Regulation (EU) 2025/40 — the Packaging and Packaging Waste Regulation — entered into force on 11 February 2025 and applies from 12 August 2026. It replaces the old Packaging Directive (94/62/EC) and creates the most significant overhaul of EU packaging law in 30 years.
But buried in 100+ articles and hundreds of recitals is the question that actually matters for most DTC brands: what do I have to do, and by when?
Here's the direct answer.
The old Packaging Directive was a 1994 framework that set recycling targets but left most implementation to member states. The result: 27 different national EPR systems with different rules, different rates, and different standards for what counts as "recyclable."
PPWR replaces this with EU-level rules that apply directly, without needing to be transposed into national law. It's a regulation, not a directive — it's legally binding in all member states from day one.
The political driver: the EU had committed to a 55% reduction in packaging waste by 2030 under the European Green Deal. The old Directive wasn't delivering that.
Under PPWR Article 6, all packaging placed on the EU market must be accompanied by a Declaration of Conformity from the producer. The DoC is a formal written document that declares your packaging meets the recyclability requirements of Articles 6 and 7 (where applicable).
What's actually required:
Who must do this: Any business placing packaging on the EU market. This includes DTC e-commerce brands.
Practical reality for SMEs: The DoC requirement is real but not burdensome for standard packaging. If you're using standard corrugated cardboard boxes, paper mailers, and basic plastic materials, your packaging almost certainly complies with the current PPWR recyclability framework. The DoC documents this. What you can't do is use clearly non-recyclable packaging (EPS foam as primary packaging, PVC bags) and declare compliance.
PPWR Article 5 prohibits PFAS (per- and polyfluoroalkyl substances) in packaging that comes into direct contact with food. PFAS were widely used as coatings for:
Who is affected: Food and beverage brands, food subscription boxes, meal kit companies, pet food brands using food-contact flexible packaging with PFAS coatings.
Who isn't affected: Most non-food DTC brands (fashion, beauty, wellness, supplements in bottles) — your packaging doesn't contact food, so PFAS coatings aren't used anyway.
If you're a food brand, ask your packaging supplier directly whether any components contain PFAS coatings. Get written confirmation. This should be in your Annex VIII documentation.
Packaging must be designed to minimise its weight and volume while maintaining its function. This prohibits:
For e-commerce brands: The excessive void space rule is particularly relevant. If you're shipping products in boxes that are 2–3x the size of the product, you may be non-compliant. The 40% void space rule means if your product occupies less than 60% of your box's interior, you need to right-size the box or pack it more efficiently.
This also hits the practice of adding purely decorative secondary packaging — an extra branded wrapper around an already-packaged product, added only for aesthetic purposes — which is prohibited.
PPWR harmonises the EPR framework across the EU. Member states retain their national EPR systems (LUCID, Citeo, Verpact, etc.) but must align them with PPWR requirements by August 2026. This means:
Immediate impact: The PPWR-aligned EPR systems are what you register with in each market. The national PRO systems continue to operate; PPWR sets the framework they must follow.
PPWR requires standardised labeling on packaging indicating recyclability. This is mandated but the technical specifications (what labels look like, the harmonised sorting instructions) depend on delegated acts from the Commission. These are expected by 1 January 2028, with labeling becoming mandatory once adopted.
For now: the PPWR labeling requirements aren't yet enforceable. You don't need to redesign your packaging labels by August 2026 for this specific requirement. Watch for the delegated acts in 2027–2028.
| Obligation | Date | What it requires |
|-----------|------|-----------------|
| Recyclability grades A–E delegated acts | By 1 Jan 2028 | Commission publishes format-by-format recyclability grades |
| Mandatory recyclability labeling | After 2028 delegated acts | Standardised labels on all packaging |
| Recycled content targets (Art. 7) | 1 Jan 2030 | 10–35% recycled plastic content by packaging type |
| EPR eco-modulation harmonised | 1 Jan 2030 | EU-wide harmonised surcharges/discounts based on grades |
| E-commerce re-use targets (Art. 29) | 1 Jan 2030 | 10% of e-commerce deliveries in reusable packaging |
| Beverage DRS (Art. 50) | By 2029 | Deposit return systems for bottles and cans |
For most DTC brands, the August 2026 to-do list is short:
For brands with complex or non-standard packaging:
What you don't need to do by August 2026:
The full text of Regulation (EU) 2025/40 is published in the Official Journal of the European Union and available at eur-lex.europa.eu. The European Commission also publishes implementation guidance at environment.ec.europa.eu.
For a practical compliance checklist, see our article on the Declaration of Conformity: a step-by-step guide for brands.
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Expert-level PPWR content: PPWR Annex VIII technical documentation guide