Regulation (EU) 2025/40, the PPWR, has applied generally since 12 August 2026. What started on that date was chemical restrictions, role definitions, conformity documentation and extended producer responsibility. The packaging design rules — labelling, empty space, recyclability, recycled content, bans and reuse — did not. They are staged from 2028 to 2040, and this article is about those.
Before the dates, the caveat, because it changes what you should do with them. The Article 6, 12 and 24 dates are conditional on implementing or delegated acts, and we could not confirm those acts as adopted at the time of writing. Each of those obligations applies from the stated date or a fixed period after the relevant act, whichever is later. That formula only moves dates later. It never pulls them forward.
2028 and 2029: harmonised labelling
Harmonised labelling under Article 12(1) covers material pictograms and sorting information on the packaging. It applies from 12 August 2028, or 24 months after the implementing act, whichever is later. The implementing act is what defines the actual pictograms, so the design work cannot honestly be finished before it exists.
Reusable-packaging labelling under Article 12(2) follows from 12 February 2029, or 30 months after the implementing act, whichever is later. This one only matters if you put reusable packaging on the market, which most small sellers do not.
The practical consequence of both is about print runs rather than about design philosophy. If you order printed boxes or labels in quantities that last two or three years, the 2028 date is already inside your ordering horizon, and it is worth asking your supplier now whether they will reprint plates when the pictograms are published and who pays for that.
1 January 2030: the 50 percent empty space rule
Article 24 sets a maximum of 50 percent empty space in grouped packaging, transport packaging and e-commerce packaging. It applies from 1 January 2030, or three years after the implementing act, whichever is later. Alongside the ratio, the article bans false bottoms and other design features that create the illusion of a larger volume.
This is the rule that generated the most alarmed coverage in 2026, usually described as already in force. It is not. But it is the one with the largest operational footprint for an online shop, because it touches box sizes, void fill, pick and pack, and shipping rates all at once.
The empty space rule is not in effect and will not be before 1 January 2030 at the earliest. If a supplier or a compliance vendor is selling you a fix for it today on the basis that it already applies, that is a reason to question the rest of what they tell you.
1 January 2030 onwards: design for recycling
Article 6 introduces design for recycling from 1 January 2030, or 24 months after the delegated act, whichever is later. Two further steps follow: packaging must be recyclable at scale from 1 January 2035, and must meet a grade B minimum from 1 January 2038.
The grading criteria live in the delegated act, so what counts as grade B is not something anyone can tell you with confidence yet. What is already directionally clear is that mixed-material packaging which cannot be separated in a normal sorting stream is the format most exposed. If you are designing new packaging from scratch this year, single-material construction is the safer bet, and it is usually cheaper anyway.
1 January 2030: recycled content in plastic packaging
Article 7 sets minimum recycled content in plastic packaging from 1 January 2030, by category:
- 30% for contact-sensitive PET, excluding single-use plastic beverage bottles
- 10% for other contact-sensitive plastics
- 30% for single-use plastic beverage bottles
- 35% for all other plastic packaging
On 1 January 2040 these rise to 50%, 25%, 65% and 65% respectively. The 35 percent band is the one that reaches the widest range of ordinary sellers, because it covers the polybags, films and mouldings that are not food contact and not beverage bottles.
This is a supplier question rather than a design question. You will not be blending resin yourself. What you will need, in 2030, is documentation from whoever makes your plastic packaging, and it is reasonable to ask them today whether they expect to supply compliant material and at what premium.
1 January 2030: banned single-use formats
Article 25 bans the single-use formats listed in Annex V from 1 January 2030. The list is specific rather than general:
- Shrink-wrap used to group multipacks
- Plastic packaging for fresh fruit and vegetables under 1.5 kg
- Single-use plastic for on-premises consumption in hospitality
- Condiment, sugar and creamer sachets in hospitality
- Hotel miniatures
- Very lightweight plastic carrier bags
Most of that list is aimed at grocery, hospitality and hotels. If you sell durable goods online, the only entry likely to touch you is shrink-wrap grouping, and only if you sell multipacks.
1 January 2030: reuse targets
Article 29 sets reuse targets from 1 January 2030: 40% for transport packaging, with 100% for movements within a single operator and between operators in the same Member State; 10% for grouped packaging; and 10% for beverages. On 1 January 2040 these become 70%, 25% and 40%.
Reuse targets are where the gap between a large operator and a small one is widest. A company moving goods between its own sites on its own pallets can plan a reusable system. A seller shipping single parcels to consumers through a carrier has far less control, and how these targets land on that model is one of the areas where implementation detail will matter a great deal.
How firm are these dates, really
Firmer than they look for planning, softer than they look for spending. Two things are true at once. The obligations themselves are in a regulation that is in force, so they are not proposals and they are not going to quietly disappear. But the dates attached to several of them depend on acts that had not been confirmed adopted when we wrote this, and the whichever-is-later formula means the real date can only be the stated one or a later one.
So plan against the stated date. Do not spend against it until the underlying act exists, because the specification you would be buying compliance with has not been written yet. That is not procrastination; it is the difference between a date you can diarise and a date you can sign a purchase order against.
What is worth doing now, and what is not
- Worth doing: talk to your packaging supplier. Ask what they are planning for labelling in 2028, for recycled content in 2030, and whether prices move. One conversation, once a year
- Worth doing: stop ordering three years of printed stock. Shorter print runs cost a little more per unit and remove the risk of a warehouse full of packaging with the wrong pictograms
- Worth doing: prefer single-material construction when you are choosing new packaging anyway. It is the direction of travel in Article 6 and rarely costs more
- Worth doing: put 2028 and 2030 in the calendar with a review a year before each, by which point the implementing and delegated acts should be known
- Not worth doing: redesigning packaging in 2026 for rules whose technical criteria are not published
- Not worth doing: buying an empty space audit for a rule that does not apply for years
- Not worth doing: switching to recycled-content plastic early at a premium, unless it sells better, in which case do it for that reason and not for compliance
For most small sellers the honest answer is that nothing about your packaging needs to change this year. The obligation that actually bites right now is registration in each national packaging register where your parcels land — not the design of the box.
One boundary from our side. We are accountants, not a packaging laboratory or a law firm. We can keep the Estonian register, recovery organisation reporting and excise in order, and we can tell you which of these dates plausibly reaches your product. Whether a specific laminate meets a grade B criterion in 2038 is a question for a materials specialist, and we will say so rather than guess.
Frequently asked questions
When do the PPWR labelling requirements apply?
Harmonised labelling under Article 12(1) applies from 12 August 2028, or 24 months after the implementing act, whichever is later. Reusable-packaging labelling under Article 12(2) follows from 12 February 2029, or 30 months after the act.
Is the PPWR empty space rule in force?
No. The maximum 50 percent empty space rule for grouped, transport and e-commerce packaging is in Article 24 and applies from 1 January 2030, or three years after the implementing act, whichever is later.
What recycled content will plastic packaging need in 2030?
From 1 January 2030: 30% for contact-sensitive PET other than beverage bottles, 10% for other contact-sensitive plastics, 30% for single-use plastic beverage bottles and 35% for all other plastic packaging. These rise in 2040.
Which single-use packaging formats will be banned?
From 1 January 2030 Annex V bans shrink-wrap grouping multipacks, plastic packaging for fresh produce under 1.5 kg, single-use plastic for on-premises hospitality consumption, condiment, sugar and creamer sachets, hotel miniatures and very lightweight carrier bags.
Can the PPWR dates move?
Later, yes. Several obligations apply from a stated date or a fixed period after an implementing or delegated act, whichever is later. We could not confirm those acts as adopted, so the dates can slip later but never earlier.
Should I redesign my packaging now?
For most small sellers, no. The technical criteria sit in acts that are not published, so a redesign today may not match the final specification. Talk to your supplier, avoid very long print runs, and revisit a year before each deadline.
TagsPPWR labelling requirementsPPWR empty space rulePPWR recycled content 2030EU packaging design rules
General information, not tax advice
This article reflects Estonian law as it stands on the date shown. Rules change and individual circumstances differ - confirm your own position with us before acting.