Packaging and Packaging Waste Regulation (PPWR)
FAQs on the new EU Packaging Regulation

Packaging and Packaging Waste Regulation (PPWR)

The new EU Packaging and Packaging Waste Regulation (PPWR) aims to reduce the environmental impact of packaging. Among other things, it stipulates that by 2030, all packaging placed on the EU market must be recyclable. Companies must adapt the design and material use of their packaging to increase recycling and reuse.

The EU Packaging and Packaging Waste Regulation (EU) 2025/40 was published in the Official Journal of the European Union on 22 January 2025. It will come into force on 12 February 2025 and will be valid from 12 August 2026.

Many questions arising from the regulation cannot be conclusively answered at this time. To this end, so-called delegated legal and implementing acts will initially be required to define and establish further details of the affected articles of the regulation for all EU member states and stakeholders. This process may take several years. Jokey will closely monitor developments and engage in an ongoing dialogue with its network partners, customers and stakeholders.

As part of the EU Green Deal, the PPWR is an important milestone on the road to a circular economy. Jokey’s sustainability activities are also geared towards the transition to a circular economy for plastics and a clear CO₂ roadmap. For years, the Jokey Eco Concept 4.0 with its four pillars has been focusing on recyclable, reusable packaging made from secondary raw materials, particularly at the product and resource level. Jokey is therefore already well positioned with regard to the requirements of the PPWR.

Scope:

Packaging should be designed, manufactured and distributed in such a way that it can be reused as often as possible or recycled to a high standard and that its impact on the environment is minimized throughout its life cycle and the life cycle of the products for which it was designed.

Implementation:

• in line with the Green Deal and the Circular Economy Action Plan
• largest regulatory intervention ever in the packaging market
• from a directive to a regulation with direct binding effect in the EU Member States
• 71 articles, 13 appendices, 344 pages
• the articles are later implemented and detailed in delegated acts, implementing acts, reports and evaluations, further CEN standards, guidelines and legislative proposals
• August 12, 2026: valid and binding for all member states

Article 1 of the PPWR describes the subject matter, scope and requirements of this regulation. It also sets out the objectives of the regulation, in particular with regard to environmental protection, the circular economy and climate neutrality. Article 2 clarifies that the regulation applies uniformly to all packaging and packaging waste in the EU, regardless of the material used.

The scope of the PPWR, as described in the first two articles, suggests that a number of detailed questions still need to be clarified. This is absolutely essential given that the EU regulation is to be implemented in all member states simultaneously and in a timely manner. The following table provides a structured overview of the PPWR and its contents. The regulation can be found online in the Official Journal of the EU in all official languages.

The PPWR will be binding on all member states from 12 August 2026. Jokey therefore recommends that its customers familiarise themselves at an early stage with the definitions for the purposes of the regulation in Article 3 in order to find out whether and at what point in time they are affected by implementation obligations. The following timelines illustrate the implementation process.

Further information can be found here:

• DENTONS: Indicative timeline for the application of the individual provisions of the PPWR (7 March 2025)

The new regulation applies to all packaging and packaging waste placed on the market in the European Union, regardless of the type of packaging or material used. This makes the regulation relevant for companies in all sectors. It defines comprehensive requirements for recyclability and sustainable packaging design. The new regulation focuses on the obligation to regulate the entire life cycle of packaging. In doing so, it aims to help strengthen the circular economy, reduce packaging waste and protect consumers from substances of concern in packaging. The PPWR focuses on three main topics:

Recyclability

Article 6 of the PPWR stipulates that packaging must be recyclable. It defines the requirements that must be met in a two-stage approach. Since 2017, the Jokey Eco Concept has been based on holistic recyclability and includes the field of action of a recyclable packaging design with the aim of achieving maximum technical and functional packaging performance in a circular economy. The Jokey Eco Concept is now in its fourth generation and comprises four pillars, which also reflect the two core requirements of recyclability and the use of recycled materials in the PPWR. This means that Jokey products are already well prepared for these requirements. With a group-wide design guideline, Jokey is already ensuring implementation at all 14 Jokey locations. The goal: All Jokey packaging should achieve the highest level of performance with at least 95 per cent recyclability in accordance with Article 6 of the PPWR.

Minimum recycled content

Article 7 of the PPWR stipulates that from 1 January 2030, all plastic packaging must contain a certain minimum amount of recycled materials obtained from consumer plastic waste In fact, a true circular economy only works if packaging finds its way back into new packaging as recycled packaging raw materials after use. The Jokey Eco Concept supports the circular economy and, in the Eco Resources pillar, deals with secondary raw materials that are an indispensable part of a functioning circular economy. With regard to Jokey packaging made of polypropylene (PP), the following minimum percentages apply

• 10 per cent for all contact-sensitive packaging (Art. 7 para. b)
• 35 per cent for all other packaging (Art. 7 para. d

Jokey has been involved in the reuse of recycled materials for the production of new packaging since the introduction of the Packaging Ordinance (VerpackV) in Germany in 1991. The Jokey Eco Concept and the “Grey is the new green” initiative launched in 2018 aim to draw attention to secondary raw materials in order to continuously increase their use. Jokey’s many years of experience in processing post-consumer recyclates already enables it to significantly exceed all the requirements for non-contact-sensitive packaging listed in Article 7 (d) of the PPWR.

For the area of contact-sensitive packaging (Art. 7 para. b), Jokey offers solutions with recyclates from chemical recycling. Together with Remondis, Jokey is working on being able to offer secondary raw materials from material recycling for contact-sensitive packaging soon.

Depending on the quality of the recyclate and the technical requirements for the packaging, almost all Jokey packaging can now be manufactured with a post-consumer recyclate content of over 90 per cent from household collections or from commercial closed loops in the non-food and food industry. Jokey is certified according to ISO 15343 and is allowed to use the RAL quality mark to transparently and reliably identify the proportion of post-consumer recyclates used.

Reusability

Article 29 of the PPWR requires economic operators, subject to certain exceptions, to manage certain packaging formats as reusable packaging within a reuse system, either in full or to a certain extent, from 1 January 2030. Specifically, the reusability rates apply to the following packaging formats, which fall under these two packaging categories, “of all sizes and materials” (Art. 29 (1)):

• Pallets
• Pallet covers and straps to stabilise and protect products transported on pallets Crates (except for those made of cardboard; see exceptions in Art. 29, Sec. 4 d)
• Plastic crates
• Trays
• Intermediate bulk containers
• Buckets
• Barrels
• Canisters

The implementation of the reusability requirements is complicated by the fact that none of the packaging formats mentioned in Art. 29 (1) are defined – neither in the text of the regulation nor in the underlying impact assessment. Some of the packaging formats mentioned can be assigned to the common designations on the market on the basis of industry standards: this applies to pallets, strapping, intermediate bulk containers, drums and jerricans. For the other formats, however, there are some significant and highly relevant questions of demarcation that cannot be clarified on the basis of the legislative materials and preparatory work. This is not only a problem with the German translation of the original English version, but also results from the partial ambiguity of the English terms. At present, it is necessary to wait until the open questions regarding the distinction are clearly defined by the legislator.

Reusable service packaging

Since 2023, Jokey’s subsidiary brand Keepin has been offering reusable solutions in the field of service packaging. The material and design meet the requirements for reusability and a circular economy very well. Jokey also has experience in the field of reusable food packaging and could contribute this if required by law.

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Further information can be found here:

• Jokey Eco Concept 4.0
• Jokey Jokey Group and REMONDIS Group: Working together for a closed loop in the food industry
• Closed Loop: Jokey is cooperating with the Zentek Group
• Closing material loops while increasing transparency
• RAL Gütegemeinschaft Rezyklate
• KeepIn / WWF: Together with KeepIn for optimised reusable solutions
• KeepIn: Specialists in sustainable reusable packaging

From 12 August 2026, the respective producer must issue a written declaration of compliance for each type of packaging, and keep it together with the relevant technical documentation. They must also hand over the declaration of compliance to a national authority upon justified request. Such a declaration of compliance already exists, for example, for food packaging. In future, they will apply to all packaging and are intended to demonstrate the “compliance of a product’s packaging” (see recital 110) with the requirements of Articles 5 to 12.

Here you can find the legal text of Article 5 of EU Regulation 2025/40

From 12.08.2026, the PPWR requires that substances of concern in packaging be kept to a minimum. This concerns SVHC substances according to REACH, hazardous substances according to CLP, substances under the POP Regulation and those that have a negative impact on reuse and recycling. Special limits apply to lead, cadmium, mercury and hexavalent chromium (max. 100 mg/kg).

Below we explain our current practice for declarations of conformity for food packaging. All packaging made from virgin plastics – whether for the food industry or for sensitive packaging – complies with this practice.

For the production of Jokey packaging in the food sector, we only use raw materials and additives that comply with Regulations (EU) No. 10/2011 and (EC) No. 1935/2004 and have been tested by accredited laboratories. These regulations lay down special rules for plastic materials and articles that come into contact with food. The Union list of Regulation (EU) No. 10/2011 contains the authorized substances for the production of plastics.

The regulation contains clear rules on supply chain communication and the health assessment of materials. The declaration of compliance is used to communicate relevant information to the downstream stages. As a manufacturer of food packaging, we request the declaration of compliance from our suppliers and carry out migration tests on the end product, including worst-case calculations. In addition to regulated substances, plastics may also contain unintentionally introduced substances (NIAS), which we evaluate as part of a risk assessment.

In addition to plastics, Jokey also uses printing inks and IML labels to decorate the packaging. We are guided by the Swiss Printing Ink Ordinance and the EuPIA Guideline, which contain positive lists of permitted substances. 9 of the 14 Jokey sites are BRCGS-certified, which guarantees high standards for product quality and safety.

Special limits for perfluorinated and polyfluorinated alkyl substances (PFAS) were introduced in the legislative process. From 12.08.2026, packaging that comes into contact with food must not contain PFAS above certain limits. Compliance with these limits must be verified in the technical documentation.

Please take into account:

The following information has yet to be defined and published by the European legislator:

• By mid-2026: The European Chemicals Agency ECHA is expected to issue a recommendation on the general restriction of PFAS by the Commission in mid-2026. The problem is that there are currently no generally recognized, standardized test methods for the PFAS content in packaging and the Commission has no mandate to have these developed. In this respect, it remains unclear how conformity with the limit values is to be proven.
• By 12.08.2030: Evaluation of whether PFAS limit values are changed or abolished.
• By 12.08.2033: Evaluation of the restriction of substances of concern to a minimum level.
• Unlimited: Reduction of limit values and exemptions for recyclates and cycles.
• 31.12.2026: Report on substances of concern in packaging.

Further information:

Guide Recyclates in food packaging

We will keep you informed about new findings on articles on our sustainability website. This service will be available to you from 07.2025.

Here you can find the legal text for Article 6 of EU Regulation 2025/40

From January 1, 2030, all packaging placed on the market in the EU must be recyclable.

The producer (filler) shall assess the recyclability of the final (filled) packaging on the basis of the delegated acts adopted pursuant to paragraph 4 of this Article and the implementing acts adopted pursuant to paragraph 5 of this Article (Art. 6 (3)). The supplier (Jokey) shall provide all technical information and documentation on the delivered (empty) packaging that is necessary for the assessment of recyclability.

Please take into account:

The following information has yet to be defined and published by the European legislator:

• It will only be possible to assess the recyclability of packaging once the Commission has defined the criteria for recycling-oriented design and the performance levels for all packaging categories in Table 1 of Annex II (see Art. 6 (4)).

These delegated acts are to be adopted by January 1, 2028 at the latest. Without knowledge of these criteria, it is not possible to prove the recyclability of packaging within the meaning of the PPWR.

You can find more information on our current state of practice:

Evaluation of the recyclability of our products

Here you can find the legal text of Article 7 EU Regulation 2025/40

As part of an implementing law, the Commission will define the format of the technical documentation for the verification of the recycled content by 31.12.2026 (see Art. 7 para. 8). The PPWR gives the Commission the option of having “producers of recyclate in the EU” and producers of “plastic packaging placed on the market as a separate sales unit from other products” carry out audits by independent third parties. It is still unclear whether such an audit obligation will be introduced. The audit requirement would possibly apply to plastic recyclers and producers of transport, service and primary production packaging containing plastic. It would not apply to producers of packaging material and empty sales and secondary packaging containing plastic, as the “producer” of this packaging is the filler and the filled packaging is not “placed on the market as a sales unit separate from other products”.

The recyclate use rates shown in red in the diagram below apply to the packaging used by Jokey.

Jokey is currently only able to meet the recyclate usage quotas for contact-sensitive packaging to a limited extent. Post-consumer recyclates from mechanical recycling are only available to a limited extent for polyolefins such as PE and PP. However, Jokey is working together with REMONDIS on a pilot and development project to recover recyclates from used food packaging for reuse in contact-sensitive packaging.

Alternatively, recyclates from chemical recycling are available in limited quantities and at high cost prices, although these have not yet been finally approved by European legislators for quota fulfillment. However, we expect (partial) approval by 2026.

The following packaging is defined as contact-sensitive (see Art. 3 Para. 1 No. 49), whereby exemptions from the obligation to use recyclates apply to many of these types of packaging (see Art. 8):

• Food within the meaning of EU Regulation No. 1935/2004
• Food supplements within the meaning of EU Directive 2002/46/EC
• Feed within the meaning of EU Regulation 767/2009
• Additives for use in animal nutrition within the meaning of EU Regulation 1831/2003
• Cosmetic products within the meaning of EU Regulation 1223/2009
• Medicinal products for human use within the meaning of EU Directive 2001/83/EC
• Veterinary medicinal products within the meaning of EU Regulation (EU) 2019/6
• Medicated feed within the meaning of EU Regulation 2019/4

For non-sensitive packaging, the PCR quotas framed in red in the diagram will apply from 2030. Jokey can technically meet these quotas, provided that the quantity and quality of recyclate is guaranteed. Jokey already processes many thousands of tons of secondary raw materials to produce new packaging for the non-food industry. The recyclates are obtained from post-consumer collection streams and subsequent mechanical processing.

Jokey is certified in accordance with EN 15343. This standard deals with the traceability of plastic recycling and the proportion of recycled plastic. It sets out requirements to ensure that manufacturers and packers of plastics meet strict traceability and recycling requirements.

Please take into account:

Important information from the legislator is still outstanding. As a result, no or only limited relevant information can be provided at present.

• Until 31.12.2026: Calculation and verification method of the recycled content (implementing act)
• Until 31.12.2026: Sustainability criteria for recycling technologies (third countries) (delegated act)
• Until 31.12.2026: Method for assessing, verifying and certifying the equivalence of rules in third countries (implementing act)
• By 31.12.2026: Evaluation of available recycling technologies in terms of economic performance and environmental compatibility (mandatory review measure)
• By 01.01.2028: Review whether exemptions from quotas in Art. 7(1) b-d or revision of exemptions in Art. 7(4) are required for certain plastic packaging (mandatory review measure)
• By 12.02.2032: Review of the quotas for 2040 and the exceptions (mandatory review measure)
• By 12.02.2032: Review whether recyclate use quotas are also appropriate for other packaging materials (mandatory review measure)
• Indefinite: Review of the quotas in Art. 7(1) and (2) in exceptional cases of lack of availability or excessive prices for certain post-consumer recyclates (delegated act)

We recommend:

Please ask your Jokey sales representative about the possibilities of using secondary raw materials in the packaging products you purchase.

We do not refer to Article 8 because Jokey does not currently produce packaging from bio-based raw materials and Jokey products are not compostable.

We do not refer to Article 9 because Jokey does not currently produce packaging from bio-based raw materials and Jokey products are not compostable.

Here you can find the legal text of Article 10 EU Regulation 2025/40

From January 1, 2030, producers (fillers) or importers of packaging placed on the market must ensure that packaging is designed in such a way that its weight and volume are reduced to the minimum necessary to ensure its functionality, taking into account the shape and material. Corresponding proof must be provided in the technical documentation as part of the declaration of conformity.

The supplier (Jokey) provides all technical information and documentation on the delivered (empty) packaging that is required for the preparation of the declaration of conformity:

a) Explanation of the technical specifications, standards, etc. used in the assessment of the minimum volume and weight, including reference to technical guidelines and product specifications of the packaging supplied by Jokey (incl. information on dimensions, volume, weight, material, logistics, load capacity).

b) Description of the requirements for each of the performance criteria listed below (Annex IV, Part A) that prevent a reduction in packaging weight or volume:

• Product protection: Jokey supplies rigid, waterproof and resealable packaging.
• Filling: Compatibility with common filling systems (stackable and unstackable, suitable for automatic filling) is guaranteed.
• Logistics: Jokey packaging can be stacked when empty and filled. The load capacity of the lowest filled container in the stack in the warehouse and during transportation can be found in the product specification.
• Functionality: Jokey packaging is easy to open and reseal, and handling is made possible by carrying handles or plastic hangers.
• Information: Jokey offers various decoration options, e.g. in-mold labelling or direct printing.
• Hygiene and safety: Jokey packaging is usually fitted with a tamper-evident closure and can be resealed.
• Legal requirements, including recyclability, recyclate content and reuse: Jokey packaging fulfills all conditions for high-quality technical recyclability, the recyclate content is tested in accordance with EN 15343. Reference to secondary use but no reuse for the same purpose (see also our explanations here Art. 6 and 7)

c) All test results, market studies or investigations that were used for the assessment according to a) and b)

Here you will find our technical guidelines. You can find our article specifications on our product page after selecting your product.

Please take into account:

By 12 February 2027, the Commission shall, where appropriate, request the European standardization organisations to develop harmonised standards setting out the methodology for the calculation and measurement of compliance with the requirements for the minimization of packaging under this Regulation.

Here you can find the legal text of Article 11 EU Regulation 2025/40

From February 11, 2025, packaging will be considered reusable if it can be reused several times and complete many cycles. It must meet consumer health, safety and hygiene requirements and must not be damaged during emptying or unloading. Packaging must be able to be refilled or reloaded in compliance with the safety and hygiene regulations and offer the possibility of reconditioning in accordance with Annex VI Part B. It must allow labels to be affixed and information to be provided and meet the specific requirements for recyclable packaging in accordance with Article 6.

Please take into account:

By February 12, 2027, the Commission will adopt a delegated act specifying the minimum number of recycling cycles for reusable packaging.

Here you can find the legal text of Article 12 EU Regulation 2025/40

From 12 August 2028, packaging in the EU must bear a harmonised label that indicates the material composition and facilitates sorting. This labelling must be easy to understand and can be supplemented by a QR code that provides additional information. Packaging containing substances of concern must be digitally labeled. From February 12, 2029, reusable packaging must bear a label that provides information about its reusability and can also be supplemented by a QR code. The labels must be clearly visible, legible and firmly attached and the information must also be available online.

Please take into account:

• From 12.8.2028 or two years after the entry into force of the corresponding implementing acts by the Commission, whichever is later, packaging that is made available in the EU for the first time must be provided with a harmonised label (see Art. 12 para. 1).
• By 12.8.2026, the Commission is to define requirements for harmonised labelling and for the indication of the material composition within the framework of implementing acts (see Art. 12 (6) and (7)).

In this respect, it is currently still unclear which specific labelling requirements will apply.

Jokey would be happy to help you implement the PPWR. We will support you with all the important answers to your questions. Just talk to our sales team or use our exclusive email contact:

The information in this document is for general information purposes and should not be construed as legal advice. Despite our efforts to ensure that the information is up-to-date and accurate, we cannot guarantee that the content is complete, correct and up-to-date.

The application of the EU Packaging Regulation may vary depending on the individual case. We are not liable for any damages resulting from the use of the information and cannot provide legally binding answers on the PPWR. Always consult the official legal texts and guidelines of the competent authorities. Jokey reserves the right to change or update the content at any time.

To give you a brief overview of our sustainability activities, we have summarised them in an overview. This should make it easier for you to identify relevant topics and focal points, which can then be discussed in more detail on our website or in a personal meeting.

You will also find answers to many of your questions on our sustainability page.

And then, of course, we will also be happy to help you personally via your known sales contacts or by e-mail to our service address ppwr@jokey.com.

Documents and information available for inspection:

• PPWR legal texts