PPWR: which obligations apply today, and which wait on a delegated act?
A quality manager at a German chemicals company wrote to us on 28 August 2026 with a sentence that sums up the year: he had seen a recyclability figure for his packaging and was, in his words, “a bit confused because the EU hasn’t published the calculation scheme yet”. He was right on both counts. The harmonised criteria are not published. The regulation still applies to him today.
Both things are true at once, and that is the part most compliance summaries get wrong. Regulation (EU) 2025/40 contains two different kinds of obligation: those that bind now, and those whose start date is tied to an act the Commission has not yet adopted. Reading one as the other costs real money in both directions — you either buy time you do not have, or you rebuild packaging years before you were required to.
What does the PPWR require today?
The design-for-recyclability obligation in Article 6(1) has applied since 12 August 2026 to all packaging placed on the market, transport packaging included. It is in force now, for brand owners, importers, converters and distributors alike. It is not a 2030 obligation and it is not waiting on anything.
What Article 6(1) does not do is give you a number. It states a design requirement. The graded performance classes that turn that requirement into a letter are a separate provision with a separate, later, and conditional start date. That distinction is the whole subject of this article, and it is why a figure can be useful today without being a regulatory verdict.
Key facts
- Article 6(1), design for recyclability: applies since 12 August 2026, transport packaging included (Regulation (EU) 2025/40, Article 6).
- Recyclability performance classes (A, B, C): the referential does not confirm a firm start date; the date is tied to the delegated acts of Article 6(4), which are not adopted.
- Empty-space ratio: capped at 50% from 1 January 2030, or 3 years after the entry into force of the Article 24(2) implementing acts, whichever is the latest (Article 24(1)).
- Re-use targets: 40% in 2030 and an endeavour of 70% in 2040 for transport packaging, binding the operators that use it within the Union (Article 29).
- Verification baseline: PPWR Connect referential, reviewed 31 August 2026.
Why is “all packaging must be recyclable by 2030” wrong?
That sentence is wrong because it presents a conditional date as a firm one. The graded recyclability floor does not run from a fixed calendar date. Article 6(2), fourth subparagraph, makes it run from 1 January 2030 or 24 months from the entry into force of the delegated acts adopted pursuant to the first subparagraph of Article 6(4), whichever is the latest.
The delegated act in question is not adopted. Until it is, nobody — not a consultant, not a software vendor, not a trade body — can tell you the date on which the graded floor starts to bind. Anyone printing a firm 2030 deadline for it is reporting a guess as a fact. The honest formulation names the condition in the same breath as the date.
The error is expensive in both directions. Announce 2030 as certain and you may promise a customer 24 months they do not have. Announce it as certain and you may equally make a packaging buyer scrap a running specification 24 months before anything required it.
What is a conditional deadline under the PPWR?
A conditional deadline is a deadline whose start date depends on a second instrument that does not yet exist. The regulation fixes the substance and defers the timing. Article 24 is the clearest worked example: the 50% cap on empty space is textual and settled, while the date it starts to bind is a moving floor.
Concretely, the empty-space ratio must not exceed 50%, and that cap applies from 1 January 2030 or 3 years after the entry into force of the implementing acts of Article 24(2), whichever is the latest. The percentage will not change. The date can. Two sentences about the same rule, and only one of them is safe to put in a customer contract.
Which obligations are firm today, and which are conditional?
| Provision | Status | What that means |
|---|---|---|
| Article 6(1) — design for recyclability | In force since 12 August 2026 | Applies now to all packaging placed on the market, transport included |
| Article 6(2)(a) — performance classes A, B, C | Conditional | Tied to the Article 6(4) delegated acts, which are not adopted |
| Article 24(1) — empty-space ratio | Cap firm, date conditional | 50% cap; from 1 Jan 2030 or 3 years after the Article 24(2) acts, whichever is later |
| Article 29 — re-use targets | Targets stated | 40% in 2030, endeavour of 70% in 2040 for transport packaging |
Every line of this table was checked against a dated referential before publication. The rows marked conditional are conditional in the text of the regulation itself, not in our reading of it.
Who do the Article 29 re-use targets bind?
The Article 29 re-use targets bind the economic operators that use transport packaging within the territory of the Union. The figures are 40% in 2030 and an endeavour of 70% in 2040 for transport packaging. The obligation attaches to the operator using that packaging inside the Union, which is a different question from where the packaging was manufactured.
This matters for anyone reading the regulation from outside the EU. The test is use within the Union, not origin. A logistics flow arriving from a third country is not in scope as such; the operator using the packaging within the Union is.
Where does the digital product passport come from?
The digital product passport is an instrument of the Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781. It is created there and nowhere else. Recital 70 of the packaging regulation refers across to that instrument rather than establishing one of its own.
This confusion is worth naming because it is everywhere in vendor material. What the packaging regulation does contain is harmonised labelling and a data carrier. Those are real obligations with their own article and their own scope. Filing them under the wrong regulation means looking for your requirements in the wrong legal text.
What should you do with a recyclability figure today?
Treat it as an engineering estimate, and record the method that produced it. That is what the German quality manager settled on once the basis was explained to him, and he called it an “initial impression” — which is the correct register for any number produced before the harmonised criteria exist.
A figure calculated today is calculated under a method that is not the harmonised one, because the harmonised one is not published. That does not make it worthless. It makes it provisional, and provisional numbers are useful exactly as long as they carry their provenance: which method, which version, which date. A number without its method cannot be defended in a supplier dispute or an inspection.
Design decisions taken now — separability of a metal handle from a plastic body, an adhesive label that survives a wash step, an ink or varnish system that does or does not contaminate a stream — are the decisions the eventual criteria will grade. Converters and printers who already hold measured, repeatable process data are better placed than those who will have to reconstruct it. For colour and print process measurement on label and packaging presses, Veoria builds inline instrumentation of that kind.
How does this change what you ask your suppliers?
Ask for the composition and the separability of each component, not for a grade. A supplier cannot give you a harmonised grade today, because the harmonised method does not exist. A supplier can give you material, weight, and how a component detaches, and those inputs stay valid whatever the eventual criteria say.
The question is more practical than it sounds. A plastic bucket with a metal handle is a real case a customer raised with us in August 2026: the handle is hard for a consumer to remove by hand, but shredding and magnetic separation extract it easily. Whether that counts, and at which stage of separation, is precisely what the criteria will decide. Recording the physical facts now means you will be able to answer either way.
The same logic applies to a removable label, an adhesive that survives washing, a barrier coating, or a printed varnish. Brand owners specifying packaging, importers taking on someone else’s specification, converters producing it and distributors putting it on a shelf all need the same underlying record. What changes between them is who holds it, not what it contains.
What did the verification referential decline to confirm?
Several things, and naming them is part of the answer. Our referential checks claims against a dated, human-reviewed source set, and it returns three outcomes: confirmed, contradicted, or not covered. Anything it does not cover, we do not assert.
It did not confirm a firm start date for the graded performance floor. It did not confirm the adoption status or the due date of the Article 6(4) delegated acts. It did not confirm a general application date for the regulation stated in isolation, though it does confirm that Article 6(1) has applied since 12 August 2026. It did not confirm the article that carries fee modulation, so we cite none.
A referential that stays silent is more useful than one that fills gaps. Two of the checks run for this article came back contradicted rather than silent, and both corrections concerned a conditional date being presented as firm — the same error, twice, in the two provisions readers most often quote.
How do you keep a compliance file that survives a delegated act?
Write down the basis of every figure at the moment you produce it. A compliance file that records method, version and date can be re-run against new criteria when they arrive. A file holding only conclusions has to be rebuilt from nothing.
Three practices carry the cost of the transition. Separate firm obligations from conditional ones in your own documentation, so a delegated act changes one column and not the whole file. Archive superseded figures rather than overwriting them, because you will be asked what you believed and when. And date your regulatory sources, since a claim that was accurate in March may not be in September.
The uncertainty here is real and we are not going to paper over it. The referential we check against does not confirm a start date for the graded floor, does not confirm the adoption status of the Article 6(4) act, and does not settle where fee modulation sits. Where it says nothing, we say nothing. That is a better basis for a decision than a confident date that turns out to be someone’s inference.
Related reading
- Article 6 and design for recycling
- The PPWR technical documentation file
- Writing a declaration of conformity
- Transport packaging obligations
- PPWR deadlines: which are firm, and which wait on an act
Published by
Rutherford (rutherford.fr) develops production control software for offset printers and converters, including ColorLoop. Veoria (veoria.com) develops inline colour measurement for label and packaging presses, including DeltaOne.