The PPWR and its impact on producers
The main purpose of PPWR is to create harmonised legislation in all EU Member States to meet the targets for reducing packaging waste, increasing circularity and promoting the EU internal market.
For you as a producer, the regulation means new and more extensive requirements for your packaging. Among other things, there will be higher requirements for recyclability, the proportion of recycled material in packaging and requirements for reuse.
Important changes
The PPWR entered into force on 11 February 2025 and will be applied for the first time from 12 August 2026. Not all requirements will come into effect at the same time. The legislation applies to all packaging, regardless of the type of material.
Some important changes in the PPWR:
- Packaging waste must be reduced by 5 percent by 2030, 10 percent by 2035 and 15 percent by 2040 – compared to 2018.
- All packaging must be recycled to 55 percent by 31 December 2035.
- Packaging must be considered recyclable only when it is designed for recycling, and can be collected, sorted and recycled on a larger scale.
- Requirement for recycled material in new packaging.
- Clear labelling of packaging to facilitate source separation.
- Certain packaging will be banned.
Milestones in the coming years
PPWR will be implemented gradually in the coming years, we listed some of the most important requirements and changes.
Introduced from August 12, 2026
- New definition of producers
Introduced from August 12, 2028
- Requirements for packaging labeling
Introduced in 2030
- New classification of material recyclability – class A-C. Packaging with less than 70% recycling rate will be banned. As a producer, you already need to familiarize yourself with which packaging is at risk of being banned in 2030.
- Minimum standards for packaging dimensions and empty spaces in packaging
- Requirements for the percentage of recycled content in plastic packaging
- Targets for reuse
- Targets for refilling refillable packaging
Introduced in 2035
- Assessment of recyclability based on packaging large-scale recyclability
Introduced in 2038
- Ban on packaging with class C recyclability
Introduced in 2040
- Increased requirements for recycled content in packaging
- Increased recycling targets
New EU Requirements for Packaging Labelling
The EU’s new Packaging and Packaging Waste Regulation (PPWR) introduces stricter requirements for the labelling of packaging. Harmonised sorting labels will be implemented across the entire EU. The approval process for the proposed labels is currently underway.
PPWR introduces (in Article 12) new harmonised sorting labels for all packaging placed on the European market. The goal is a common labelling system that makes it easier for consumers to sort packaging correctly, based on the material from which the packaging is made.
This means that today’s Nordic packaging labels must be replaced with new common European labels over the coming years.
According to the plan, the harmonised labelling requirements will apply from 12 August 2028. Packaging produced or imported into the EU before the deadline may be sold for up to three years.
The EU’s Joint Research Center (JRC) has developed proposals for the new packaging labels. Various drafts have been circulated for consultation among Member States and tested with consumers. In January, the JRC submitted its final proposal to the European Commission, which will prepare an implementing act.
The final proposal for the labels will be presented in the implementing act, and changes may occur compared with the JRC’s proposal. The act must be reviewed and approved by a committee of representatives from EU Member States. The goal is to finalise the process by 12 August 2026, which means the labelling requirement would apply 24 months later, i.e., on 12 August 2028. If the process is delayed, the deadline will also shift.
The proposed labelling system is largely inspired by the existing Nordic sorting labels but with some changes to visual design and colour usage.
NPA recommends that our affiliated producers continue using the symbols from the Nordic signage system to label packaging until the European Commission has adopted a decision on the new labelling.
PPWR regulates sorting labels for packaging. The same symbols will also be used on waste containers and collection systems, but these follow separate timelines and requirements. Since PPWR only applies to packaging, today’s waste labels for the collection of other waste types will not be covered by the new requirements.
In addition to the labels themselves, there will be requirements regarding size, text, and colour usage. As today, the use of colours is recommended, but flexibility for black and white versions is being discussed.
From 12 February 2027, the Green Dot symbol may only be used within a QR code or an equivalent digital solution that clearly explains producer responsibility.
The Green Dot is a financing symbol administered by PRO Europe, showing that a company has fulfilled its legally required producer responsibility for packaging. It is a collective trademark and voluntary to use. It has historically been recommended to signal that companies take financial responsibility for recycling but is not a requirement.
However, studies show that many interpret the symbol as an indicator of recyclability. PPWR therefore requires that labels indicating that a company has fulfilled its producer responsibility, if used, must be clear and unambiguous, and may only be displayed through a QR code or similar open digital marker.
PRO Europe is working on an updated version of the Green Dot that will meet the new requirements while also providing sorting information to consumers. The proposal is not yet final.
As a member of PRO Europe and license holder in Sweden, NPA will share their final proposal with our affiliated producers as soon as it becomes available.
NPA’s interpretation is that the requirement applies to packaging or packaged products made available for the first time on the European market after 12 February 2027.
As NPA interprets it, packaging or packaged products placed on the European market before 12 February 2027 will be exempt from the requirement.
From 12 August 2026:
- Packaging must be marked with an article number.
- Packaging must be marked with contact information.
- Packaging may not be labelled with tags, symbols, or similar that risk misleading or confusing consumers or other end users regarding the packaging’s sustainability characteristics, other packaging properties, or how the packaging waste should be handled.
From 12 February 2027, it is voluntary to label packaging covered by extended producer responsibility schemes. If labelling is used – for example, the Green Dot – it may only appear as a symbol within a QR code. It is no longer permitted to use a separately printed symbol to show that a fee has been paid to a PRO. The symbol must be clear and unambiguous and must not mislead consumers regarding recyclability or reusability.
From 12 August 2028 (or 24 months from the adoption of relevant implementing acts), additional requirements will apply regarding harmonised sorting instructions. These requirements apply to all packaging types except transport packaging.Transport packaging used in e commerce is included in the requirement and must be labelled.
From 12 August 2028 (or 24 months from the adoption of relevant implementing acts), additional requirements will also apply regarding labelling of substances of concern. This requirement applies to all packaging types.
PPWR also contains additional labelling requirements:
- Packaging containing hazardous substances must be labelled with a standardised digital data carrier, for example a QR code.
- Packaging included in deposit systems must have a clear label showing this by 1 January 2029.
- Compostable packaging must be labelled as compostable by 12 August 2028 (with a three year transition period).
- Reusable packaging must be labelled so that it is clearly distinguishable from single use packaging from 12 February 2029.
PPWR also opens the possibility for harmonised labelling of recycled and bio based content in packaging. Proposals are being developed but have not yet been submitted to the Commission.
Labelling of bio based or recycled content is voluntary, but if companies choose to communicate this they must, from 12 August 2028 (or 24 months from the adoption of relevant implementing acts) use the harmonised labels.
Support
Support for our producers
We offer advice and support related to PPWR and are actively working to produce verified answers to questions related to upcoming requirements. We continue to offer support by services related to design for recycling and packaging minimization.
The requirements in PPWR apply to both producer responsibility organizations and producers and we are continuously working to offer you a relevant customer support going forward. At present, we do not have answers to all questions, but you are always welcome to contact us.
As a customer at NPA, you have access to our overview introduction to PPWR. If you have not already received it, you are welcome to contact your account manager or producer service at producer@npa.se
In the spring of 2024, we produced a short information film where we review the goals of PPWR and summarize what the main changes will be and when they will be introduced.
The Swedish Environmental Protection Agency’s guidance
The Swedish Environmental Protection Agency is responsible for guiding producers and producer responsibility organizations in the new legislation and has produced guidance for PPWR.
The Swedish Environmental Protection Agency’s guidance to PPWR (in Swedish)
Frequently asked questions
PPWR stands for Packaging and Packaging Waste Regulation and is a new EU regulation that replaces the previous directive on packaging and packaging waste. The aim of the PPWR is to establish a coherent regulatory framework across the EU to achieve the objectives of reducing packaging waste, increasing circularity, and promoting the internal market of EU. The PPWR requires producers to ensure that packaging is recyclable, and that waste management is efficient.
All companies that place packaging on the EU market – whether they are manufacturers, importers, or distributors – are covered by the regulations. This also applies to e-commerce businesses and brand owners.
The Regulation contains a new definition of producers. As a general rule, the producer is the economic operator who, as a manufacturer, importer or distributor established in a Member State, makes packaging or packaged products available for the first time from the territory of that Member State and on the same territory. The aim of the new producer definition is that only one company should be the producer for a single packaging unit.
The PPWR applies to all packaging and packaging waste, regardless of the material used and regardless of whether the packaging waste has been used in or comes from, for example, industry, other manufacturing, households, or retail.
The PPWR is a comprehensive set of regulations with many requirements, some of which we already fulfil in Sweden, for example through a widespread return and deposit system. The new requirements added by PPWR are mainly requirements for the recyclability of packaging through design for recycling, minimization of packaging material, recycled material in packaging, labelling, re-use and refilling of packaging and environmental claims on packaging. Furthermore, the Regulation contains some explicit prohibitions.
Packaging can only be placed on the market if it fulfils the requirements set out in the Regulation.
Further information can be found in the document ‘A brief introduction to the PPWR’, which is available to you as a customer. You are also welcome to contact us for advice.
The PPWR will apply from 12 August 2026. Some of the provisions will not take effect until the following years. Below, we outline some of the key requirements and changes.
Introduced on 12 August 2026:
- New definition of producers
Introduced on 12 August 2028:
- Labelling requirements for packaging
Introduced in 2030
- New classification of material recyclability – class A-C. Packaging with less than 70% recycling rate will be banned. As a producer, you already need to familiarize yourself with which packaging is at risk of being banned in 2030.
- Minimum standards for packaging dimensions and empty spaces in packaging
- Requirements for the percentage of recycled content in plastic packaging
- Targets for reuse
- Targets for refilling refillable packaging
Introduced in 2035
- Assessment of recyclability based on packaging large-scale recyclability
Introduced in 2038
- Ban on packaging with class C recyclability
Introduced in 2040
- Increased requirements for recycled content in packaging
- Increased recycling targets
Further information can be found in the document ‘A brief introduction to the PPWR’, which is available to you as a customer. You are also welcome to contact us for advice.
