What the June 2026 PPWR Guidance Changed
What the Commission's June guidance actually changed, and what we updated
On 12 August 2026, Regulation (EU) 2025/40 — the PPWR — starts to apply across the Union. Two months before that date, on 10 June 2026, the European Commission published its interpretative guidance (C/2026/3084), following the FAQ of 30 March 2026 (C(2026) 2151).
Those two documents did something uncomfortable and useful: they corrected several readings of the regulation that had become standard across the packaging industry — in consultants' alerts, in compliance tools, and in training material, including ours. Most of that material was written in 2025, from early analyses, and never revisited.
In July we re-verified every regulatory statement in PPWR Connect against the regulation and the guidance, dated the review, and put automated checks in place so the content cannot silently drift again. This article lists what the guidance settles, because if we had these points wrong, chances are some of your internal documentation does too.
Seven points the guidance settles
1. Recyclability is not a 2030 subject. It starts on 12 August 2026.
The widespread reading was that recyclability obligations begin in 2030. In fact Article 6(1) applies from the general application date: packaging placed on the market must be recyclable from 12 August 2026. What is phased is the graded performance requirement — at least grade C from 1 January 2030, or 24 months after the Article 6(2)(a) delegated act enters into force, whichever is later, and at least grade B from 1 January 2038. That delegated act has not been adopted, so the 2030 date is a floor rather than a certainty.
2. There are three recyclability grades, not five.
The regulation defines grades A, B and C only. Packaging below grade C is technically non-recyclable; there is no grade D and no grade E, and there is no 2040 grade milestone. The percentage thresholds behind the grades will be set by delegated acts which, as of today, have not been adopted.
3. There is no packaging Digital Product Passport.
The PPWR requires harmonised labelling under Article 12, optionally delivered through a QR code or another standardised data carrier. The Digital Product Passport is a concept of the ESPR — Regulation (EU) 2024/1781 — and no ESPR delegated act currently subjects any product to one. Preparing your packaging data so it can feed a passport when one arrives is smart; treating a dated packaging DPP obligation as law is wrong.
4. The recycled-content targets are differentiated, and they sit in Article 7.
By 1 January 2030, calculated as an average per manufacturing plant and year: 10% for contact-sensitive plastic packaging other than PET, 30% for single-use plastic beverage bottles, and 35% for other plastic packaging. A specific rate applies to contact-sensitive PET packaging (Article 7(1)(a)).
A second tier follows in 2040. We are not going to give you those figures, because we cannot source them: apart from 65% for single-use plastic beverage bottles — which we have only from a Council press release, not from the regulation — the 2040 thresholds are not confirmed against a primary text. If you have seen a full 2040 table, ask where it comes from before you plan against it.
5. The format bans of Annex V start on 1 January 2030.
They do not start with the rest of the regulation, which is the assumption we hear most often. That four-year gap covers the much-discussed ban on single-use plastic packaging for fresh fruit and vegetables under 1.5 kg. The guidance also clarifies scope: packaging falls within the plastic-related restrictions from 5% plastic content by weight.
6. Penalties are a 2027 subject, and there is no EU-wide cap.
Member States must lay down their national penalty regimes by 12 February 2027. Any figure you may have seen presented as a harmonised PPWR fine — a fixed amount, or a percentage of turnover — does not come from the regulation.
7. EN 18120 is published, but it is not a harmonised standard.
The series exists and you can buy it. It has not been cited in the Official Journal, which is the step that would give it legal effect. Conforming to it is sensible engineering; it is not, today, proof of compliance with Article 6, and it grants no presumption of anything.
One more clarification worth knowing: the regulation entered into force on 11 February 2025, the twentieth day after its publication on 22 January 2025. A surprising number of documents state 12 February. The date matters when transitional periods are counted.
What we updated at PPWR Connect
Between 24 and 26 July we completed a full legal review of the platform: the compliance engine, the assistant, the glossary, more than 80 blog articles in nine languages, and every course of the PPWR Academy, including the quizzes and the course videos. Every regulatory value now lives in a single versioned reference dated 25 July 2026, and an automated check runs on every release: content that contradicts the reference cannot ship.
Where the law is not yet settled, because a delegated or implementing act has not been adopted, our content now says so explicitly instead of quoting a figure. You have just read two examples of that in point 4. We believe a compliance product earns trust by distinguishing what the text says from what the industry assumes.
Academy learners who completed courses before this update will receive an email in the coming days with a free re-take offer and an updated certificate referencing the June guidance.
The regulation applies in a few days. If your internal documentation was written before 10 June 2026, the seven points above are where we would start checking.
This article is a training and information summary, not legal advice. The binding reference is the official text of Regulation (EU) 2025/40 and its implementing and delegated acts.