PPWR deadlines 2026 to 2040: which obligation applies when, and which dates can still move

In brief

The PPWR does not have one deadline; it has around forty. The general date of application was 12 August 2026; since then substance restrictions, conformity assessment, the declaration of conformity and the obligations of economic operators apply. Most design requirements only take effect on 1 January 2030, the last stages in 2038 and 2040.

Three kinds of dates need to be told apart. Fixed dates are written into the Regulation and do not move: 12 February 2027, 12 February 2028, 1 January 2030 for bans and minimisation, 1 January 2038. Movable dates are tied to Commission acts and apply "at the earliest": harmonised labelling from 12 August 2028, recyclability grades and minimum recycled content from 1 January 2030. And Member State deadlines such as deposit systems by 1 January 2029 reach companies only through national law.

The most important movable date has already moved: the implementing act on labelling was due by 12 August 2026 and was still outstanding at the editorial deadline. The 24-month period only starts on its entry into force, so the label will not arrive before autumn 2028.

For Germany the dates of the Packaging Law Implementation Act come on top: LUCID registration for newly obliged producers by 12 September 2026, data updates by 12 November 2026, old scheme contracts until 31 December 2026 at the latest.

Anyone who takes the timeline into their planning needs three year marks: 2026 for documentation and registers, 2027 for digital symbols and hospitality, 2030 for everything that changes the packaging itself.

Why the PPWR has no single deadline but a timeline

Regulation (EU) 2025/40 entered into force on 11 February 2025 and has applied since 12 August 2026 under Article 71. Anyone who knows only those two dates plans wrongly, because the Regulation works with three deadline mechanics, and each calls for a different reaction.

Fixed dates. They appear with a date in the text and depend on nothing: the ban on the packaging formats in Annex V from 1 January 2030, compostability for tea bags and fruit stickers from 12 February 2028, grades A and B as the minimum from 1 January 2038. There is no deferral for these dates, because there is nothing that could be delayed.

Movable dates. The Regulation ties many requirements to a delegated or implementing act of the Commission and phrases it as: from date X or from Y months after the act enters into force, "whichever is the later". The date is therefore an earliest date. If the Commission keeps its own deadline, the date applies; if it is late, the obligation shifts by exactly the delay. Harmonised labelling, the recyclability grades, minimum recycled content, the empty-space ratio and the reuse targets all work this way.

Member State deadlines. Recycling targets, waste prevention, deposit systems, penalty rules and producer registers are addressed to the Member States. They reach companies only once national law implements them, in Germany through the Packaging Law Implementation Act (VerpackDG) and the Central Agency Packaging Register.

Added to this are transitional and sell-off rules that soften individual dates for existing stock, and exemptions for micro-enterprises, medicines, medical devices, infant formula and dangerous goods. The Commission's simplification proposal of 10 December 2025 has so far changed none of these dates; the date of application was not postponed, and no postponement has been decided for the later dates.

2025: entry into force with quiet advance effect

On 22 January 2025 the Regulation appeared in the Official Journal, on 11 February 2025 it entered into force. For most companies nothing changed that day. Two advance effects still matter.

First, the criteria for reusable packaging under Article 11 apply to everything placed on the market from 11 February 2025. Authorities have been able to check that since 12 August 2026; reusable packaging from before that date is exempt from corrective action, withdrawal and recall under Article 15(9) and may stay in circulation until it is technically spent.

Second, the Commission started work on around twenty legal acts whose deadlines are spread across 2026 to 2030. They are the reason the second half of the timeline is in motion.

By 31 December 2025 the first recycling target for the Member States also applied: 65 percent of all packaging waste by weight, with material rates from 50 percent for plastics to 75 percent for paper and cardboard. That is a state obligation, not a company deadline, but it feeds back through the fees of the compliance schemes.

2026: the date of application on 12 August

Since 12 August 2026 the Regulation applies directly in all Member States. Directive 94/62/EC is repealed as of that day; in Germany the Packaging Law Implementation Act has replaced the Packaging Act. What applies since that day is described in detail in PPWR obligations 2026; for the timeline what counts is which of it is fixed in time.

Substance requirements under Article 5. Lead, cadmium, mercury and hexavalent chromium together must not exceed 100 mg/kg. Food-contact packaging may contain PFAS only up to 25 ppb per single substance, 250 ppb in total and 50 ppm for all PFAS including polymeric ones. There is no sell-off period for these limits: the Commission has clarified in its guidance that packaging placed on the market after 12 August 2026 must comply with the values even if it was manufactured before. Stock with PFAS coatings that was still in the warehouse on 11 August has not been marketable since. Details in PFAS and heavy metals.

Conformity assessment, technical documentation and declaration of conformity. The producer assesses every packaging under Module A of Annex VII, draws up the technical documentation and issues the EU declaration of conformity under Annex VIII before placing it on the market. Both are to be kept for five years from the day of placing on the market, ten years for reusable packaging. The declaration refers only to requirements that apply at the time of placing on the market; it does not anticipate 2030. What it looks like is in Declaration of conformity.

Obligations of economic operators. Producers, suppliers, importers, distributors and fulfilment service providers have had the obligations of Articles 15 to 22 since 12 August 2026, including identification and contact details on the packaging, verification duties of importers and distributors and the own-brand rule of Article 21. Who holds which role is settled in Producer or manufacturer.

Reuse systems and refill. Anyone placing reusable packaging on the market must demonstrate a reuse system under Annex VI since 12 August 2026. Anyone offering refill informs end users about containers and hygiene.

Ban on misleading labels. Labels that could mislead about recyclability, recycled content, compostability or reusability have been prohibited since the date of application (Article 12(8)). It is the only labelling rule that already applies.

What expressly did not arrive on 12 August 2026 deserves its own paragraph, because these are the most common misconceptions: no harmonised sorting label, no QR-code obligation, no recyclability grades, no minimum recycled content, no 50 percent empty-space ratio for transport packaging and no format bans. All of that sits on the timeline between 2028 and 2030.

The German dates in 2026. The Packaging Law Implementation Act (BGBl. I No. 207 of 17 July 2026) essentially entered into force on 12 August 2026. Anyone registered in the LUCID register continues to count as registered. Three deadlines from Section 68 apply to all producers within the meaning of the Regulation:

• By 12 September 2026 producers must register that are obliged for the first time under the new law but were not under the old.
• By 12 November 2026 existing registrations must be supplemented with the new data.
• Until 31 December 2026 at the latest, scheme participation contracts under the old law continue; after that only the new regime applies.

What changed in detail compared with the Packaging Act is in VerpackG, VerpackDG and LUCID.

Commission deadlines in 2026. Two acts were due by 12 February 2026: the format for registration and reporting in the producer registers (Article 44(14)) and the standardisation request for compostable packaging (Article 9(6)). By 12 August 2026 the implementing act on harmonised labelling was to be adopted; more on that below. By 31 December 2026 the implementing act on calculating and verifying recycled content follows (Article 7(8)), on which the 2030 date for recycled content depends. The Commission also published its FAQ in March 2026 and expanded it in a second edition in July 2026; both are interpretive aids, not legal acts.

2027: digital symbols, hospitality, penalties

The year 2027 brings no new requirement for the packaging itself, but four dates with practical consequences.

12 February 2027: EPR symbols digital only. Under Article 12(9), labels indicating compliance with extended producer responsibility may from that day only be affixed as a symbol in a QR code or another open digital data carrier. For Germany this concerns the Green Dot and comparable scheme logos: no longer permitted in print, still permitted digitally. Anyone with print files carrying a participation logo should revise them before the date. More in Labelling obligations.

12 February 2027: customers' own containers in hospitality. Final distributors offering drinks or ready-prepared food to take away must under Article 32 provide a system in which consumers can have their own container filled, at the same price and with a visible notice at the point of sale. Micro-enterprises are not exempt from this; the exemption in Article 33(4) applies only to the reusable offer in 2028.

12 February 2027: Member States' penalty rules. By that day the Member States must adopt their penalty rules and notify them to the Commission (Article 68). Germany is already done with the fine provisions of Section 66 VerpackDG; fines therefore apply since 12 August 2026, not only from 2027.

Acts and institutions in 2027. By 12 February 2027 the Commission sets the minimum number of rotations for the most common reusable formats by delegated act (Article 11(2)) and establishes the European observatory on reuse (Article 31(7)). By 30 June 2027 the implementing act on calculating the reuse targets follows (Article 30(3)). For the producer registers: after the entry into force of the format act of February 2026 the Member States have eighteen months to convert their registers to the harmonised format, that is until the second half of 2027. Until then LUCID applies unchanged, and producers keep reporting under today's rules.

1 January 2027 in Germany. Section 5 VerpackDG enters into force: producers without an establishment in Germany must mandate an authorised representative for extended producer responsibility before they first make packaging or packaged products available; each producer may have only one representative, the mandate must be in writing and in German, and the registration itself remains strictly personal.

2028: compostability, reusable offer and the label that is still missing

1 January 2028: deadline for the recyclability criteria. By that day the Commission must adopt the delegated acts with the design-for-recycling criteria and the grades per packaging category (Article 6(4)). Whether the grades really apply on 1 January 2030 depends on this date: the Regulation names 1 January 2030 or 24 months after the acts enter into force, whichever is later. Every month the Commission is late shifts the grades by a month.

12 February 2028: compostability. Very lightweight plastic carrier bags, where Member States so require, as well as tea bags, coffee pods and stickers on fruit and vegetables must from that day comply with the standards for industrial composting (Article 9(1)). All other packaging made of biodegradable materials must from the same day be designed for material recycling (Article 9(3)). A fixed date with no reservation for a legal act.

12 February 2028: reusable offer in hospitality. Final distributors in the hospitality sector must also offer drinks and food to take away in reusable packaging within a reuse system, without surcharge and with a notice at the point of sale (Article 33). Micro-enterprises are exempt. From 2030 the endeavour obligation to offer 10 percent of products in reusables is added.

12 August 2028: harmonised labelling, at the earliest. Article 12(1) requires from 12 August 2028 or 24 months after the implementing act enters into force, whichever is later, a harmonised pictogram-based label on material composition on all packaging placed on the market, except transport packaging other than for e-commerce and packaging in deposit systems. The act was due by 12 August 2026 and was outstanding at the editorial deadline. The consequence is arithmetic: if it is published in autumn 2026, the label applies from autumn 2028; if it is only published in 2027, it applies in 2029. On the same date the indications of recycled and bio-based content are harmonised (Article 12(4)), their use remains voluntary, and waste receptacles receive the matching sorting label under Article 13, there with a 30-month period from the act. For packaging manufactured or imported before the date, a sell-off period of three years applies (Article 12(12)).

12 August 2028: end of the old material identification. Decision 97/129/EC with the material codes such as PAP 20 or PET 1 is repealed as of that day (Article 70(2)). Until then the old codes may be used, in Germany exclusively these (Section 4 VerpackDG). Since the new label arrives on the same day at the earliest, a delay creates a gap in which the old system is no longer prescribed and the new one not yet available; only the labelling act itself can close that gap.

Further dates in 2028. By 11 February 2028 the implementing act on calculating the empty-space ratio is due (Article 24(2)), on which the 2030 date for transport, grouped and e-commerce packaging depends. From 2028 producers inform end users about collection and waste prevention (Article 55). And on 31 December 2028 the last remnants of the old Directive that Article 70 kept alive expire, with the exception of the essential requirements on packaging minimisation, which continue until 31 December 2029 because the new minimisation criteria only take effect in 2030.

12 February 2028 in Germany. A further part of the omnibus act accompanying the VerpackDG enters into force on that day; it concerns consequential amendments to other laws, not the obligations of the Regulation.

2029: deposits, reusable label and the last Directive deadline

1 January 2029: deposit systems in all Member States. Under Article 50 the Member States must ensure by that day that at least 90 percent of single-use plastic beverage bottles and metal beverage cans up to three litres are collected separately, as a rule through a deposit system. Germany meets the rate with its existing deposit; for exporters the date means that from 2029 the deposit markings of the respective country are to be observed in almost all target markets. There is no harmonised deposit label; Member States can only additionally require the harmonised colour label.

12 February 2029: labelling of reusable packaging, at the earliest. From that day or 30 months after the implementing act enters into force, reusable packaging must bear a reusable label and a QR code or another open data carrier through which return and rotations can be traced (Article 12(2)). Open-loop systems without a system operator are exempt. National reuse labels may no longer exist alongside the EU label after that. For reusable transport packaging placed on the market between 11 February 2025 and the date of application of the reuse label, the Commission has described a practical reading in its guidance; the details are in B2B and transport packaging.

12 February 2029: Article 67(5). The amendment of the Single-Use Plastics Directive in Article 67(5) applies only from that day; it is the only exception to the general date of application that Article 71 itself names.

31 December 2029: end of the old minimisation rule. Until that day the essential requirements of Directive 94/62/EC on minimisation continue to apply, in practice the standard EN 13428. From 1 January 2030 Article 10 with the performance criteria of Annex IV replaces it.

2030: the year in which the packaging itself must comply

1 January 2030 is the real turning point of the Regulation. Almost everything prescribed for design, material and format begins on that day. Part of it is fixed, part movable.

Fixed: packaging minimisation (Article 10). Weight and volume are to be reduced to the minimum that secures the function, assessed against the performance criteria in Annex IV. Packaging that only serves the perception of a larger product, double walls, false bottoms and unnecessary layers are inadmissible from that day unless they fulfil a function.

Fixed: format bans (Article 25 with Annex V). From 1 January 2030 the following formats, among others, may no longer be placed on the market: single-use plastic packaging for unprocessed fresh fruit and vegetables under 1.5 kilograms, single-use plastic packaging for food and drinks consumed on the premises in hospitality, single-use portion packs for condiments, sauces, sugar or coffee creamer in the hospitality sector, miniature packaging for cosmetics and toiletries in accommodation, very lightweight plastic carrier bags except for hygiene reasons or loose food, and single-use plastic grouped packaging such as shrink film around multipacks in retail. National restrictions for the formats in points 2 and 3 may be kept by Member States even before 2030 (Article 70(4)).

Movable: recyclability grades (Article 6). From 1 January 2030 or 24 months after the delegated acts enter into force, packaging may only be placed on the market if it is recyclable at grade A, B or C, that is, reaches at least 70 percent in design for recycling. There is no grade D: anything below 70 percent counts as technically non-recyclable. Innovative packaging receives five years' deferral under Article 6(10); exemptions apply among others to medicines, contact-sensitive medical devices, infant formula and dangerous goods (paragraph 11). What the grades mean is explained in Recyclability, recycled content, empty space.

Movable: minimum recycled content in plastic packaging (Article 7). From 1 January 2030 or three years after the implementing act on calculation enters into force, which is due by the end of 2026, the following apply per packaging type and format, calculated as an annual average per manufacturing plant: 30 percent for contact-sensitive PET packaging, 10 percent for contact-sensitive packaging made of other plastics, 30 percent for single-use beverage bottles and 35 percent for all other plastic packaging. The recycled content must come from post-consumer plastic waste.

Movable: empty-space ratio (Article 24). From 1 January 2030 or three years after the implementing act enters into force, grouped, transport and e-commerce packaging may have at most 50 percent empty space, with filling material counting as empty space. For sales packaging no fixed percentage applies but minimisation under Article 10.

Movable: reuse targets (Article 29). From 1 January 2030 or 18 months after the calculation act enters into force, economic operators must demonstrate: 40 percent reusable for transport and sales packaging used for transport within the Union, such as pallets, boxes, drums, canisters and straps; 100 percent for transport between sites of the same company; 10 percent for grouped packaging in the form of boxes other than cardboard; 10 percent for alcoholic and non-alcoholic beverages with exceptions for wine, milk and further categories. Cardboard boxes are exempt from the transport targets, micro-enterprises from all of them. The first reporting year is 2030, the first report is due by 30 June 2031.

Further dates in 2030. From 1 January 2030 sales areas above 400 square metres are to endeavour to devote 10 percent of their space to refill stations (Article 28(5)), and hospitality businesses are to endeavour to offer 10 percent of their products in reusables (Article 33(5)); both are endeavour obligations. By 1 January 2030 the Commission must set the method for the digital indication of substances of concern (Article 12(7)). The Member States must reduce their packaging waste per capita by 5 percent against 2018 (Article 43) and recycle 70 percent of all packaging waste by 31 December 2030, with material rates up to 85 percent for paper and cardboard (Article 52).

2032 to 2040: the long lines

12 February 2032. The Commission reviews the empty-space ratio and the exemptions for e-commerce and reusables and examines empty-space requirements for sales packaging, in particular for toys, cosmetics, DIY kits and electronics (Article 24(6)).

12 August 2034. The Commission evaluates the whole Regulation, including the effects on the agri-food sector and food waste (Article 69).

1 January 2035: recycled at scale. A second yardstick is added to the assessment of recyclability: the packaging category must in practice be recycled at scale, measured by quantities actually recycled under the method of the implementing acts (Article 6(2)). The date is 1 January 2035 or five years after the acts enter into force, whichever is later. By the same day the Commission reviews the exemptions from recyclability. The Member States must have reduced their waste generation by 10 percent.

1 January 2038: only A and B. Packaging may only be placed on the market if it reaches grade A or B, that is, at least 80 percent (Article 6(3)). Grade C disappears. A fixed date, because it is not tied to a legal act.

1 January 2040: second recycled-content stage and target values. Minimum recycled content rises to 50 percent for contact-sensitive PET, 25 percent for other contact-sensitive plastics, 65 percent for single-use beverage bottles and 65 percent for all other plastic packaging (Article 7(2)). The reuse targets reach their target values, which the Regulation calls indicative: 70 percent for transport packaging, 25 percent for grouped-packaging boxes, 40 percent for beverages. The Member States must have reduced their waste generation by 15 percent.

Which dates can still move and which cannot

The question purchasing and packaging development ask most often is: what can I rely on? The answer follows from the deadline mechanics.

Immovable are all dates without a reservation for a legal act: the date of application, the digital EPR symbols on 12 February 2027, compostability and the reusable offer on 12 February 2028, the end of the old material codes on 12 August 2028, the format bans and the minimisation criteria on 1 January 2030, grades A and B on 1 January 2038 and the recycled-content stage in 2040. They could only be postponed by an amending regulation in the ordinary legislative procedure, and no such procedure is under way.

Movable upwards, that is only backwards, are the dates with the formula "whichever is the later": harmonised labelling (12 August 2028 at the earliest), reusable labelling (12 February 2029 at the earliest), recyclability grades (1 January 2030 at the earliest), minimum recycled content (1 January 2030 at the earliest), empty-space ratio (1 January 2030 at the earliest), reuse targets (1 January 2030 at the earliest) and recycled at scale (1 January 2035 at the earliest). They cannot move forward; they only shift if the Commission misses its deadline, and then by exactly the delay.

The experience of the first year argues for caution with the movable dates: of the four acts due by August 2026, the most important, labelling, is behind schedule. For planning, that does not mean waiting. Anyone who only checks their packaging after the acts are adopted has 24 months to convert all lines, and with more than a handful of packagings that is not enough. The data base, material composition, recycled-content sources, empty-space values and reuse shares, is independent of the act and can be built today.

Transitional and sell-off rules

The Regulation contains no general use-up of stock, but several targeted transitional rules that one needs to know to assess warehouse goods correctly.

For the substance limits of Article 5 there is no transitional period; placing on the market is decisive, not manufacture. Packaging placed on the market before 12 August 2026 may continue to be made available; whatever is first placed on the market after that must comply.

For the labelling obligations of Article 12, paragraph 12 provides a sell-off period of three years from application of the respective requirement for packaging manufactured or imported before. With a label date in autumn 2028, old packaging may therefore be made available until autumn 2031.

For recyclability, Article 6(10) provides five years' deferral for innovative packaging that does not yet reach the grades at the time of placing on the market, with evidence required in the technical documentation.

For reusable packaging placed on the market before 11 February 2025, corrective action, withdrawal and recall are dispensed with under Article 15(9). For reusables between that date and the application date of the reusable label, the Commission has announced in its guidance that it will make a practicable rule in the implementing act.

For the old Directive, Article 70 applies: parts of it live on until 31 December 2028 and 2029, the material codes until 12 August 2028, the decisions on heavy metals until their repeal by delegated acts. Anyone relying on EN 13428 for minimisation today does so correctly in law, until 31 December 2029.

And for Germany, Section 68 VerpackDG governs the transition of registrations and scheme contracts with the dates named above; the declarations of completeness for 2025 are processed under the old law.

Roadmap per role

The dates affect the roles differently. The producer of the packaging bears the packaging requirements, the producer within the meaning of EPR the extended producer responsibility, importers and distributors verification duties. Who holds which role is in Producer or manufacturer; here the dates per role.

Producer of packaging. Since 12 August 2026: conformity assessment, technical documentation, declaration of conformity, substance limits, identification on the packaging. 12 February 2027: EPR logos out of the print files. 12 February 2028: compostability where relevant. From the act plus 24 months, 12 August 2028 at the earliest: harmonised label. 1 January 2030: minimisation under Annex IV, format bans, at the earliest grades, recycled content and empty space. 1 January 2038: grade B as the minimum.

Producer within the meaning of EPR. Since 12 August 2026: registration in every Member State of first making available, in Germany with the deadlines 12 September and 12 November 2026. 1 January 2027: authorised representative in Germany without an establishment. Second half of 2027: conversion of the national registers to the harmonised format, then annual quantity reporting by 1 June. From the entry into force of the recyclability acts plus 18 months: fee modulation by grade. 2030: reuse targets, first report in 2031.

Importers. Since 12 August 2026: checking that conformity assessment, documentation and declaration exist and the packaging bears the details; name and address of the importer on the packaging. 2029: deposit markings of the target markets. 2030: format bans also for imported packaged goods. What additionally affects importers as EPR producers depends on the Member State of first making available.

Distributors and e-commerce. Since 12 August 2026: verification before making available, own-brand rule, platform duties on the EPR registration of sellers. 1 January 2030: 50 percent empty-space ratio for e-commerce packaging, at the earliest. What applies to micro-enterprises and e-commerce is in Micro-enterprises and e-commerce.

Hospitality and retail. 12 February 2027: customers' own containers. 12 February 2028: reusable offer. 1 January 2030: format bans for portion packs and on-site consumption, refill stations from 400 square metres, 10 percent reusables as an endeavour obligation.

How Polygon One maps the timeline

Polygon One keeps every packaging unit with its role per market and checks the requirements against the state that applies at the time: today substance limits, documentation and declaration of conformity, from the acts onwards the grades, recycled-content shares and empty-space values, which are already captured as data now. The declaration of conformity is generated from the packaging data, EPR registration is prepared and tracked per Member State, and if an act shifts a date, the check shifts with it.

What the software does not do: determine your role in law, assess conformity on your behalf or carry out the registration in the register; that stays with you, and the Regulation intends it to. If you would like to see where your packagings stand on this timeline, book a demo or read on at the PPWR module product page.

Download: PPWR deadline plan 2026 to 2040

Four pages for purchasing, packaging development and compliance: the fixed dates, the timeline, all movable dates with their trigger and the roadmap per role.

• Download: PPWR deadline plan 2026 to 2040 (PDF)

Frequently asked questions

Since when does the PPWR apply?

Since 12 August 2026, under Article 71. It has been in force since 11 February 2025. Individual requirements carry later dates; most design requirements apply from 1 January 2030.

Was the PPWR postponed?

No. The date of application arrived unchanged on 12 August 2026. The Commission's simplification proposal of December 2025 has changed no date.

From when is the harmonised label mandatory?

From 12 August 2028 at the earliest, or 24 months after the implementing act enters into force, which was due by August 2026 and was outstanding at the editorial deadline. The date shifts by the delay.

From when is a QR code mandatory?

For reusable packaging from 12 February 2029 at the earliest. For EPR symbols such as the Green Dot the QR code is the only permitted route from 12 February 2027. There is no general QR-code obligation.

From when do the recyclability grades apply?

From 1 January 2030 at the earliest, or 24 months after the delegated acts enter into force, which are due by 1 January 2028. From 1 January 2038 only grades A and B are permitted.

From when does minimum recycled content apply?

From 1 January 2030 at the earliest, or three years after the implementing act enters into force, which is due by the end of 2026. The second stage applies on a fixed basis from 1 January 2040.

Which dates are fixed?

12 February 2027 for digital EPR symbols and customers' own containers, 12 February 2028 for compostability and the reusable offer, 12 August 2028 for the end of the old material codes, 1 January 2030 for format bans and minimisation, 1 January 2038 for grade B, 1 January 2040 for the second recycled-content stage.

Are there sell-off periods?

For labels three years from application of the respective obligation. For substance limits none. For innovative packaging five years on recyclability. Reusable packaging from before 11 February 2025 need not be retrofitted.

Which deadlines apply additionally in Germany?

Registration of newly obliged producers by 12 September 2026, supplementing existing registrations by 12 November 2026, end of the old scheme contracts by 31 December 2026 at the latest, authorised representative for foreign producers from 1 January 2027.

When do deposit systems come EU-wide?

By 1 January 2029 the Member States must ensure a 90 percent collection rate for plastic bottles and metal cans up to three litres. Germany meets that with its existing deposit.

When do the reuse targets apply?

From 1 January 2030 at the earliest, or 18 months after the calculation act enters into force, which is due by 30 June 2027. Reporting starts for 2030, by 30 June 2031.

What happens in 2040?

Minimum recycled content rises to 50, 25, 65 and 65 percent per category, the reuse targets reach their target values, and the Member States must generate 15 percent less packaging waste than in 2018.

Sources and status: Regulation (EU) 2025/40 (Articles 5 to 13, 15, 24, 25, 28 to 33, 43, 44, 50, 52, 67 to 71, Annexes II, IV, V). Commission guidance, notice C/2026/3084 (document C(2026) 3702). Commission FAQ on the PPWR, second edition (July 2026). Packaging Law Implementation Act (BGBl. 2026 I No. 207 of 17 July 2026), in particular Sections 4, 5, 66, 68. DIHK and IHK Nürnberg information sheets on the PPWR. As at 18 September 2026; dates tied to legal acts are updated after their publication. This article is not legal advice.

Photos: Guilherme Mendes, Towfiqu barbhuiya, Yannic Kreß, all via Unsplash.