Prepared as part of the European Union’s efforts to reduce packaging waste and strengthen its circular economy objectives, the Packaging and Packaging Waste Regulation (PPWR) will become directly applicable in all EU Member States as of 12 August 2026.
Adopted by the Council of the European Union and the European Parliament on 19 December 2024 and published in the Official Journal of the European Union on 22 January 2025, the regulation establishes a single EU-wide framework governing the technical, environmental and market-related conditions applicable to packaging.
From Directive to Regulation: What does this mean?
While reshaping the existing legal framework for packaging, the PPWR will progressively phase out the application of Directive 94/62/EC on Packaging and Packaging Waste. Certain technical provisions and transitional arrangements will continue to apply according to staggered timelines extending into 2028, 2029 and 2030.
Under EU law, directives require transposition into national legislation by Member States, whereas regulations apply directly and uniformly without the need for national implementing measures. In this respect, the PPWR is expected to ensure a more harmonised application of packaging rules across the EU internal market.
The Regulation applies to all packaging placed on the EU market
The regulation applies to all packaging placed on the EU market, regardless of whether it is produced within the EU or imported from third countries. As a result, the PPWR has direct implications for non-EU exporters supplying packaged products to the European market.
Regardless of the product itself, compliance of the packaging with the criteria set out in the regulation will become a prerequisite for access to the EU market.
How will packaging be assessed under the PPWR?
The PPWR introduces a phased approach to recyclability requirements for packaging.
From 1 January 2030, all packaging placed on the EU market must be “designed for recycling”.
From 2035 onwards, design criteria alone will no longer be sufficient. Packaging will also be assessed based on whether it can be effectively and at scale recycled within recycling infrastructures established in the EU.
To this end, packaging will be classified according to recyclability performance into classes A, B and C. Packaging falling below class C will be considered technically non-recyclable and its placement on the EU market will be restricted.
This classification will be based on design-for-recycling criteria from 2030, and on both design and actual recycling performance from 2035 onwards. From 1 January 2038, only packaging achieving at least class B recyclability will be allowed on the EU market.
The PPWR therefore goes beyond the concept of packaging merely being “designed for recycling” and adopts an approach that requires recyclability to be demonstrated in practice and at industrial scale.
Accordingly, the European Commission will establish common methodologies for assessing design for recycling, chain of custody and the measurement of quantities of materials effectively recycled.
By 2030, Member States are expected to report the first data on quantities of packaging waste recycled by packaging category for the purposes of monitoring.
Textile packaging: technical exemptions, financial obligations remain
Under the PPWR, packaging made from materials such as textiles, wood, cork, rubber, ceramics and porcelain, which represent very low volumes on the EU market, is exempt from the technical recyclability performance requirements.
However, this exemption does not remove the financial obligations arising under Extended Producer Responsibility (EPR) schemes. In other words, while such packaging may fall outside the technical classification system, it remains subject to producer responsibility obligations.
What does this mean for Turkish exporters?
For companies exporting from Türkiye to the EU, the PPWR necessitates a reassessment of product packaging strategies.
In particular, the following elements are set to become integral parts of export processes:
- Compliance of packaging design with regulatory criteria
- Recyclability of materials used
- Traceability and documentation across the supply chain
- Potential financial obligations under EPR schemes
As the regulation will apply directly across the EU, independent of national implementation timelines, exporters are required to review and adapt their packaging strategies well in advance of the key compliance milestones.