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The PPWR calendar: every date that changes what you pack, label or payLast checked 7 October 2026
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The PPWR calendar: every date that changes what you pack, label or pay
The short version
12 August 2026 was the start line, not the deadline. The first date that changes what you do is 12 February 2028: from then, whoever fills sales packaging has to keep empty space to the minimum necessary — and tea bags, coffee bags, soft pods and stickers on fruit and vegetables have to be compostable. August 2028 adds the material-composition label, 2029 the deposit-return systems, and 1 January 2030 the wave everyone quotes: minimisation, the 50% empty-space cap, the bans in Annex V, recyclability grades, recycled content and refill space. The last dates run to 2040.
The calendar, 2026 to 2040
One table, one row per date. The fourth column is how much weight the date carries here: Regulation means we read it in the text of Regulation (EU) 2025/40 on EUR-Lex; Regulation + FAQ means the Commission's own Q&A says the same thing; disputed means the two do not agree — see the next section. The FAQ is not binding law and says so about itself; the Regulation is.
| When | What changes | Where it is written | Confidence |
|---|---|---|---|
| 12 August 2026 | The Regulation applies. The 1994 Packaging and Packaging Waste Directive is repealed, with listed exceptions. Food-contact packaging may not be placed on the market with PFAS at or above 25 ppb for any PFAS, 250 ppb for the sum of PFAS, or 50 ppm including polymeric PFAS. The sum of lead, cadmium, mercury and hexavalent chromium stays capped at 100 mg/kg for all packaging. | Art. 71, second subparagraph; Art. 70(1); Art. 5(5); Art. 5(4) |
Regulation + FAQ (ch. V q12 dates Art. 5(1) and (4) to 12 August 2026) |
| 31 December 2026 | Two Commission deadlines that shape your file: the report on substances of concern in packaging, prepared with the European Chemicals Agency, and the implementing act fixing the methodology for calculating recycled content. | Art. 5(2); Art. 7(8) |
Regulation. Not a duty on you — but the recycled-content method it produces decides when your 2030 percentages start |
| 12 February 2027 | More Commission deadlines: the request to the European standardisation organisations for the updated minimisation methodology (the successor to EN 13428:2004), guidelines explaining Annex V and its exemptions, and a correction factor for tourism in the prevention target. |
Art. 10(3); Art. 25(6); Art. 43(2) |
Regulation + FAQ (ch. VII q3, ch. XII q1) |
| 12 February 2028 | The first date that bites. Sales packaging: whoever fills it must keep empty space to the minimum necessary for the packaging's function, including product protection — filler counts as empty space, protective gas does not. Compostability: permeable tea, coffee and other beverage bags and soft single-serve units, plus sticky labels on fruit and vegetables, must be compatible with industrial composting standards. All other packaging must be designed for material recycling. The Commission also owes the implementing act that fixes how the empty-space ratio is calculated. | Art. 24(4); Art. 24(3); Art. 9(1); Art. 9(3); Art. 24(2) |
Disputed on the sales-packaging date — the Regulation says 12 February 2028, the FAQ's date list points to 1 January 2030. See below |
| 12 August 2028 | Packaging placed on the market must carry a harmonised, easily understandable label on its material composition for sorting — or 24 months from entry into force of the implementing acts on labelling, whichever is later. Compostable packaging must say so on that label, that it is not suitable for home composting and that it is not to be discarded in nature. Labelling of recycled content follows the same date and the same "whichever is later" clause. | Art. 12(1); Art. 12(4) |
Regulation. The repeal of Decision 97/129/EC takes effect the same day (Art. 70(2)) |
| 1 January 2029 | Member States must ensure separate collection of at least 90% per year by weight of single-use plastic beverage bottles up to three litres and single-use metal beverage containers up to three litres, and must set up deposit and return systems with a deposit charged at the point of sale. The duty is the Member State's; the label on the packaging and the deposit at the till are what you see. | Art. 50(1); Art. 50(2) |
Regulation + FAQ (ch. XVI q11, ch. I summary) |
| 12 February 2029 | Reusable packaging placed on the market must bear a label saying it is reusable, with a QR code or other digital carrier for the re-use system and collection points — or 30 months from the implementing act, whichever is later. | Art. 12(2) |
Regulation |
| 1 January 2030 | The wave. Minimisation: weight and volume reduced to the minimum necessary, and no double walls, false bottoms or unnecessary layers whose only aim is to increase the perceived volume. Empty space: a 50% cap for grouped, transport and e-commerce packaging — or three years after the empty-space method, whichever is later. Bans: the formats in Annex V, including single-use plastic packaging for pre-packed fresh fruit and vegetables under 1.5 kg and for food and drink consumed on the premises in the HORECA sector. Refill: final distributors with a sales area over 400 m² "shall endeavour" to give 10% of it to refill stations. Recyclability: grades A, B or C only. Recycled content: 30% for contact-sensitive PET (except single-use bottles), 10% for other contact-sensitive plastics, 30% for single-use plastic beverage bottles, 35% for other plastic packaging — or three years after the recycled-content method, whichever is later. Reuse: 40% of listed transport packaging, all of it between sites and within a member state, 10% of grouped packaging in the form of boxes other than cardboard. Prevention: member states cut packaging waste per person by at least 5% against 2018. | Art. 10(1); Art. 10(2); Art. 24(1); Art. 25(1) with Annex V; Art. 28(5); Art. 6(3); Art. 7(1); Art. 29(1)–(3), (5); Art. 43(1)(a) |
Regulation. The FAQ's date list agrees on minimisation, the 50% cap and the recycled-content window (ch. X q2) |
| 12 February 2032 | The Commission reviews the 50% empty-space ratio and its exemptions, and looks at whether sales packaging should get a ratio of its own — including for toys, cosmetics, DIY kits and electronics. | Art. 24(6) |
Regulation |
| 1 January 2035 | Packaging must be recycled at scale, not merely recyclable in design — or five years from the implementing act on recycling at scale, whichever is later. Member states cut packaging waste per person by at least 10% against 2018. | Art. 6(2), point (b); Art. 43(1)(b) |
Regulation |
| 1 January 2038 | Only packaging in recyclability grades A or B may be placed on the market. Grade C, acceptable from 2030, falls away. | Art. 6(3), third subparagraph |
Regulation |
| 1 January 2040 | Second stage of recycled content: 50% for contact-sensitive PET, 25% for other contact-sensitive plastics, 65% for single-use plastic beverage bottles and 65% for other plastic packaging. Reuse becomes an endeavour rather than a duty in places: 70% of listed transport packaging, 40% of beverage products in reusable packaging. Member states cut packaging waste per person by at least 15% against 2018. | Art. 7(2); Art. 29(1), (6); Art. 43(1)(c) |
Regulation. This is where the "phased in until 2040 at the latest" line in the trade coverage lands |
Art. 70(1)(b), and so does the standard EN 13428:2004.
And the substance report of 31 December 2026 may end in lower heavy-metal limits
by delegated act — Art. 5(7) allows the Commission to lower them, so
the 100 mg/kg figure is a floor, not a ceiling that is fixed forever.
The sales-packaging date is disputed
This is the one place where a careful reader can end up with two different dates, and it is not our invention — it is a real disagreement between the text of the Regulation and the Commission's own Q&A. It matters because the sales-packaging duty is the one that reaches ordinary parcels.
- What the Regulation says
Art. 24(4): "By 12 February 2028, the economic operators who fill sales packaging shall ensure that empty space is reduced to the minimum necessary for ensuring the packaging functionality, including product protection." Read plainly, that is a duty from 12 February 2028, and it is how a TÜV SÜD consumer briefing of 7 October 2026 reads it too ("Ab Februar 2028 müssen Verkaufsverpackungen ihren Leerraum aufs Nötigste beschränken").- What the Commission's FAQ says
- Its list of application dates puts minimisation under
Art. 10(1)–(2)at 1 January 2030, and for void space it says: "as regards void space in sales packaging, see Art. 10". Its empty-space chapter answers the "minimum necessary" question inArt. 24(4)without naming any date at all. On that reading the sales-packaging duty starts in 2030. - What governs
- The Regulation. The FAQ's own front matter says it reflects only the views of its authors and that the Commission is not liable for reuse; where the two differ, the text on EUR-Lex decides. That does not make the FAQ wrong about your file, though — it tells you what the Commission's own staff will say when asked.
- The practical reading
- Plan for 12 February 2028 and be pleased if the Commission's reading prevails. The measure itself is cheap and reversible: know the internal volume of your boxes against the volume of what goes in them, and stop treating filler as a substitute for the right size. Nothing in
Art. 24(4)depends on the calculation method that is still owed underArt. 24(2)— that method is for the 50% cap on grouped, transport and e-commerce packaging.
Where the briefing and the Regulation part ways
We checked the consumer briefing that prompted this page against the Regulation, line by line. Most of it holds. Four things do not, and they are worth knowing because they are the kind of detail that gets repeated.
"Compostability standards from next February"
No February 2027 obligation exists. Art. 9(1) dates the
compostability requirement for beverage bags, soft single-serve units and
produce stickers to 12 February 2028, and the Commission's FAQ says
the same in as many words ("As Article 9 on compostability applies from
12 February 2028"). The only February 2027 item in this area belongs to the
Commission: a request to the standardisation organisations.
"Coffee capsules must be compostable"
Only half true. The mandatory compostability route covers permeable
bags and soft single-serve units (Art. 3(1), point (1)(f))
and produce stickers. Rigid capsules and hard pads
(Art. 3(1), point (1)(g)) are covered only where a member state
has chosen to require it under Art. 9(2)(a), which it may do only
where bio-waste collection and treatment infrastructure exists. The briefing's
line about "special recyclability rules for coffee capsules" is not something
we could find in the Regulation.
"Stricter heavy-metal limits"
The PFAS limits are new and are the sharp end. The heavy-metal limit is not:
Art. 5(4) restates the sum of 100 mg/kg for lead,
cadmium, mercury and hexavalent chromium that already applied under the
repealed Directive, and recital 72 says so. It can be lowered later by
delegated act under Art. 5(7) — it has not been.
"At least 10% for refill stations"
Softer than it sounds. Art. 28(5) says final distributors with a
sales area of more than 400 m² "shall endeavour to" dedicate 10% of
that area to refill stations for food and non-food products from
1 January 2030. The other 2030 items in the table are duties; this one is an
effort obligation. The single-use plastic bans the briefing lists do
have a date — 1 January 2030, Art. 25(1) — and its
"August 2028" for material information matches Art. 12(1).
In Germany: the VerpackDG
The Regulation is directly applicable, so most of the calendar above needs no German act. What the national law supplies is the machinery around it — enforcement, competences and fines.
- The act
- Verpackungsrecht-Durchführungsgesetz (VerpackDG) — full title "Gesetz zur Durchführung der Verordnung (EU) 2025/40 betreffend Verpackungen", dated 13 July 2026 (BGBl. 2026 I Nr. 207).
- The date
- TÜV SÜD states it entered into force on 12 August 2026, the day the Regulation started to apply, and the act's own transitional rules split on exactly that line: they speak of the registration and system-participation duties of the old Verpackungsgesetz as in force until 11 August 2026, with the first notification deadline on 12 November 2026.
- What it adds
- Registration, system participation, data reporting and completeness declarations for the German market; the authorised-representative duty for foreign producers; and the fines that go with them. The Germany desk follows that side, and the registry deadlines are the ones a small seller actually meets first.
What to do with this
Not legal advice, and not a compliance programme. Three rows of the table are close enough to need data from suppliers now, and one is close enough to need nothing but a tape measure.
- 1. The 2028 rows: ask suppliers now
- If you sell tea, coffee, pads or loose produce, ask now which of your items is a permeable bag or soft pod and which is a rigid capsule, and what the supplier's compostability certificate says. Certification takes longer than a season, and
Art. 9(1)applies on 12 February 2028. - 2. The 2028 substance and label rows
- PFAS limits are live today, and run through coatings on food-contact board — burger boxes, snack packaging, freezer trays, bakery cartons. Ask for the declaration rather than the assurance. On labelling, the label design is the Commission's job, but the material data behind it is yours.
- 3. The 2030 rows: get the numbers, not the boxes
- Recycled content is averaged across a plant and a year, and recyclability is graded per packaging category, so this is a conversation with your converter — starting with which of your formats has a plausible route to grade A or B by 2038.
- 4. And the one you can do this afternoon
- Measure a box: internal volume, and the volume of what goes in it. Keep the number and the date. That is not a compliance answer, and it is the thing every one of these duties will ask you for.
Sources
-
Regulation (EU) 2025/40 (PPWR) — EUR-Lex, English text Official, and the governing text. Read in full for this page — this time we did get the text, having failed to when we wrote the void-fill note. Everything in the "Where it is written" column is taken from it:
Art. 3(1), points (1)(f) and (1)(g) for the compostability categories;Art. 5(1),(2),(4),(5)and(7)for substances of concern, the 100 mg/kg heavy-metal sum and the PFAS limits;Art. 6(2)and(3)for recyclability and the 2035 and 2038 steps;Art. 7(1),(2)and(8)for recycled content;Art. 9for compostability;Art. 10for minimisation;Art. 12for labelling;Art. 24for empty space;Art. 25(1)and(6)and Annex V for the bans;Art. 28(5)for refill;Art. 29for reuse;Art. 43for prevention targets;Art. 50(1)and(2)for deposit and return;Art. 70andArt. 71for application and transition dates; and recital 72 on the heavy-metal limit not being new -
Regulation (EU) 2025/40 — EUR-Lex, German text Official. Read to check the one date this page turns on, because it reads oddly in both versions:
Art. 24(4)— „Bis zum 12. Februar 2028 stellen die Wirtschaftsakteure, die die Verkaufsverpackungen befüllen, sicher, dass der Leerraum auf das für die Gewährleistung der Verpackungsfunktionen, einschließlich des Produktschutzes, erforderliche Mindestmaß beschränkt ist." -
European Commission — PPWR Frequently Asked Questions, 2nd edition (KH-01-26-068-EN-N), August 2026 Official, not binding. Read for this page from the copy we mirror and describe here. Source for the divergences we flag: chapter X question 2, whose date list puts minimisation at 1 January 2030 and sends void space in sales packaging to
Art. 10; chapter XI questions 1 to 4, which set out the 50% cap, the obligated party, the "minimum necessary" test and the empty-space method due by 12 February 2028; chapter VI question 1 for compostability applying from 12 February 2028; chapter VII questions 1 and 3 for minimisation dates and the standardisation request; chapter V question 12 forArt. 5(1)and(4)applying to all packaging from 12 August 2026; and chapter I's summary of main provisions -
TÜV SÜD — "Lebensmittel: TÜV SÜD informiert über die neue EU-Verpackungsverordnung" (press release, 7 October 2026) Secondary, and the briefing this page answers. Read in full. Source for the "Ab Februar 2028" void-space line, the "ab nächstem Februar" compostability line we could not confirm, the "strengere Grenzwerte" for heavy metals, the refill figure, the 2029 deposit-return line and the statement that the VerpackDG entered into force on 12 August 2026. A certification body's consumer summary, not the legal text, and it carries commercial interest in PPWR conformity work
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Wochenblatt Reporter — "Neue EU-Regeln für Lebensmittelverpackungen" (7 October 2026) Secondary. The republication that put the briefing in front of us, read in full. It carries the same dates as the TÜV SÜD release and adds the "Nach Angaben von TÜV SÜD" attribution, which is why both are listed as secondary on every row above
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Verpackungsrecht-Durchführungsgesetz (VerpackDG) — full text, gesetze-im-internet.de Official text, non-official consolidation. Source for the title, the date of 13 July 2026 and the citation BGBl. 2026 I Nr. 207, and for § 68, whose transitional rules distinguish the old Verpackungsgesetz as in force until 11 August 2026 and set the first notification deadlines on 12 August 2026 and 12 November 2026. The consolidated text does not print an entry-into-force article, so the exact in-force date comes from the transition rules and the TÜV SÜD release
Help us keep this page honest
This page is a table, so it is only as good as its rows. The most useful thing
anyone could add is a row we cannot write from Vienna: what a market
surveillance authority in your country actually asks for, and when. If your
Kammer, your Verband or your authority has published its own reading of
Art. 24(4) — especially if it takes the 2030 side — send it over.