EU PPWR 2025/40: What the New Packaging and Packaging Waste Regulation Means for Businesses

PPWR, the Packaging and Packaging Waste Regulation (EU) 2025/40, officially entered into force on February 11, 2025. As of August 12, 2026, the regulation has generally started to apply across the EU, introducing new requirements for how packaging is designed, used, and recycled.

The regulation introduces stricter requirements covering the entire packaging lifecycle, including packaging design, recyclability, recycled content, waste reduction, and the control of substances of concern. These requirements are expected to significantly influence how packaging manufacturers, suppliers, and brands design and produce packaging for the European market.

For the flexible packaging industry, PPWR is both a compliance challenge and an opportunity for innovation. It is driving the industry toward packaging solutions that balance product protection, functionality, recyclability, and sustainability.

Key PPWR Requirements

The new EU PPWR sets requirements for packaging substances, recyclability, recycled content, packaging minimization, and sustainable packaging design, bringing significant changes to how packaging is developed and placed on the EU market.

Article 5: Requirements for Substances in Packaging

PPWR introduces stricter requirements for substances of concern in packaging. It includes:

1. The presence and concentration of substances of concern (SoCs) in packaging should be minimized as much as possible.
2. The total concentration of lead, cadmium, mercury, and hexavalent chromium must not exceed 100 mg/kg.
3. PFAS limits will apply from August 12, 2026, including:
   • Individual PFAS: ≤ 25 ppb
   • Total PFAS: ≤ 250 ppb
   • Polymeric PFAS: ≤ 50 ppb
   • These limits apply regardless of whether PFAS is intentionally added or unintentionally present.
4. The requirements cover the entire packaging unit, including films, inks, adhesives, and other packaging components.

Article 6: Recyclable Packaging

All packaging placed on the EU market must meet recyclability requirements, with recyclability assessed according to specific performance criteria.
To be considered recyclable, packaging should meet two key conditions:

Designed for recycling	Recycling at scale
The packaging should be designed for material recycling, with the recycled material being of sufficient quality to replace virgin raw materials where applicable.	Once the packaging becomes waste, suitable collection, sorting, and recycling systems need to be available at commercial scale.

Recyclability Performance

Under the PPWR framework, recyclability performance will be assessed through different performance classes.

Class	Recyclability Performance
A	90%
B	80%
C	70%

According to the applicable Design for Recycling (DfR) requirements:

• From 2030, packaging will need to meet the applicable minimum recyclability requirements in grade C 70%.
• Packaging that does not meet the required criteria may face higher EPR (Extended Producer Responsibility) costs.
• From 2038, the requirements will become stricter, with only higher-performing recyclable packaging (exceeding grade B 80% ) expected to remain eligible for the EU market.

Article 7: Minimum Recycled Content in Plastic Packaging

From January 1, 2030, packaging placed on the EU market will need to be designed to minimize its weight and volume, while still providing the necessary functionality and protection.

This means companies will need to pay closer attention to packaging size, material selection, structure, and unnecessary space to avoid over-packaging.

How Should Brands and Packaging Manufacturers Respond?

For Brands

Brands can take several steps to prepare for PPWR:

1. Review existing packaging structures and gradually transition to recyclable, recycled-content, or reusable packaging where appropriate.
2. Reduce unnecessary packaging weight and volume, including excessive space and oversized packaging.
3. Work closely with packaging suppliers to evaluate alternative materials and structures.

For Packaging Manufacturers

Packaging manufacturers can support customers by:

1. Selecting raw materials that meet applicable PPWR Article 5 requirements, including PFAS restrictions.
2. Developing recyclable and reusable packaging without compromising product performance.
3. Increasing the use of PCR (Post-Consumer Recycled) materials where technically and legally suitable.
4. Working closely with customers to optimize packaging structures and develop more sustainable solutions.

How KDW Helps Customers Prepare for PPWR

With nearly 30 years of experience in flexible packaging manufacturing, KDW Packaging has been developing sustainable packaging solutions for years.

We work closely with brands to provide PPWR-oriented packaging solutions, helping customers transition toward recyclable, recycled-content, and more resource-efficient flexible packaging.

PFAS-Free Packaging Solutions

PPWR introduces stricter controls on PFAS and other substances of concern in packaging.

Traditional blown-film production may introduce trace amounts of PFAS through certain processing additives used in the extrusion screw system. KDW has optimized its material formulations and works with qualified raw materials to reduce the risk of PFAS being present in packaging materials while maintaining the required film performance.

During the transition toward recyclable packaging, KDW can also provide conventional flexible packaging solutions designed to meet applicable Article 5 PFAS limits, helping customers maintain product performance while preparing for future packaging requirements.

High-Performance Recyclable Packaging

As recyclability requirements become increasingly important, KDW has developed Mono-PE and Mono-PP packaging solutions for different applications.

These structures are designed to provide a balance between recyclability, mechanical strength, barrier performance, and processing requirements.

Key Material Selection Matters

• Replacing Nylon with BOPE:
  Traditional nylon (NY) can provide excellent puncture resistance, toughness, and drop performance. However, recyclable packaging requirements may limit the use of nylon in certain packaging structures.

  Under APCO standards, co-extruded NY/PE film with a nylon content below 20% can be classified as recyclable material. However, PPWR requirements are stricter, and recyclable packaging cannot contain nylon materials. 

  To address this challenge, KDW uses BOPE as an alternative material in suitable applications, helping maintain mechanical performance while supporting recyclable packaging designs.

• Avoiding PE/PP Composite PO Structures Where Required:
  APCO classifies PE/PP composite PO materials as recyclable materials. However, PPWR does not currently recognize PO composite materials as recyclable, so material selection needs to be carefully considered, and such structures should be avoided where they do not meet the applicable PPWR requirements.
• For high-temperature applications:
  KDW has also developed Mono-PP solutions, such as BOPP / High Barrier BOPP / CPP, for applications requiring retort or heat resistance.

  These structures can be used for products such as sauces, beverages, and spouted retort pouches, providing a balance between high-temperature performance and recyclability.

  

Recycled Packaging Solutions

KDW has developed a range of recycled-material packaging structures, including:

• PE/PE – PIR
• PET/PE – PIR
• PET-PCR/PE-EVOH-PCR
• PET-PCR/AL/PE-PCR

Depending on the material and application, recycled content can reach high levels.

Key examples:

1. For PET-based materials, PCR recycled content can typically reach 70%, with up to 100% possible for certain applications.
2. For 50 μm PE film, PCR/PIR recycled content can reach up to 60% in certain structures.
3. For 50 μm White PE film, PCR/PIR recycled content can reach up to 55% in certain structures.
4. KDW offers recycled-material packaging solutions that comply with major international recycled-material certification requirements. Certain PCR packaging solutions can be used for food-contact applications, subject to the specific material, certification, and regulatory requirements. PIR-based packaging solutions are currently not supported for food-contact applications.

Compostable and Biodegradable Packaging

In addition to recyclable and recycled-content packaging, KDW also offers compostable and biodegradable packaging solutions, including:

• Paper / PLA
• PLA / BOPLA

and more.

These materials can provide alternatives for customers looking for bio-based and compostable packaging solutions.

Working Together Toward PPWR-Ready Packaging

PPWR is changing the way packaging is designed and evaluated in the European market.

For brands, the transition is not simply about replacing one material with another. The challenge is to find the right balance between recyclability, barrier performance, mechanical strength, shelf life, processing, cost, and regulatory requirements.

KDW works with customers to evaluate existing packaging structures and develop customized alternatives based on their specific products and applications.

From Mono-PE and Mono-PP packaging to PCR solutions, high-barrier structures, and compostable materials, KDW continues to develop packaging solutions designed to support customers on their journey toward more sustainable and PPWR-ready packaging.