New EU Packaging Regulation 2025: Recycled Content Targets, Reuse Rules, and What Exporters Must Know

What the PPWR Changes and Why It Matters#

The EU Packaging and Packaging Waste Regulation replaces Directive 94/62/EC, which has governed EU packaging rules since 1994. The new regulation is directly applicable — no member-state transposition — and introduces significantly more prescriptive requirements than the directive it replaces. The key changes are: mandatory minimum recycled content percentages for plastic packaging by 2030 and 2040; reuse targets for specific packaging formats in food service and retail; bans on certain packaging formats deemed unnecessary; and harmonised extended producer responsibility rules across member states. Businesses placing packaged goods on the EU market — including imports — are within scope. For UK exporters to the EU, packaging compliance is now a market access requirement, not a voluntary sustainability commitment.

Recycled Content Requirements for Plastic Packaging#

The PPWR sets minimum recycled content requirements for plastic packaging, phased by packaging category. By 2030, contact-sensitive plastic packaging for non-food applications must contain 35% recycled content. By 2040, the target rises to 65% for the same category. Food-contact plastic packaging faces lower 2030 targets (10-35% depending on format) due to safety considerations, with significant increases required by 2040. Single-use plastic beverage bottles must contain 30% recycled content by 2030, rising to 65% by 2040. These targets apply to the packaging of any product placed on the EU market — a UK food manufacturer exporting to Germany must use EU-compliant packaging or reformulate their packaging supply chain. AskBiz tracks how recycled content thresholds apply to your specific packaging categories.

Reuse Targets by Sector#

The PPWR introduces reuse targets for specific packaging formats, requiring that a proportion of packaging in those formats be offered in reusable systems. Targets apply to: cold and hot beverages consumed on-premises (cafe and restaurant sector), take-away food and beverages, e-commerce transport packaging, and grouped or secondary packaging in the retail sector. The reuse targets scale up over time — starting at lower percentages by 2030 and rising significantly by 2040. For exporters, the relevant obligation is on the economic operator placing the packaged product on the EU market. Exporters should work with EU distribution partners to understand how take-back and reuse systems are being established and whether their packaging formats are within scope of the targets.

Banned Packaging Formats#

The PPWR bans certain packaging formats from January 2030 on the basis that they are unnecessary. The banned formats include: single-use plastic packaging for fresh fruit and vegetables in portions below 1.5kg; single-use plastic packaging for food and beverages consumed in cafes and restaurants (where reusable systems are available); miniature plastic packaging in the hospitality sector (hotel shampoo bottles, etc.); and single-use plastic wrapping around hotel bedding and towels. These bans affect exporters whose products are packaged in these formats for the EU market. Reformulation of packaging before 2030 is required for affected products. Given lead times for packaging development and supply chain changes, 2025 is the time to begin this work.

Extended Producer Responsibility Harmonisation#

Currently, packaging EPR systems vary significantly across EU member states — different fee structures, different covered packaging categories, and different administrative requirements. The PPWR introduces harmonised EPR requirements across the EU, standardising the scope of covered packaging and the modulation of fees based on packaging recyclability. For businesses currently navigating separate national EPR systems in Germany, France, Spain, Italy, and other EU markets, greater harmonisation should reduce administrative complexity over time. However, the transition period and implementation of national systems against the new framework will require careful monitoring. EPR registration obligations in each member state where you place products on the market remain mandatory.

• The EU Packaging and Packaging Waste Regulation (PPWR) was adopted in early 2025, replacing the 2004 Packaging Directive.
• It introduces mandatory minimum recycled content for plastic packaging, reuse targets for specific sectors, bans on unnecessary plastic packaging formats, and harmonised extended producer responsibility (EPR) across the EU.
• Any business placing packaged goods on the EU market must comply.