Packaging and Packaging Waste Regulation replaces Packaging and Packaging Waste Directive: 12 measures change

Event 2026-08-12Change AmendedBasis In force
Packaging and Packaging Waste Regulation
named by 6 of the changed measures
Plastics converting
named by 6 of the changed measures
Glass
Every figure on this diagram is counted from the act itself, and checked before the page is built.

Packaging and Packaging Waste Regulation replaces the Packaging and Packaging Waste Directive. 12 measures change, and the earlier wording is on file for 12 of them, shown against what each requires now. These measures name 8 sectors — most often Plastics converting, on 6 of them — and reach 3 more through supply chains, dependencies on other acts, or procurement. This act is adopted. It is law, not a proposal.

Sectors

Who this lands on

Sectors the act names in its own text, and — where the reach can be stated — the sectors its measures arrive at through a chain, with the channel each one travels.

Named in the act

Reached through a chain

Measures

What changed

The 12 measures this record is about. Where the earlier wording could be sourced, each shows what it said before.

Neutral · SUB-02Open the measure →

Keep the sum of lead, cadmium, mercury and hexavalent chromium in packaging or packaging components at or below 100 mg/kg.

Packaging and Packaging Waste RegulationArt. 5(4)Manufacturers and importers of packagingBusinesses
Prior rule
Trigger

packaging or packaging components placed on the market

Obligation

Sum of lead, cadmium, mercury and hexavalent chromium not to exceed 100 ppm by weight, five years from the date in Art. 22(1) of the Directive.

New rule
Trigger

packaging or a packaging component placed on the market

Obligation

Sum of lead, cadmium, mercury and hexavalent chromium not to exceed 100 mg/kg.

Verbatim

the sum of the concentrations of lead, cadmium, mercury and hexavalent chromium resulting from substances present in packaging or packaging components shall not exceed 100 mg/kg.

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Requirement · SUB-03Open the measure →

Rely on a heavy-metals exemption only where a Commission delegated act grants it; the exemptions are now time-limited, subject to marking, information and regular reporting requirements, and reviewable.

Packaging and Packaging Waste RegulationArt. 5(8)Manufacturers relying on a heavy-metals derogationBusinesses
Prior rule
Trigger

packaging entirely made of lead crystal glass

Obligation

The heavy-metals concentration limits did not apply at all to packaging entirely made of lead crystal glass, with no time limit, no marking duty and no review.

New rule
Trigger

packaging claiming an exemption from the 100 mg/kg limit

Obligation

Exemptions exist only via delegated act amending Decisions 2001/171/EC and 2009/292/EC, must be justified case by case, time-limited, marked, reported on and regularly reviewed.

Verbatim

Delegated acts adopted in accordance with this paragraph shall only be adopted to amend derogations es

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Requirement · LAB-01Open the measure →

Mark packaging with the harmonised material-composition label, pictogram-based and understandable including for people with disabilities; mark compostable packaging as compostable, not home-compostable and not for disposal in nature.

Packaging and Packaging Waste RegulationArt. 12(1)Economic operators placing packaging on the marketBusinesses
Prior rule
Trigger

packaging placed on the market

Obligation

Packaging had to indicate the nature of the packaging material used for identification and classification by industry, on the basis of Commission Decision 97/129/EC, marked clearly, visibly, legibly and durably on the packaging or the label.

New rule
Trigger

packaging placed on the market

Obligation

A harmonised, pictogram-based label aimed at CONSUMER SORTING, set by Commission implementing act, with digital marking for packaging containing substances of concern.

Verbatim

packaging placed on the market shall be marked with a harmonised label containing information on its material composition in order to facilitate consumer sorting.

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Requirement · BAG-01Open the measure →

Meet the 40-bags-per-capita ceiling in EVERY year after 2025, not only in 2025, and lose the alternative route of discharging the duty by ensuring bags are not supplied free of charge.

Packaging and Packaging Waste RegulationArt. 34(1), second subparagraphMember StatesGovernments
Prior rule
Trigger

annual national consumption of lightweight plastic carrier bags

Obligation

Measures ensuring the annual consumption level does not exceed 90 lightweight plastic carrier bags per person by 31 December 2019 and 40 by 31 December 2025, or equivalent targets in weight -- a one-off endpoint with no obligation stated for the years after 2025.

New rule
Trigger

annual national consumption of lightweight plastic carrier bags

Obligation

Consumption not to exceed 40 lightweight plastic carrier bags per capita by 31 December 2025 AND subsequently by 31 December each year thereafter.

Verbatim

A sustained reduction is considered to be achieved if the annual consumption does not exceed 40 lightweight plastic carrier bags per capita, or the equivalent target in weight, by 31 December 2025 and subsequently by 31 December each year thereafter.

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Neutral · BAG-02Open the measure →

Keep annual consumption of lightweight plastic carrier bags at or below 40 per capita -- the level itself, unchanged from the repealed directive.

Packaging and Packaging Waste RegulationArt. 34(1), first subparagraphMember StatesGovernments
Prior rule
Trigger

annual national consumption of lightweight plastic carrier bags

Obligation

Measures ensuring the annual consumption level does not exceed 40 lightweight plastic carrier bags per person by 31 December 2025, or an equivalent target set in weight.

New rule
Trigger

annual national consumption of lightweight plastic carrier bags

Obligation

Annual consumption not to exceed 40 lightweight plastic carrier bags per capita, or the equivalent target in weight.

Verbatim

Member States shall take measures to achieve a sustained reduction in the consumption of lightweight plastic carrier bags on their territory.

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Simplification · CNF-02Open the measure →

No longer required to prove conformity from first principles where a harmonised standard covers the requirement: conformity is presumed, and Art. 37 adds a Commission common-specification fallback where no standard exists or the standard is inadequate.

Packaging and Packaging Waste RegulationArts. 36(1)-(3) and 37Economic operators demonstrating conformity of packagingBusinesses
Prior rule
Trigger

packaging complying with relevant harmonised standards, or with national standards where no harmonised standard existed

Obligation

Member States presumed compliance with the essential requirements in Annex II for packaging complying with relevant harmonised standards published in the Official Journal, or with notified national standards in areas where no harmonised standard existed.

New rule
Trigger

packaging conforming to a harmonised standard or a Commission common specification

Obligation

Conformity is presumed against the whole of Arts. 5 to 12, 24 and 26 -- a far wider requirement set than the old Annex II essential requirements -- and Art. 36(2) additionally presumes conformity for methods performed by accredited conformity assessment bodies. Where no harmonised standard exists or an existing one is inadequate, Art. 37 lets the Commission adopt common specifications that carry the same presumption.

Verbatim

Packaging which is in conformity with harmonised standards or parts thereof, the references of which have been published in the Official Journal of the European Union, shall be presumed to be in conformity with the requirements laid down in or pursuant to Articles 5 to 12, 24 and 26 covered by those standards or parts thereof.

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Requirement · CNF-03Open the measure →

Prove conformity without relying on a national standard: the route by which a notified national standard conferred a presumption of conformity where no harmonised standard existed is not carried over.

Packaging and Packaging Waste RegulationArt. 36(1), by omission of the 94/62/EC Art. 9(2)(b) routeEconomic operators in Member States that had notified national packaging standardsBusinesses
Prior rule
Trigger

packaging complying with a notified national standard in an area where no harmonised standard existed

Obligation

Compliance with a relevant national standard, communicated to the Commission and published in the Official Journal, conferred a presumption of conformity with the essential requirements wherever no harmonised standard covered the area.

New rule
Trigger

a requirement covered by no harmonised standard and no common specification

Obligation

No presumption is available. The operator demonstrates conformity directly under Art. 35, using state-of-the-art methods of low uncertainty.

Verbatim

Test, measurement or calculation methods referred to in Article 35 which are in conformity with harmonised standards or parts thereof, the references of which have been published in the Official Journal of the European Union, shall be presumed to be in conformity with the requirements covered by those standards or parts thereof set out in that Article.

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Requirement · EPR-01Open the measure →

Carry extended producer responsibility for all packaging first made available or unpacked in a Member State, with financial contributions additionally covering the cost of labelling waste receptacles under Art. 13 and of compositional surveys of mixed municipal waste.

Packaging and Packaging Waste RegulationArt. 45(1) and (2)Producers of packaging and packaged productsBusinesses
Prior rule
Trigger

all packaging placed on the national market

Obligation

Member States had to ensure that extended producer responsibility schemes were established for all packaging by 31 December 2024, in accordance with Arts. 8 and 8a of Directive 2008/98/EC.

New rule
Trigger

packaging first made available in a Member State, or unpacked without being an end user

Obligation

EPR is imposed directly on the producer by the Regulation rather than through a Member State duty to set up a scheme, and the cost base is widened to include receptacle labelling and mixed-municipal-waste compositional surveys.

Verbatim

Producers shall have extended producer responsibility under the schemes established in accordance with Articles 8 and 8a of Directive 2008/98/EC and with this Section for the packaging, including packaging of packaged products, that they make available for the first time on the territory of a Member State or that they unpack without being end users.

View source →
Requirement · COL-01Open the measure →

Set up return and separate collection covering the whole territory and all packaging waste, open to operators, authorities and third parties and to imported products on non-discriminatory terms; collect design-for-recycling-compliant packaging for recycling and prohibit its incineration and landfill.

Packaging and Packaging Waste RegulationArts. 48(1) and (5)Member StatesGovernments
Prior rule
Trigger

used packaging and packaging waste from consumers and other final users

Obligation

Member States had to ensure systems were set up for the return and/or collection of used packaging and packaging waste in order to channel it to the most appropriate waste management alternative, and for its reuse or recovery including recycling. Collection did not have to be separate.

New rule
Trigger

all packaging waste from end users

Obligation

Return and SEPARATE collection of all packaging waste, covering the whole territory including public spaces, business premises and residential areas, with an outright prohibition on incinerating or landfilling packaging that meets the design-for-recycling criteria.

Verbatim

Member States shall ensure that systems and infrastructures are set up to provide for the return and separate collection of all packaging waste from the end users, in order to ensure that it is treated in accordance with Articles 4, 10 and 13 of Directive 2008/98/EC, and to facilitate its preparation for re-use and high-quality recycling. Packaging that complies with design for recycling criteria as established in delegated acts adopted pursuant to Article 6(4) of this Regulation shall be collected for recycling. Incineration and landfill of such packaging shall be prohibited, with the exception of waste resulting from subsequent treatment operations of separately collected packaging waste for which recycling is not feasible or does not deliver the best environmental outcome.

View source →
Neutral · RCT-01Open the measure →

Achieve recycling of at least 65% of all packaging waste by weight by 31 December 2025 and 70% by 31 December 2030, with material lines of 50/55% plastic, 25/30% wood, 70/80% ferrous metals, 50/60% aluminium, 70/75% glass and 75/85% paper and cardboard.

Packaging and Packaging Waste RegulationArt. 52(1)Member StatesGovernments
Prior rule
Trigger

packaging waste generated on the national territory

Obligation

Identical targets: 65% of all packaging waste recycled by 31 December 2025 and 70% by 31 December 2030, with the same six material lines at the same percentages -- plastic 50/55, wood 25/30, ferrous metals 70/80, aluminium 50/60, glass 70/75, paper and cardboard 75/85.

New rule
Trigger

packaging waste generated on the national territory

Obligation

65% by 31 December 2025 and 70% by 31 December 2030, with the same six material lines at the same percentages.

Verbatim

Member States shall take the necessary measures to achieve the following recycling targets covering the whole of their territory: (a) by 31 December 2025, a minimum of 65 % by weight of all packaging waste generated; (b) by 31 December 2025, the following minimum percentages by weight of the following specific materials contained in packaging waste generated: (i) 50 % of plastic; (ii) 25 % of wood; (iii) 70 % of ferrous metals; (iv) 50 % of aluminium; (v) 70 % of glass; (vi) 75 % of paper and cardboard; (c) by 31 December 2030, a minimum of 70 % by weight of all packaging waste generated; (d) by 31 December 2030, the following minimum percentages by weight of the following specific materials contained in packaging waste generated: (i) 55 % of plastic; (ii) 30 % of wood; (iii) 80 % of ferrous metals; (iv) 60 % of aluminium; (v) 75 % of glass; (vi) 85 % of paper and cardboard.

View source →
Requirement · RCT-03Open the measure →

Where an adjusted recycling target is claimed for re-use, calculate it by subtracting the three-year average share of reusable sales packaging, capped at five percentage points, and account separately for wooden packaging repaired for re-use.

Packaging and Packaging Waste RegulationArt. 54Member States claiming a re-use adjustmentGovernments
Prior rule
Trigger

a decision to achieve an adjusted target level for reusable sales packaging

Obligation

The same adjustment existed, on the same three-year average and the same five-percentage-point cap, against the targets in Art. 6(1)(f) to (i).

New rule
Trigger

a decision to achieve an adjusted target level for reusable sales packaging

Obligation

Unchanged in substance: three-year average share of reusable sales packaging subtracted from the Art. 52(1) targets, capped at five percentage points, with a separate limb for wooden packaging repaired for re-use.

Verbatim

A Member State may decide to achieve an adjusted level of the targets set out in Article 52(1) for a given year by taking into account the average share, in the preceding 3 years, of reusable sales packaging placed on the market for the first time and re-used within a re-use system.

View source →
Requirement · INF-02Open the measure →

Report to the Commission each calendar year on recycling target implementation and reusable packaging, per-capita consumption of each carrier-bag category, the DRS separate collection rate, and the quantities of packaging made available, collected and recycled by category.

Packaging and Packaging Waste RegulationArt. 56(1) and (2)Member StatesGovernments
Prior rule
Trigger

each calendar year

Obligation

Member States reported data on packaging and packaging waste to the Commission, including annual lightweight plastic carrier bag consumption from 27 May 2018.

New rule
Trigger

each calendar year

Obligation

Reporting extended to four separate carrier-bag categories rather than one, to the DRS separate collection rate, to reusable packaging data, and to packaging made available, collected and recycled per Annex XII category.

Verbatim

Article 56 Reporting to the Commission 1. Member States shall submit the following data to the Commission for each calendar year: (a) data on the implementation of Article 52(1), points (a) to (d), and data pursuant to Table 2 of Annex XII on reusable packaging; (b) the annual consumption of very lightweight plastic carrier bags, lightweight plastic carrier bags, thick plastic carrier bags and very thick plastic carrier bags per capita, separately for each category as listed in Table 4 of Annex XII;

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