PPWR -
Packaging and Packaging Waste Regulation

The Regulation entered into force on 11 February 2025, and its application will begin gradually from 12 August 2026.

Please note that on Sumi’s website, the PPWR is primarily addressed from the perspective of extended producer responsibility (EPR) for packaging.

REGULATION (EU) 2025/40 on Packaging and packaging waste (PPWR)

Guidance Document for PPWR

PPWR - Packaging and Packaging Waste Regulation

The PPWR (Packaging and Packaging Waste Regulation) is a European Union regulation aimed at reducing packaging waste, improving recyclability of packaging, and promoting circular economy across the EU. The Regulation introduces stricter and harmonised obligations for all market operators.

As an EU regulation, the PPWR is directly applicable in all EU Member States and takes precedence over national packaging legislation.

Key Objectives of the PPWR

Reduce the amount of packaging waste
Ensure that all packaging is recyclable or reusable by 2030
Increase the use of recycled materials, particularly in plastic packaging
Reduce harmful chemicals in packaging
Harmonise the EU internal market

The Regulation entered into force on 11 February 2025, with its provisions applying gradually from 12 August 2026.

Branded packaging

If a company has packaging or a packaged product manufactured under its own name or trademark, the company is considered the manufacturer and will therefore be responsible for extended producer responsibility and reporting obligations for such branded packaging.

In these cases, producer responsibility will transfer from one operator to another as of 12 August 2026.

Transport packaging

For transport packaging, the producer responsible will be the manufacturer, importer, or distributor of the packaging. Previously, the responsibility typically rested with the packer or importer.

In these cases, producer responsibility will transfer from one operator to another as of 12 August 2026.

New packaging types subject to reporting

Tea bags and coffee capsules used in coffee machines will be classified as packaging and will fall within the scope of extended producer responsibility. Consequently, they must be reported.

From 12 August 2026, tea bags and coffee capsules will be reported in SumiOn under the category “Other materials.”

Authorised Representative for Distance Sellers

A distance seller must appoint an authorised representative when it is a producer established in one Member State and makes products available directly to end users in another Member State. This requirement does not apply to producers established outside the EU unless specified by national legislation.

Note: On 10 December, the European Commission published a proposal (the so-called Omnibus legislative package) suggesting that the appointment of an authorised representative would not, for the time being, become mandatory for distance sales to end users inside EU.

Restricted substances in packaging

Heavy metals: Lead (Pb), Hexavalent Chromium (Cr⁶⁺), Cadmium (Cd), and Mercury (Hg) are prohibited in all packaging and PFAS compounds restricted in food contact packaging.

Food contact packaging placed on the market after 12 August 2026 must comply with PFAS limit values. Packaging placed on the market before this date may remain on the market and does not need to be withdrawn.

Compliance requirement

Manufacturers will be required to provide a Declaration of Conformity for packaging concerning PFAS compounds and heavy metals. The declaration must include identification details such as the type, batch, serial number, or other equivalent information enabling traceability.

These requirements will apply from 12 August 2026, with additional requirements expected in the future.

PPWR in practice
-webinar (in Finnish)

May 19, 9:30–11:00

Welcome to the “PPWR in practice” webinar, where we will go through the changes introduced by PPWR in a practical way from the perspective of packaging producer responsibility.

In addition to Sumi’s own experts, the webinar will feature experts from Tukes, Marita Hiipakka and Tiia Salamäki.

Participants will also have the opportunity to ask questions directly to the experts during the webinar.

PPWR - Packaging and Packaging Waste Regulation ​