PPWR: what changes on your packaging before 2028
This isn't a sustainability suggestion — it's a regulation with dates. If you sell a packaged product in the EU, your label will have to change before 2028.
What it is and since when
PPWR (EU Regulation 2025/40) replaces a thirty-year-old directive and, unlike it, applies identically across all 27 countries without each one translating it its own way. It has been in force since 12 August 2026.
It reaches whoever manufactures, packs, distributes or sells packaged product. It doesn't distinguish by company size: a small winery or an artisan cosmetics brand falls under it exactly like a multinational.
The dates that matter
Three milestones set when the work has to be done:
- 2026 — the regulation already applies, with registration required in the national system of each country you sell in
- 2028 — harmonised labelling becomes mandatory: common pictograms for material and recyclability on all packaging
- 2030 — all packaging must reach 70 % recyclability to be placed on the market, a threshold that keeps rising until 2038
What almost nobody has looked at: better design lowers your fee
PPWR introduces eco-modulation: what you pay into the extended producer responsibility scheme stops being a flat amount and starts depending on your packaging's recyclability, graded A to C.
In plain terms: the same product with better-designed packaging costs less every year. It stops being an image question and becomes a budget line. And what moves that grade are design decisions: how many materials you mix, whether the label separates from the pack during recycling, which inks and adhesives you use.
The design mistakes that will cause trouble
The most common ones, and the ones we see most in labels that come in for redesign:
- A label that doesn't separate from the container during recycling: it penalises the whole grade
- Mixing materials in a small piece — metallised plastic over glass, say — for an effect ink can deliver
- Inks and adhesives that contaminate the recycling stream
- Leaving the pictogram for last and forcing it into a closed design, which is when it ends up badly placed and ugly
What to do, and in what order
The efficient thing is not to touch the label twice. If your packaging is going to change before 2028 anyway, do the redesign once, covering the pictogram, recyclability and — if you're a winery — the e-label QR that is already mandatory.
We approach it like this: first a review of what you already have against the requirements, and from there it becomes clear whether it needs a tweak or a full redesign. It's often less than people fear.
Frequently asked
- Does it apply to a small brand selling 500 units?
- Yes. The regulation sets no size threshold for labelling. What changes with volume are the registration and reporting duties, not the packaging design.
- Are the pictograms defined yet?
- The Commission is developing them through implementing acts, and the obligation lands in 2028. That's why the sensible move now is to design leaving the space for it, instead of improvising later.
- What if I import the packaging from outside the EU?
- That's the most exposed case: packaging that fails the harmonised labelling or the recycled-content quotas can be held at customs. Manufacturing in the EU avoids that risk, and that's what we do.