PPWR, current state

PPWR: current state, immediate impact and what happens next

Officially published in the Official Journal of the European Union, the Packaging and Packaging Waste Regulation (PPWR) entered into force on February 11, 2025 and applies broadly from August 12, 2026. For brands, retailers and label converters, the regulation has important implications for packaging design, material choices and the wider packaging value chain.

At Avery Dennison, we understand how important it is to choose labeling solutions that support packaging performance, regulatory readiness and end-of-life outcomes. Our teams are monitoring the regulation closely and working with customers to assess how label choices may affect packaging recyclability, compostability and compliance.

This article looks at the current state of the PPWR, the most immediate requirements and the next steps for companies preparing for implementation. These insights can help you understand what the regulation means for your existing packaging portfolio and how it may influence future labeling decisions.

The current state of the PPWR

The journey to finalize the PPWR has been lengthy and complex. Its objective is ambitious: to create a more harmonized regulatory framework for packaging across the EU while reducing packaging waste and supporting circularity.

The regulation affects a wide range of stakeholders, including packaging manufacturers, converters, brand owners, retailers, recyclers, waste management organizations and environmental groups. Each part of the value chain has a role to play in interpreting and implementing the new requirements.

Because the PPWR is broadly applicable from August 12, 2026, businesses now have a limited but critical preparation window to review packaging specifications, documentation, supplier data and labeling choices against the upcoming requirements.

Packaging value chain impacts and actions

The PPWR sets requirements across the packaging ecosystem, including rules on recyclability, recycled content, reuse, compostability and substances of concern.

One of the first requirements to prepare for is the restriction on PFAS in food-contact packaging. From August 12, 2026, food-contact packaging placed on the EU market must not contain PFAS at or above limits set out in the PPWR. 

Businesses should consider working with suppliers to confirm whether packaging materials, coatings, barriers, inks, adhesives or other components may contain PFAS and assess whether any food-contact packaging formats require updates.

PPWR, current state

 

Packaging manufacturers and converters are likely to feel early pressure to adapt. They will need to evaluate materials, validate specifications, update documentation and demonstrate that packaging meets applicable requirements. For brands, this means closer collaboration with packaging and label suppliers will be essential.

The transition may be complex, but it also creates an opportunity to improve packaging design decisions. By reviewing packaging early, companies can reduce the risk of late-stage compliance issues and identify label constructions that better support recyclability, compostability or other defined end-of-life requirements.

Action to take now 

Companies can start preparing by focusing on five practical steps:

  1. Map packaging formats and components
    Identify which packaging formats are in scope of the PPWR and where labels, adhesives, inks, coatings or other components may affect compliance.

  2. Assess label compatibility
    Review whether current label constructions support the intended packaging end-of-life route, including recycling or composting where applicable.

  3. Review supplier documentation
    Confirm whether suppliers can provide the data needed for compliance, including information on substances of concern, recycled content, recyclability and material composition.

  4. Prepare for reporting and registration obligations
    Determine whether your organization will need to update internal systems, collect additional packaging data or submit information to meet future requirements.

  5. Prioritize immediate obligations
    Based on current PPWR timelines, key dates to monitor include:

    • PFAS limits for food-contact packaging apply from August 12, 2026.

    • Sticky labels attached directly to fruit and vegetables must meet applicable compostability requirements by February 12, 2028.

PPWR, current state

 

All eyes on design for recycling

A crucial next step will be the development of detailed design-for-recycling criteria and related technical requirements. These will help determine how packaging is assessed for recyclability and how different packaging components, including labels, affect that assessment. Work is already underway at standards level, including through CEN and CENELEC, to support more consistent guidance for packaging design and recycling across the EU.

For the labeling industry, these criteria will be particularly important. Labels can support packaging identification, branding and consumer information, but they can also influence whether packaging can be effectively sorted and recycled. The right label choice depends on the packaging material, decoration method, adhesive, ink system and intended recycling stream.

As the technical framework develops, companies should avoid assuming that a label is “recyclable” in isolation. A more accurate approach is to assess whether the complete packaging system, including the label, is compatible with the relevant recycling stream and applicable guidance.

Design-for-recycling standards for plastic packaging are available through CEN and CENELEC. As criteria and guidance continue to develop for other materials, companies should monitor updates and assess how they may affect packaging components, including labels.

 

A catalyst for better packaging decisions

The PPWR is not only a compliance challenge. It is also a catalyst for more consistent, data-led packaging decisions across the EU.

For businesses, the priority now is proactive engagement and strategic planning. Waiting until requirements apply may create unnecessary risk, especially where packaging changes require testing, qualification, customer approval or supply chain adjustments.

At Avery Dennison, we work with stakeholders across the packaging value chain, including manufacturers, converters, brands, recyclers and industry associations. Our goal is to help customers evaluate label materials and constructions in the context of their packaging format, regulatory obligations and end-of-life objectives.

We also participate in relevant industry discussions and initiatives, including work with organizations such as RecyClass and 4evergreen. These forums play an important role in shaping technical guidance, improving industry alignment and supporting more consistent packaging assessments.

With expertise across packaging formats including PET, HDPE, glass, paper and cardboard, our teams can help customers review label options and identify solutions that are better aligned with specific packaging and recycling requirements.


Learn more

Visit our dedicated PPWR webpage for the latest insights, or contact us directly to discuss how Avery Dennison can support your packaging and labeling decisions as the regulation moves toward implementation.

 

 

Disclaimer: This article provides general industry insights and should not be relied upon as formal legal or regulatory compliance advice.