Packaging and Packaging Waste Regulation (PPWR)
Authors I Katarina Čepon and Zala Rom
On 12 August 2026, most of the requirements of Regulation (EU) 2025/40 on packaging and packaging waste (PPWR)¹ will apply. The PPWR governs the entire life cycle of packaging and packaging waste, from the manufacture of packaging through to the management of packaging waste. As an EU regulation, it applies directly throughout the EU. Its principal objectives are to reduce the amount of packaging and packaging waste and to increase the re-use, collection and recycling of packaging.
Scope and Obliged Parties
The PPWR applies to all packaging, regardless of the material used, and to all packaging waste generated or used in industry, other manufacturing, retail or distribution, offices, services or households. Production residues are not regarded as packaging waste. The PPWR applies to a broad range of economic operators, imposing obligations primarily on manufacturers, importers and distributors, but also on fulfilment service providers and suppliers.
Obligations of Manufacturers, Importers and Distributors
The manufacturer of packaging or of a packaged product bears primary responsibility for the conformity of the packaging. In particular, the manufacturer must:
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Where packaging is imported from third countries, the importer must verify that the manufacturer has carried out the appropriate conformity assessment procedure, prepared the technical documentation and provided the required labelling and information.
The distributor must verify that the obligations of the manufacturer or importer have been fulfilled, particularly those relating to labelling and the overall conformity of the packaging.
Registration and Reporting
Producers, importers or distributors that make packaged products available on the EU market must register in the national register of each Member State in which they make packaging or packaged products available for the first time, or in which they unpack packaged products without being end users. They must also report regularly on the quantities and types of packaging concerned.
Sustainable Packaging Design Requirements
The PPWR places significant emphasis on sustainable packaging design, the use of recycled materials and the effective management of packaging waste.
All packaging must be recyclable. Under the PPWR, packaging is considered recyclable if it is designed for material recycling and, once it becomes waste, can be collected separately, sorted into specific waste streams and recycled at scale. These requirements will be phased in progressively.
For plastic packaging, the PPWR sets minimum recycled-content requirements that vary according to the type of packaging. By 2030, plastic packaging will have to contain between 10% and 35% recycled content, and by 2040 between 25% and 65%. For example, single-use beverage bottles will have to contain at least 30% recycled content by 2030 and 65% by 2040.
By 12 February 2028, certain types of packaging must be suitable for industrial composting, while Member States may also require suitability for home composting. This mainly concerns packaging from which the contents are particularly difficult to separate, such beverage bags and labels affixed to fruit and vegetables.
To prevent excessive packaging, manufacturers and importers must reduce the weight and volume of packaging to the minimum necessary to ensure its functionality. Packaging features whose sole purpose is to increase the perceived volume of a product, such as false bottoms, are also prohibited. For certain types of packaging, the empty-space ratio must not exceed 50%. Compliance with this requirement must be ensured by the economic operators that fill the packaging.
In addition, from 1 January 2030, the PPWR will restrict the placing on the market of certain single-use packaging formats. These include, among others, single-use plastic packaging for fresh fruit and vegetables, packaging for food and beverages filled and consumed in restaurants, and miniature packaging for toiletries commonly found in hotels. Restaurants offering takeout will have to give consumers the option of reusable packaging by 12 February 2028 and, from 2030, endeavour to offer 10% of their products in it.
Packaging Labelling
From 12 August 2028, the PPWR will introduce clear and harmonised packaging-labelling requirements designed to help consumers sort waste correctly. The pictogram-based labelling must provide information on the material composition of the packaging. The PPWR also permits the use of digital solutions, such as QR codes, to provide additional information on sorting, recycled content or re-use.
Restrictions on Hazardous Substances
The PPWR retains restrictions on the concentrations of lead, cadmium, mercury and hexavalent chromium. It also introduces additional restrictions on per- and polyfluoroalkyl substances (PFAS) in food-contact packaging.
Packaging Collection, Return and Deposit-Return Systems
Member States are required to establish separate collection, return and deposit- return systems for certain types of packaging. The PPWR strengthens the principle of extended producer responsibility, under which producers must bear the financial and operational costs of collecting, recycling and managing packaging waste. Every undertaking must register with the national waste-management system and provide detailed information on the quantity of packaging placed on the market, its composition and its method of disposal. This information must be reported to the competent authorities and, upon request, made available to consumers. Slovenia has not yet established these systems.
Draft Regulation Implementing the PPWR in Slovenia
On 23 July 2026, the Ministry of the Environment and Spatial Planning published the draft Regulation on Common Rules for the Implementation of Extended Producer Responsibility Schemes and on the Implementation of the EU Packaging and Packaging Waste Regulation.² The key features of the proposed Slovenian framework are summarised below. As the regulation is still in draft form, its provisions may change before final adoption.
As the PPWR applies directly in all EU Member States, the draft Slovenian regulation focuses mainly on the national measures required to ensure its effective implementation, supervision and enforcement. It designates the competent authorities, defines the responsibilities of the relevant parties and lays down rules on monitoring, record-keeping, reporting, offences and penalties. In particular, the draft regulation:
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In Slovenia, the main obligations of producers under the extended producer responsibility framework are already laid down in the Environmental Protection Act (ZVO-2). These include ensuring the collection and treatment of waste generated from their products, meeting the prescribed environmental targets, providing information to the public and waste holders, supplying the necessary information to waste treatment operators, keeping records and reporting to the competent ministry.
Conclusion
The PPWR marks an important step towards a more harmonised and stringent approach to packaging across the EU. Although the European Union has pursued the objectives of a »Green Europe« for many years, packaging management remains a significant challenge. The PPWR therefore intervenes at an early stage, beginning with the manufacture of packaging, and requires economic operators to adapt their processes in a timely manner.
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¹ Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R0040.
² https://e-uprava.gov.si/si/drzava-in-druzba/e-demokracija/predlogi-predpisov/predlog-predpisa.html?id=19195&lang=si
³ Zakon o varstvu okolja, Official Gazette of the Republic of Slovenia, Nos. 44/22, 18/23 – ZDU-1O, 78/23 – ZUNPEOVE, 23/24, 21/25 – ZOPVOOV, 56/25 – PoZ, and 11/26 – Constitutional Court Decision: https://pisrs.si/pregledPredpisa?id=ZAKO8286.
