, as mail-order sales generate a large number of packaging items: cardboard boxes, envelopes, plastic film, tape, labels and packing materials. Online shops should combine PPWR analysis with e-commerce audit, and for sales to Germany, this also includes checking obligations via the LUCID system.

You can read more about the German system in the guide The LUCID Register and sales to Germany – obligations of Polish businesses.

2030: the biggest turning point for PPWR

The year 2030 is one of the key milestones in the PPWR timetable. The European Commission states that the new regulations are intended to ensure that all packaging on the EU market is recyclable by 2030.

In practice, 2030 will bring several concurrent changes for businesses:

– packaging will have to meet the requirements for recyclability,
– the importance of designing in accordance with the principles of ‘design for recycling’ will increase,
– requirements regarding the minimum proportion of recycled material in selected plastic packaging will come into force,
– the range of single-use packaging formats will be reduced,
– reuse and refill models will become more important,
– Excessive weight and volume of packaging will be restricted.

The Council of the EU points out that the new rules set targets for 2030 and 2040 regarding the minimum proportion of recycled material, the minimisation of the weight and volume of packaging, the restriction of substances of concern, and requirements for labelling and consumer information.

For businesses, 2030 should not be the starting point for preparations. It is the deadline by which many design, procurement and documentation decisions should already have been implemented.

2030 and the recyclability of packaging

Recyclability does not simply mean that a material is „theoretically recyclable”. What will matter is the design of the packaging as a whole: the material, additives, labels, adhesives, dyes, coatings, laminates and sortability.

Packaging may prove to be the most problematic:

– multi-material,
– laminated,
– heavily dyed,
– difficult to separate,
– with labels that interfere with sorting,
– with excessive embellishments,
– containing elements from different material fractions.

In this context, it is worth analysing multi-material packaging, as it is these projects that often require the most thorough technical and environmental assessment.

2030 and recycled content in packaging

The PPWR anticipates that recycled content will become increasingly important, particularly in plastic packaging. For companies, this means they will need to work with suppliers who are able to verify not only the declared proportion of recycled content, but also its origin, properties and compliance with the requirements for the specific application.

The problem will not be the phrase „packaging made from recycled material” itself. The problem will be proving that the claim is true and properly documented.

In practice, it’s already worth starting to collect:

– material specifications,
– declarations from suppliers,
– information on the proportion of recycled material,
– information about the source of the material,
– certificates of compliance for food contact, where applicable,
– documents confirming the chemical safety of the packaging.

2030: e-commerce and excessive packaging

The e-commerce sector should view 2030 as the deadline by which packaging processes must become more efficient. Oversized boxes, excessive padding, unnecessary plastic film, multiple layers of packaging and artificially inflating volumes could pose regulatory and cost risks.

In practice, an online shop should check:

– are the sizes of the boxes suitable for the products,
– how much empty space there is in the parcels,
– what fillers are used,
– are the materials easy to sort,
– whether the packaging has a verified composition,
– whether overseas sales have been correctly accounted for in the domestic systems.

If a company is sending goods to Germany, it should also check the VerpackG and LUCID. The following may be helpful: LUCID audit, which makes it possible to assess whether sales to the German market have been properly hedged.

2035: recycling in practice, not just on paper

The year 2035 is significant because the PPWR shifts the focus from the packaging design itself to its actual performance within the recycling system. According to an industry report by the FDF, from 1 January 2035, packaging must not only be theoretically recyclable, but also recycled on a large scale, i.e. within a system encompassing collection, sorting and processing.

This is a major change for companies that have so far relied on material declarations. After 2035, what will matter is whether a particular type of packaging actually enters the recycling system and can be processed effectively.

After 2035, the argument that „the material is recyclable” may not be sufficient if the packaging is not actually collected, sorted and processed on a sufficient scale.

2038: stricter recycling class requirements

The year 2038 is also significant in the PPWR timetable. According to practical industry studies on the PPWR, from 2038 the market is set to become more restrictive towards packaging with a lower recyclability class. The FDF indicates that, from 1 January 2038, only packaging with recyclability class A or B will remain authorised on the EU market, whilst class C will no longer be accepted.

For businesses, this means that „minimum compliance” in 2030 may not be sufficient in the years to come. Packaging designed solely to meet the minimum acceptable standard may soon require further modification.

2040: Long-term packaging strategy

The year 2040 marks the next stage in the transformation of packaging. The Council of the EU notes that the legislation includes targets for 2030 and 2040 regarding the minimum proportion of recycled materials and reuse targets, although for some areas the 2040 targets are intended as a long-term development direction.

For businesses, the year 2040 is not a distant abstraction. Decisions regarding packaging, production lines, suppliers, contracts and product designs often have repercussions for many years to come. If a company invests in a new packaging line today, it should assess whether this investment will comply not only with the requirements for 2026, but also with the direction of change up to 2030 and 2040.

That is precisely why the PPWR must be integrated with the circular economy strategy. You can read more about this approach in the EKOPRO section on circular economy.

How should a company plan its transition to PPWR?

Preparation for the PPWR should be carried out in stages. It is not a matter of haphazardly replacing all packaging, but rather a controlled process of risk assessment and implementing changes.

Stage 1: inventory of packaging

The company should compile a complete list of unit, bulk, transport and dispatch packaging. For each type of packaging, the material, weight, supplier, intended use, target market and documents confirming the composition must be specified.

Stage 2: PPWR risk assessment

Not every type of packaging will pose the same risk. Priority should be given to checking plastic packaging, multi-material packaging, laminated packaging, overly complex packaging, packaging sold in several EU markets, and packaging bearing environmental claims.

Stage 3: analysis of the documentation

Suppliers should provide specifications, declarations, data on material composition, and information on recycled content and substances of concern. The absence of documentation does not always indicate non-compliance, but it does indicate a lack of readiness to provide such evidence.

Stage 4: Plan for changes up to 2026 and 2030.

The company should distinguish between urgent and strategic actions. Some issues need to be resolved by 12 August 2026, whilst others need to be planned with a view to meeting the requirements for 2030 and beyond.

Stage 5: ongoing monitoring of changes

The PPWR will be supplemented by implementing acts, guidelines and the practices of the competent authorities. The compliance strategy should therefore be kept up to date. A one-off review of packaging may not be sufficient if a company regularly launches new products or changes suppliers.

A good approach is to combine a packaging audit with a broader environmental audit, which allows you to monitor not only the packaging itself, but also the flow of documents, waste, and registration and reporting obligations.

PPWR in Poland – do we need to wait for national regulations?

No. The PPWR is an EU regulation, so it does not operate in the same way as a directive, which requires full transposition into national law. Companies in Poland should prepare to comply with it regardless of what the specific national implementing regulations, sanctions or the authorities’ practice may be.

This does not, however, mean that Polish obligations are no longer relevant. It is still necessary to analyse BDO, waste records, reporting, fees, and product and packaging obligations. The PPWR adds a layer of EU requirements concerning the packaging itself.

If a company wishes to get its affairs in order in Poland and the EU, a good starting point is comprehensive environmental consulting for companies, including an analysis of legislation, documentation, registers and environmental risks.

The most common mistakes companies make when planning PPWR

The first mistake is to assume that, simply because many of the requirements will not come into force until 2030, the issue can be put on hold. This is risky, as changing packaging requires testing, liaising with suppliers, design changes, updating labels and, often, renegotiating contracts.

The second mistake is to analyse only individual packaging. PPWR also covers collective, transport and dispatch packaging, which account for significant volumes in many companies.

The third mistake is the lack of data on weights and materials. Without this data, it is impossible to assess recyclability, recycled content, reporting obligations or costs.

The fourth mistake is separating the PPWR from overseas sales. A company selling to Germany, France, the Czech Republic or other EU countries must integrate the PPWR with local packaging systems.

The fifth mistake is treating environmental claims as marketing communications rather than evidence-based statements. Any claim regarding recycling, recycled content or the „eco-friendly” nature of packaging should be supported by documentation.

FAQ – frequently asked questions about the PPWR timetable

Since when has the PPWR been in force?

The PPWR came into force on 11 February 2025, but most of its provisions will generally apply from 12 August 2026. This means that companies should use the transition period to assess their packaging, documentation and processes.

Does the PPWR come into force immediately in Poland?

Yes, as an EU regulation, the PPWR will be directly applicable in Poland. National legislation will continue to apply in relation to supervision, sanctions, data protection officers and other administrative obligations, but the EU regulation itself does not require traditional transposition in the same way as a directive.

Is 2030 the most important date in the PPWR?

The year 2030 is one of the most important milestones, as it involves requirements relating to recyclability, recycled content, reducing single-use packaging and minimising packaging. However, preparations should begin earlier.

What should companies do before 12 August 2026?

Before 12 August 2026, companies should carry out an inventory of packaging, gather documentation from suppliers, assess PPWR risks, check their obligations in EU markets and plan the changes that will be required by 2030.

Does the PPWR apply to e-commerce?

Yes. Online shops use shipping packaging such as cardboard boxes, envelopes, plastic film, tape, labels and packing materials. If they sell abroad, they must also analyse local packaging schemes, such as LUCID in Germany.

Does the PPWR audit need to be carried out right now?

Yes, if a company places packaged products on the EU market, uses various types of packaging, operates an e-commerce business, imports goods or sells abroad. A prior audit helps to avoid costly last-minute changes.

Discuss your strategy for transitioning to PPWR

The PPWR timetable shows that companies do not have a single deadline, but rather several implementation phases. The nearest milestone is 12 August 2026, but strategic decisions must be made with 2030, 2035 and 2040 in mind.

If you want to find out which PPWR dates are relevant to your business, consult the PPWR transition strategy and select EKOPRO technical consultancy. You could also start by PPWR audit or go directly to the tab Contact Eko-Pro, to describe your situation.