PPWR Regulation – New Rules for Packaging

The PPWR (Packaging and Packaging Waste Regulation) is the European Union’s new packaging legislation, which entered into force on 11 February 2025 and will become fully applicable across the EU from 12 August 2026. The Regulation replaces the previous packaging framework established by the 1994 Packaging and Packaging Waste Directive (PPWD) with a directly applicable legal act containing harmonised requirements for all Member States.

The PPWR (Packaging and Packaging Waste Regulation), the European Union’s new packaging legislation, must be fully applied from 12 August 2026

Regulation (EU) 2025/40 on packaging and packaging waste (“PPWR Regulation”) significantly reshapes packaging practices and has major implications for restaurants, cafeterias, and other food service establishments that sell takeaway food and beverages in plastic containers and cups. These single-use products account for nearly 40% of the approximately 25 million tonnes of plastic packaging waste generated annually in the EU, while only about 30% is currently recycled and returned to the circular economy.

EU Member States are required to reduce per capita packaging waste by 5% by 2030, 10% by 2035, and 15% by 2040, compared to 2018 levels. According to estimates, these measures could reduce packaging waste by approximately 37% compared to the 2040 baseline scenario.From 1 January 2030, economic operators using transport packaging (e.g. boxes, pallets, and wrapping films) must ensure that at least 40% of such packaging is reusable within a reuse system. From 1 January 2040, they will be expected to increase this share to at least 70%.

Economic operators using the transport or consumer packaging listed in the Regulation for the transportation of goods between facilities must ensure that such packaging is reusable within a reuse system. This requirement also applies to transport between a company’s own facilities, affiliated companies, and business partners.

How Will the PPWR Affect Hungarian Businesses?

The Regulation applies to all market participants that manufacture, distribute, or import packaging within the European Union. Consequently, it will have a significant impact on Hungarian businesses as well.

• The introduction of the Extended Producer Responsibility (EPR) fee and the Deposit Return System (DRS) represented the first steps towards compliance with these requirements.
• Logistics processes will change: Businesses will need to organize the return, reuse, and traceability of packaging used in transportation between facilities.
• Phase-out of certain packaging types: Some single-use plastic packaging solutions (e.g. certain grouped packaging formats, some takeaway food containers, and very lightweight carrier bags) will no longer be permitted from 2030 onwards, making it necessary to identify alternative solutions.

From 12 August 2026, food-contact packaging materials may no longer be placed on the market if they contain PFAS (per- and polyfluoroalkyl substances) at or above the following thresholds:

• Single PFAS Substance: If the concentration of any individual PFAS substance exceeds 25 ppb (parts per billion; 25 units per billion units), the packaging may not be placed on the market. (Polymeric PFAS are excluded from this calculation.)
• Total PFAS Concentration: If the combined concentration of all PFAS substances exceeds 250 ppb, the packaging is likewise prohibited from being marketed. (Again, only non-polymeric PFAS substances are taken into account.)
• Total PFAS Including Polymers: If the total concentration of all PFAS substances, including polymeric PFAS, exceeds 50 ppm, the packaging is not permitted. (In this case, polymeric PFAS are included in the calculation.)

In addition, if the total fluorine content of packaging exceeds 50 mg/kg, the manufacturer, importer, or user must, upon request, demonstrate the form in which the fluorine is present (whether as PFAS or another substance). This requirement enables the party placing the packaging on the market to prepare the necessary technical documentation.

Impact on EPR Fees

The PPWR introduces a new conceptual framework (including definitions such as producer, manufacturer, and end user) and applies a harmonised EU methodology. As a result, changes may occur both in determining the party responsible for EPR obligations and in defining the scope of the EPR fee.

Several changes can therefore be expected:

• Obligations under EPR legislation and under the PPWR may not necessarily fall on the same economic operator.
• Even empty packaging materials may become subject to EPR obligations.
• Due to the clarification of the concept of the end user, companies that unpack imported products for their own use may no longer qualify as EPR-obligated entities in the future.

In light of these developments, businesses should consider packaging compliance and EPR obligations as interconnected elements of a single regulatory framework established by the PPWR, rather than managing them separately.

What Should Businesses Do Now?

To comply with the requirements applicable from 12 August 2026, affected businesses should review in advance whether the packaging they use must be demonstrated to comply with the Regulation. They should also undertake the necessary technical assessments and documentation preparations required to prove compliance.