carbonormPPWR self-assessment · Reg. (EU) 2025/40
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Which PPWR obligations actually apply to you?

Most companies get this wrong in the first five minutes — they look up "the manufacturer's obligations" before checking whether they are a manufacturer at all. Under the PPWR you can hold several roles at once, and each one brings its own file. This assessment runs the three questions in the right order.

Three modules, in this order

  1. 01Who are you?Legal status across five stages of the packaging life — before market, market entry, commercial circulation, logistics, end use.
  2. 02What packaging is it?Functional qualification: sales, grouped, transport, e-commerce, service, reuse/DRS, multi-material.
  3. 03What is it made of?Predominant material, components and multi-material cases.
Why the order matters. Role × function × material is what selects your obligation set. Skip one and you end up reading the wrong article — or missing an EPR registration in a Member State you didn't think you were active in.

Where you are on the clock

12 AUG 2026
General application
Art. 6(1) · Art. 5 · Art. 44
12 FEB 2028
Empty-space minimisation in sales packaging
Art. 24(4)
12 AUG 2028
Harmonised label for material composition or 24 months from the entry into force of the implementing acts adopted pursuant to Art. 12(6) or 12(7), whichever is the latest
Art. 12(1)
12 FEB 2029
Label informing users that packaging is reusable or 30 months from the entry into force of the implementing act adopted pursuant to Art. 12(6), whichever is the latest
Art. 12(2)
1 JAN 2030
50% empty-space limit or 3 years from the entry into force of the implementing acts adopted pursuant to Art. 24(2), whichever is the latest
Art. 24(1)
1 JAN 2030
Minimum recycled content in plastic packaging or 3 years from the entry into force of the implementing act under Art. 7(8), whichever is the latest
Art. 7(1)
1 JAN 2030
Recyclability classes / design-for-recycling or 24 months after the delegated acts, if later
Art. 6(2)(a) · Art. 6(3)
1 JAN 2030
Demonstrating the re-use targets have been met or 18 months from the entry into force of the implementing act under Art. 30(3), whichever is later
Art. 30(4)
1 JAN 2030
10% of grouped packaging in box form must be reusable
Art. 29(5)
1 JAN 2030
40% of transport packaging must be reusable
Art. 29(1)
1 JAN 2035
The 'recycled at scale' condition starts to bite or 5 years from the entry into force of the implementing acts under Art. 6(5), whichever is the latest
Art. 6(2)(b)
1 JAN 2038
Only grade A or B packaging may be placed on the market
Art. 6(3)
1 JAN 2040
Raised recycled-content thresholds
Art. 7(2)
1 JAN 2040
70% / 25% re-use ambitions
Art. 29(1) · Art. 29(5)
≈ 4 minutes · 3 modules

General information, not legal advice. Every statement here cites the article it comes from so you can check it. Where a reading rests on Commission guidance rather than on the Regulation itself, it says so on the line.