The European Union has announced that Regulation (EU) 2025/40 or the new Packaging and Packaging Waste Regulation (PPWR), entered into force on 11 February 2025. This regulation replaces Directive 94/62/EC on packaging and packaging waste and aligns with the EU’s Circular Economy Action Plan.
The new regulation harmonizes the current packaging laws of the various EU Member States while simultaneously mitigating and preventing the adverse effects of packaging and packaging waste on human health and the environment. The primary objective of the regulation is to prevent and reduce packaging waste by promoting more reuse and refill systems. It seeks to make all packaging on the EU market recyclable in an economically viable way by 2030. Additionally, the regulation aims to safely increase the use of recycled plastics in packaging, phase out hazardous and harmful substances such as per- and polyfluoroalkyl substances (PFAS), promote re-use, and decrease the use of virgin materials, ultimately putting the sector on track to achieve climate neutrality by 2050.
The PPWR will be applicable from 12 August 2026, allowing stakeholders an 18-month transition period to adhere to the new regulations. The full implementation will be rolled out over the next fifteen (15) years.
The key dates that Philippine exporters should take note of are as follows:
| Date | Obligation |
| 12 Aug 2026 | Full application of PPWR requirements (18 months post-entry into force) |
| 01 Jan 2028 | European Commission to establish specific criteria and methodologies related to packaging |
| 01 Jan 2030 | All packaging sold in the EU must be recyclable, with minimum recycled content requirements for plastics. Packaging may only be placed on the market if it is recyclable according to grades A (higher or equal to 95% recyclability) or C (higher or equal to 70% recyclability). Recyclability of lower than 70%, the packaging will be considered technically non-recyclable, and its placing on the market will be restricted. |
| 01 Jan 2030 | Reusable packaging should be exclusively used for transport packaging between different sites of the same business or between different businesses within the same EU country. For other types of transport packaging, including e-commerce, at least 40% should be reusable by 2030, increasing to at least 70% by 2040. Grouped packaging, which is used to group sales units together, must have at least 10% reusable packaging by 2030 and at least 25% by 2040. For alcoholic and non-alcoholic drinks, excluding milk, wine, and some spirits, at least 10% of the packaging should be reusable by 2030, with this figure rising to at least 40% by 2040. Cardboard packaging is excluded from all reuse targets. |
| 01 Jan 2035 | Packaging must be recycled-at-scale, meaning widely collected and recycled across the EU. “At scale” means annual quantity of recycled material equal or greater than 55%, or 30% in the case of wood. |
| 01 Jan 2038 | Packaging may only be placed on the market if it meets higher recyclability grades (A or B). |
| 01 Jan 2040 | Increased recycled content requirements for plastic packaging |
Below are the salient provisions of the PPWR:
Article 1: Subject matter
Specifies the requirements for the entire life cycle of packaging in relation to environmental sustainability, labeling, extended producer responsibility, and the prevention of packaging waste.
Article 5: Requirements for substances in packaging
Product packaging must contain no or few harmful substances, applying to both the packaging material and its components, such as prints or writings. Harmful substances in packaging and disposal waste (recycled materials, ash, or other waste products) should be minimized to reduce environmental impact throughout the packaging’s life cycle. The PPWR restricts the use of PFAS in food contact packaging materials from 12 August 2026, with concentration limits set at 25 ppb for targeted PFAS, 250 ppb for the sum of targeted PFAS with prior degradation precursors, and 50 ppm for PFAS (including polymeric PFAS), along with information communication obligations on fluorine quantity. Additionally, the sum of the concentrations of lead, cadmium, mercury, and hexavalent chromium in packaging or packaging components must not exceed 100 mg/kg.
Article 6: Recyclable packaging
All packaging placed on the market shall be recyclable with several derogations to be reviewed by 01 January 2035. Packaging shall be considered recyclable: 1) if it is designed for material recycling, which enables the use of resulting secondary raw materials that are of sufficient quality when compared to the original material that they can be used to substitute primary raw materials; and 2) when it becomes waste, it can be collected separately, sorted into specific waste streams without affecting the recyclability of other waste streams and recycled at scale.
The packaging of medical products and devices, veterinary products, infant formula and foods, and dangerous hazardous goods is not subject to these requirements. It also does not apply to smaller packaging materials, such as wood, cork, textile, rubber, ceramic, porcelain, or wax.
Article 7: Minimum recycled content in plastic packaging
By 01 January 2030, any plastic part of packaging shall contain the prescribed minimum percentage of recycled content recovered from post-consumer plastic waste, per packaging type, manufacturing plant, and year. Recycled materials must be from EU-collected post-consumer plastic waste or non-EU countries adhering to European waste collection and environmental standards.
Article 10: Packaging minimization
By 01 January 2030, only packaging that has been reduced to the required minimum necessary to ensure its functionality shall be allowed in the market. Prohibited are double walls, false bottoms, extra layers, so-called “cheat packaging,” etc.
Article 11: Reusable packaging
Packaging placed on the market from 11 February 2025, will only be considered reusable if it meets a set of defined conditions stipulated in the regulation.
Article 12: Labelling of Packaging
From 12 August 2028, packaging has to be marked with a yet to be established harmonized label containing information on its material composition to facilitate consumer sorting. The label shall be based on pictograms and be easily understandable, including for persons with disabilities.
Philippine exporters to EU are strongly advised to ensure that their packaging materials are recyclable, reusable, and have the necessary proportion of recycled content in order to comply with the new EU PPWR. Packaging weight and volume should be kept to a minimum, labels should be updated to reflect material composition and recycling guidelines, and hazardous materials such as PFAS, lead, cadmium, mercury, and hexavalent chromium should be checked to make sure they are within the allowed limits. Furthermore, exploring sustainable packaging options and comprehending compliance expectations may be substantially aided by careful coordination and collaboration with EU importers. Maintaining records to demonstrate compliance is recommended.
Further details of the new regulation can be accessed through this link: Regulation (EU) 2025/40.
For questions and clarifications, please contact Philippine Trade and Investment Center-Brussels at brussels@dti.gov.ph and/or the DTI-EMB Market Innovation Division at mid@dti.gov.ph. ♦
Date of release: 03 Mar 2025
