PPWR timeline 2026-2040: every deadline that hits producers, on the verified dates

Search for a PPWR timeline and you will find dozens of infographics, many carrying dates the Regulation does not contain: a "1 January 2028" labelling deadline that does not exist, a "65% recycled content for all plastic packaging in 2040" that applies to specific categories only. Because packaging redesign cycles run 18 to 36 months, planning on a wrong date is expensive in both directions: too early wastes a redesign, too late means non-compliant stock.

This is the verified calendar of Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation, deadline by deadline from 2026 to 2040, with the commonly circulated errors corrected. It is written for producers, EU and non-EU alike, selling packaged goods into France and the rest of the EU. Each date states what applies and who is hit.

How to read the PPWR calendar

Two mechanics drive every date below.

The Regulation has direct effect. PPWR entered into force on 11 February 2025 and applies from 12 August 2026, in every Member State, without national transposition. Dates written in the text (2029, 2030, 2035, 2038, 2040) are firm unless the co-legislators amend the Regulation itself.

Many obligations hinge on implementing or delegated acts. The harmonised label, the design-for-recycling criteria behind the recyclability grades, and the recycled-at-scale methodology are all defined in Commission acts. Where the application date is "X or 24 months after the act, whichever is later", a late act pushes the obligation back automatically. Between each milestone, new delegated acts keep specifying the details, so the calendar below states which dates are act-dependent.

The verified timeline at a glance

Now each milestone in detail.

12 August 2026: the compliance infrastructure date

The first wave is not about the packaging itself but about who answers for it. From 12 August 2026:

• Article 45: any producer placing packaging or packaged products in a Member State where it is not established must appoint, by written mandate, an EPR authorized representative in that Member State. For France, that means a French-established representative; a producer selling into several Member States needs one per country.
• The producer status changes. PPWR defines the EPR "producer" per Member State: the first company placing the product on that national market, with online D2C sales assessed from the end-user's Member State. Many companies that never considered themselves "producers" in France become exactly that on this date.
• PFAS: food-contact packaging above the set PFAS thresholds can no longer be placed on the market.

This is the deadline we cover in depth in the 12 August 2026 countdown guide. One caveat belongs in every honest calendar: the pending Omnibus proposal (COM(2025) 982) would suspend the Article 45 obligation for some EU-established producers. It is not adopted, the Council discontinued negotiations on that suspension in June 2026 (Parliament pursues only a narrower version), and the proposal keeps the third-country framework in place, so for producers established outside the EU the 12 August 2026 date stands regardless.

2027-2028: the labelling prep dates, and one common confusion

An early labelling date is often missed: from 12 February 2027, on-pack marks identifying affiliation to an EPR scheme, the Green Dot being the obvious case, may only be displayed through digital means (a QR code or equivalent), and the delegated act on reusable-packaging labelling is due. Brands still printing the Green Dot on French or EU artwork should plan its removal into their 2026 artwork cycle.

Several circulating timelines then announce a "mandatory packaging marking on 1 January 2028". No marking obligation carries that date: the only 1 January 2028 in the Regulation is the Commission's own deadline to adopt the design-for-recycling delegated acts. Two real milestones sit in 2028:

• 12 February 2028: notably tea and coffee bags, sticky labels on fruit and vegetables and very lightweight plastic carrier bags must be compostable (industrial conditions).
• 12 August 2028, or 24 months after the Commission implementing act, whichever is later: the harmonised packaging label applies (sortability marking, material composition, reuse marking where relevant). The implementing act itself is due by 12 August 2026, so the practical window is late 2028 at the earliest. Once the harmonised label applies, national marks like the French Triman are not to be required on top; until then, they remain fully mandatory. The full state of play, including the Commission-vs-France case on the Triman, is in our EU sorting-label harmonisation guide.

1 January 2029: deposit return goes EU-wide

Member States must have deposit-return systems in place for single-use plastic beverage bottles and metal beverage containers up to 3 litres, meeting the Annex X minimum requirements, with schemes expected to reach 90% separate collection. Wine, spirits and milk are outside the mandatory scope. For beverage producers this is a packaging-design and logistics deadline as much as a legal one: labels, deposit marks and return flows have to be ready per country.

1 January 2030: the big bang

The single heaviest date in the Regulation. Six obligations land at once:

1. Recyclability grades. All packaging must reach grade A (at least 95% recyclable by design), B (at least 80%) or C (at least 70%). Anything below C is banned from the EU market. The grading runs on design-for-recycling criteria set by Commission delegated acts due by 1 January 2028; formally, this requirement applies from 1 January 2030 or 24 months after those acts, whichever is later.
2. Recycled content in plastic packaging. Minimum shares apply per unit: 30% for contact-sensitive PET packaging, 10% for contact-sensitive packaging in other plastics, 30% for single-use plastic beverage bottles, 35% for other plastic packaging.
3. Format bans (Annex V). Single-use plastic disappears for listed uses: fresh fruit and vegetables under 1.5 kg, food and drinks consumed in cafés and restaurants, single-portion condiments and sauces in HORECA, hotel miniature toiletries, and other listed formats.
4. Empty-space ratio. Grouped, transport and e-commerce packaging may not ship more than 50% air.
5. First reuse targets. 40% of transport packaging, 10% of grouped packaging and 10% of beverage packaging must be reusable within a reuse system, with wine excluded from the beverage target and intra-company and intra-EU B2B transport flows expected to run reusable.
6. Waste reduction. Member States must cut per-capita packaging waste by 5% versus 2018 by 2030, which feeds through into national measures and eco-modulated fees.

For any producer redesign started after mid-2028, the 2030 wave arrives faster than one packaging cycle. This is the date to plan backward from, now.

1 January 2035: recyclable in practice, not on paper

From 2035, design is no longer enough: packaging must be recycled at scale, meaning actually collected, sorted and recycled through installed infrastructure, per the Commission's methodology (formally, from 1 January 2035 or five years after the relevant implementing acts, whichever is the latest). A theoretically recyclable pack in a material nobody recycles loses its status. The per-capita waste-reduction target tightens to 10% by 2035.

1 January 2038: grade C exits

Only packaging graded A or B may be placed on the market. Grade C, tolerated since 2030, is out. A pack designed today to scrape 70% recyclability has a 12-year shelf life as a design.

1 January 2040: the end-state targets

• Recycled content step-up: 50% for contact-sensitive PET, 25% for contact-sensitive other plastics, 65% for single-use beverage bottles and 65% for other plastic packaging. The famous "65% in 2040" is real, but per category, not a single blanket figure.
• Reuse step-up: 70% transport packaging, 25% grouped packaging, 40% beverages.
• Waste reduction: 15% per capita versus 2018.

The three wrong dates to stop repeating

Because this article exists to be the accurate reference, here are the errors we see most often in circulated timelines, corrected:

What producers should do now

1. Close the 2026 file first. Appoint the authorized representative in every Member State where you sell without an establishment, France included, and register per stream. This is administrative lead time, not design lead time: it can be done in weeks, and our PPWR action plan sequences it.
2. Plan artwork against 2028, not 2030. The harmonised label lands mid-2028 at the earliest; if you print packaging in long runs, your 2027 artwork decisions should already anticipate it.
3. Run the 2030 audit in 2026-2027. Grade your packaging against A/B/C, check the recycled-content gap per material, test the Annex V exposure of your formats, and measure your e-commerce empty-space ratio. An 18-to-36-month redesign cycle started in 2028 is already tight.
4. Design for 2038, not 2030. If a redesign is happening anyway, targeting grade B or A immediately avoids paying for a second redesign when grade C exits.
5. Watch the acts, not the headlines. The label act, the design-for-recycling criteria and the recycled-at-scale methodology each restart a clock. We track them, and the Omnibus procedure, continuously.

France remains the strictest large market on the enforcement side (Triman and Info-tri labelling, SYDEREP registration, per-stream IDU), and it is where the PPWR meets an already-mature national system: our French EPR compliance guide covers that layer, and the cost calculator prices the representative side in 60 seconds.

Frequently asked questions

Is the whole PPWR postponed by the Omnibus? No. The Omnibus proposal (COM(2025) 982) targets a narrow slice, the Article 45 representative obligation for some EU-established producers, it is not adopted, and the Council discontinued negotiations on that suspension in June 2026. Every other deadline in this calendar is untouched by it, and the proposal keeps the third-country framework in place, so producers outside the EU are not relieved by it.

Do the 2030 recycled-content targets apply to my existing stock? The obligations attach to placing on the market. Stock lawfully placed before a deadline is generally covered by sell-off logic, but stock placed after it must comply, so inventory planning matters: long-lifecycle packaging bought in 2029 can become unsellable in 2030.

Are the recyclability grades already assessable today? The A/B/C architecture is in the Regulation, but the grading runs on design-for-recycling criteria set by Commission acts. You can and should pre-assess against the known thresholds (95/80/70%) and current recyclability guidance, then confirm when the acts land.

Does the PPWR replace French EPR? No. It harmonises packaging rules EU-wide, but the French EPR machinery (SYDEREP registration, IDU, eco-organisms, Triman and Info-tri until the harmonised label applies) continues, and the other French streams (WEEE, batteries, textile and the rest) are untouched by the PPWR. Both layers apply at once.

We sell into several Member States. Is one representative enough? No. Article 45 requires a representative in each Member State where you place packaged goods without being established there. We act in France only; for other Member States a separate locally-established representative is required.

Sources & references

Dates verified against the Regulation and corroborating official and specialist sources; act-dependent dates can move with the acts, and this article is not legal advice. Verified 22 July 2026.

• Regulation (EU) 2025/40 (PPWR), EUR-Lex
• European Commission, Packaging and Packaging Waste Regulation page
• Latham & Watkins, PPWR summary of provisions and new guidance
• Fieldfisher, new EU packaging rules: 10 key things
• Keller & Heckman, the new EU PPWR: highlights and challenges
• TOMRA, what the PPWR means for deposit return schemes
• Bio4Pack, compostable tea packaging under the PPWR
• Greiner Packaging, recycled content under Article 7