JUNE 23, 2025

Resource Center: European Packaging Sustainability Legislation

ThermoSafe continues to round up relevant packaging legislation in this article so you have the information at your fingertips. The focus is on the European Union and we will continue to update this page with updates and country specific laws, where applicable.

After reading this comprehensive article, you will be able to better understand:

Updated August 26^th, 2025

1. The implications and requirements of the European Union Packaging and Packaging Waste Regulation (PPWR) and key exemptions for certain requirements, like for outer packaging used to maintain quality of medical products
2. The current timeline of various PPWR requirements and deep dive into the various sustainability and information requirements
3. Updates on proposed material bans and new labeling requirements
4. Simplification Omnibus proposal affecting the CSRD and CSDDD
5. Implications of European Union Deforestation Regulation (EUDR) and proposed Green Claims Directive

Packaging and Packaging Waste Regulation (PPWR)

In the EU, the Packaging and Packaging Waste Regulation (PPWR) will dictate the extended producer responsibility and sustainability/information requirements for packaging. It aims to reduce waste, conserve resources and support a circular economy by promoting sustainable packaging practices. It entered into force on February 11, 2025 and its general date of application is August 12, 2026.

General principles:

• Background
  • The requirements were initially established in the Packaging and Packaging Waste Directive 94/62/EC (PPWD) and are now governed by the Packaging and Packaging Waste Regulation 2025/40 (PPWR).
• Scope
  • PPWR sets standards for packaging allowed on the EU market while also addressing packaging waste management and prevention strategies.
  • Regulation aims to apply to all packaging and packaging materials, as well as to packaging waste that is made available on the market, placed on the market, and made available on the territory of a Member State
• Obligated parties
  • Economic operators – entities involved in the packaging supply chain including packaging manufacturers, suppliers, importers, and distributors.
  • Producers and Importers – companies that place packaging on the EU market, including manufacturers and businesses importing packaged goods
  • Retailers and Distributors – businesses that sell packaged products directly to consumers or other businesses
• Requirements
  • PPWR includes packaging and sustainability requirements for EU economic operators to follow including:
    • Designing for recyclability
    • Minimum thresholds for recycled content depending on the material and format
    • Maximum empty space percentages of packaging/void fill
    • Restrictions on substances and certain formats
    • Labelling of material composition to facilitate consumer sorting
    • Targets of reusability for transport packaging
    • Established harmonized extended producer responsibility
• Exemptions
  • The regulation clearly excludes immediate packaging of medicinal products and outer packaging of medicinal products (for human or veterinary use) “where such packaging is necessary to comply with specific requirements to preserve the quality of the medicinal product” from the recyclability, recycled content and labeling requirements (if there is no space on packaging or if label could jeopardize safe use of medicinal products).
• Implementation
  • Accompanying implementing acts detailing methodologies for calculating recyclability thresholds, recycled content minimums and other data needed for successful implementation of PPWR will be published in the next coming months/years.

PPWR Sustainability Requirements

• Substances in Packaging (Article 5)
  • Food contact packaging containing PFASs in concentration equal to or above given limit values will be banned
  • Packaging shall be manufactured minimizing the presence and concentration of substances of concern (SoC), like lead, cadmium, mercury and hexavalent chromium.
• Recyclability (Article 6)
  • Packaging recyclability will be defined as performance grades based on its ability to be recycled effectively:
    • Grade A: ≥ 95% recyclability
    • Grade B: ≥ 80% recyclability
    • Grade C: ≥ 70% recyclability
  • The methodology for assessing recyclability will be finalized by January 1, 2028, with implementation acts defining the criteria by January 1, 2030.
  • By January 1, 2030, packaging will not be allowed on the EU market unless recyclable within grades A, B or C.
  • By January 1, 2038, packaging will not be allowed on the EU market unless recyclable within grades A and B.
  • Recyclability Exceptions
    • Does not apply to immediate packaging of medicinal products, contact sensitive packaging of medical devices, infant formula, cereal-based food and baby food, and of food for special medical purposes
    • Does not apply to outer packaging of medicinal products (for human or veterinary use) used to maintain quality of medical products
• Minimum Recycled Content in Plastic Packaging (Article 7)
  • By 2030 and 2040, any plastic part of packaging will have to contain a minimum percentage of recycled content (typically post-consumer recycled content), at different levels depending on whether the packaging is or not contact sensitive
  • Targets are set per packaging type and format and will be calculated as an average per manufacturing plant and year
  • Recycled Content Exceptions
    • Does not apply to immediate and outer packaging of medicinal products
    • Does not apply to packaging of suppliers, components and immediate packaging components for the manufacturing of medicinal products
    • Does not apply to any plastic part representing less than 5% of the total weight of the whole packaging unit
• Compostability (Article 9)
  • By 3 years from the entry into force of PPWR, several packaging formats will need to be compostable to be allowed on the EU market.
  • Formats include permeable tea, coffee or other beverage bags, single serve units which are intended to be used and disposed of together with the product, and sticky labels attached to fruit and vegetables.
• Packaging Minimization (Article 10) and Waste Prevention (Article 43)
  • By January 1, 2030, packaging placed on the EU market shall be designed so that its weight and volume is reduced to the minimum necessary to ensure its functionality, considering its shape and material.
  • Methodology for packaging minimization assessment includes list of performance criteria such as product protection, packaging manufacturing processes, and logistics.
  • By January 1, 2030 or 3 years from definition of methodology to calculate the empty space ratio, a max 50% empty space ratio will be allowed in grouped packaging, transport packaging or e-commerce packaging.
  • Packaging Minimization Exceptions
    • Economic operators using reusable packaging within a system for reuse are exempt from complying with the max 50% empty space ratio.
  • PPWR introduces packaging waste prevention targets for Member States which are set per capita, as compared to packaging waste generated in 2018.
    • 5% by 2030
    • 10% by 2035
    • 15% by 2040
• Packaging Restrictions (Article 25 and Annex V)
  • From January 1, 2030, packaging formats listed in Annex V to the PPWR will no longer be allowed on the EU market
  • Formats include: single-use plastic packaging, including grouped packaging like collation shrink, packaging for unprocessed fresh fruits and vegetables, disposable packaging such as trays, plates, bags, and boxes, food service packaging for condiments, sauces, coffee creamer, sugar, and seasoning used in restaurants and cafes, and single-use packaging in the accommodation sector for individual bookings and very lightweight plastic carrier bags

PPWR Information Requirements

• Labeling (Article 12)
  • PPWR establishes standardized labeling and marking requirements for various packaging formats.
  • Standardized markings and labels will indicate material composition, packaging reusability, as well as the percentage of recycled content and bio-based plastic content helping consumer sort packaging. The PPWR also establishes consistent waste receptacle labeling across the EU.
  • Companies will have 3.5 to 4 years to comply, depending on labeling requirements linked to market access conditions.
  • Labeling Exceptions
    • These requirements do not apply to immediate and outer packaging of medicinal products or medical devices if space constraints exist or if labeling could compromise the safe use of medicinal products.
• Claims (Article 14)
  • Environmental claims on packaging need to follow PPWR, Empowering Consumers Directive and the future Green Claims Directive
  • Claims can be made only in relation to packaging properties exceeding the applicable minimum requirements set out in PPWR
  • Compliance with requirements shall be demonstrated in the technical documentation set out in Annex VII of the PPWR

Obligations of Economic Operators

• Reuse and refill (Article 11)
  • PPWR will introduce reuse targets for packaging used for different applications such as for transport and beverage from January 1, 2030
  • Transport, grouped and beverage packaging are applicable categories including pallets, foldable plastic boxes, trays, plastic crates, intermediate bulk containers, pails, drums and canisters, pallet wrappings or straps
  • Reuse Exceptions:
    • There are many exemptions including cardboard boxes, packaging used to transport dangerous goods, large-scale machinery, flexible formats that are in direct contact with food, feed or food ingredients.
• Extended Producer Responsibility
  • By February 2026, the European Commission will adopt implementing acts defining the registration format and reporting requirements for the register, including data granularity and covered packaging types and categories.
  • Within 18 months of the implementing acts being adopted, Member States must establish a register to monitor producer compliance with Extended Producer Responsibility (EPR) requirements.
  • It remains to be determined when the obligation for packaging producers to register in each Member State (where they make packaging or packaged products available) will begin
  • Modulation of EPR fees based on packaging recyclability performance grades and recycled content
• Manufacturers, Suppliers, Importers and Distributors
  • To prove packaging’s compliance with the PPWR, economic operators placing packaging on the market will need to carry out a conformity assessment procedure and draw up technical documentation, that they will need to keep for several years and present to market surveillance authorities when requested.

Outlook

The PPWR takes precedence over existing European Union packaging directives or national laws including the Single Use Packaging Directive (SUPD), Packaging and Packaging Waste Directive (PPWD), and Waste Framework Directive. PPWR will also establish a harmonized Extended Producer Responsibility (EPR) scheme.

Pharmaceutical

Based on ThermoSafe’s interpretation[1] of the language of the exceptions for the PPWR, temperature-controlled packaging used to maintain temperature/efficacy of a medical drug, biologic, or device would be excluded from the recyclability performance requirements, minimum recycled content thresholds, and labeling requirements. Packaging for medical drugs, biologics or devices will have to follow other requirements of PPWR.

Transport/Protective

Based on ThermoSafe’s interpretation of the language of the exceptions for the PPWR, transport packaging used to deliver product to the end consumer would need to comply with the recyclability performance requirements, minimum recycled content thresholds, and labeling requirements. Transport packaging used to deliver from business to business (B2B) is also regulated, but with different requirements and considerations, with the focus on durability, reuse, and recyclability performance requirements.

Material Bans and Labeling Requirements

While the PPWR is consuming much of the conversation regarding European packaging legislation, there are some other noteworthy regulations and key changes detailed below.

Material Bans

Proposed Styrene Polymer Ban – France

There was a proposed ban in France for nonrecyclable styrene compounds that would have gone into effect on January 1, 2025. This proposed ban has since been removed in favor of alignment with the PPWR. The original ban statement was included in Article 23 of the August 2021 version of the French Climate and Resilience Act. As of May 2025, this statement and proposed ban has been removed from the French Climate and Resilience Act and also not incorporated into the French Environmental Code within Article L541-15-10.

To summarize, the proposed ban of styrene compounds in France has been removed. Instead, the PPWR establishes recyclability requirements (≥70%) for all packaging from 2030 based on recyclability performance classes, as described above. The recyclability performance grades, associated timeline, and minimum thresholds will determine what type of packaging can be placed on the EU market. Finally, outer packaging of medical drugs, biologics, etc to maintain quality/efficacy of the product (i.e. expanded polystyrene insulation), is excluded from the recyclability requirements of PPWR.

Oxo-Degradable Additive Ban

Oxo-degradable plastics were effectively banned in the EU on July 1, 2021, implemented through the Single-Use Plastics Directive (Directive 2019/904).

It is important to differentiate between oxo-degradable, biodegradable and compostable. Oxo-degradable additives cause conventional plastics to break down and disintegrate into small pieces. Biodegradability refers to the ability to be broken down into simpler compounds by microorganisms, as part of the natural biological process of decomposition. Compostability refers to the ability to decompose under specific conditions into natural, non-toxic components like carbon dioxide, water, and biomass, leaving no harmful residues. While all compostable materials are biodegradable, not all biodegradable materials are compostable. Biodegradable materials may break down in the environment, but not necessarily into compost and may not provide nutrients to the soil.

ThermoSafe’s Biodegradable EPS is not oxo-degradable. Instead, this innovative material can be recycled via drop-off programs alongside standard EPS or it can enzymatically biodegrade over 90% within four years in a microbial-rich landfill environment.

Labeling Requirements

PPWR Labeling

The PPWR includes requirements (Articles 12 + 13)  for certain information to be included on labels including information of proper disposal, recyclability, and harmonized EU-wide separation instructions with easily understandable graphics. There may also be requirements to include digitally provided information via QR codes.

The following markings must be visible on the packaging:

• Packaging material composition
• Participation in a deposit system
• Packaging reusability
• Harmonized criteria for labeling recycled & bio-based plastic proportions
• Substances of concern
• EPR system participation
• Prohibition of misleading and confusing labeling
• Waste container for correct disposal

The following information must be provided digitally via QR code or similar technology:

• Manufacturer name, registered trade name or registered trademark + contact
• Waste stream information for each individual packaging component
• Recycled content information
• Reusability information (availability of location, national, or EU-wide reuse system), information on collection points, and simplification of packaging tracking and rotation calculations
• Packaging labeling that is part of an EPR system
• Identification of substances of concern

Sustainability Reporting and Claims

Corporate Sustainability Reporting Directive (CSRD)

The Directive on corporate sustainability reporting (Directive 2022/2464) was published in the Official Journal in December 2022 and came into force on January 5, 2023. It was introduced to replace the Non-Financial Reporting Directive (NFRD) and improve transparency and consistency in corporate sustainability reporting across the EU. Companies must report on their environmental, social, and governance (ESG) impacts and disclose double materiality assessments about how their activities impact the environment and society, and how sustainability risks affect their financial health.

The CSRD applies to:

• Wave One (2024 reports, published in 2025): large companies already subject to the Non-Financial Reporting Directive
• Wave Two (Originally 2025 reports, now delayed to 2027, published in 2028): large EU-based companies that meet two of the following criteria: 1) €50M+ annual turnover, 2) €25M+ total assets, 3) 250+ employees
• Wave Three (Originally 2026 reports, now delayed to 2027, published in 2028): non-EU companies with annual revenue €150M+ in the EU and listed SMEs

The companies will be required to report sustainability information according to mandatory European Sustainability Reporting Standards (ESRS) which would be established by the European Commission through delegated acts. Large companies with 500+ employees were originally required to report for the first time in 2025 for financial year 2024, but this scope could be refined by the Omnibus proposal, detailed more below.

Corporate Sustainability Due Diligence Directive (CSDDD)

The Directive on corporate sustainability due diligence (Directive 2024/1760) entered into force on July 25, 2024 and aims to support sustainable and responsible corporate behavior in companies’ operations and across their global value chains. It creates a harmonized legal framework for companies to identify and address potential and actual adverse human rights and environmental impacts in their operations and value chain. It sets out an obligation for large companies to adopt and put into effect a transition plan for climate change mitigation aligned with the 2050 climate neutrality objective of the Paris Agreement and intermediate targets under the European Climate Law.

The CSDDD applies to:

• Wave One (originally July 2027, now July 2028) – large EU companies: 5,000+ employees and €1.5B+ turnover; non-EU companies with €1.5B+ net turnover in the EU
• Wave Two (originally July 2028, now July 2029) – EU companies with 3000+ employee and €900M+ turnover; non-EU companies with €900M+ net turnover in the EU
• Wave Three (originally July 2029, now July 2030) – all other companies falling under the general scope of CSDDD (EU companies with 1000+ employees and €450M+ turnover)

Micro companies and Small and Medium-sized Enterprises (SMEs) are not covered by the proposed rules in CSDDD.

Omnibus Package

The Omnibus package published on February 26, 2025 is a set of simplification measures to reduce regulatory burdens and streamline sustainability reporting. Key changes include scope reduction of companies covered by CSRD, postponed reporting deadlines for CSRD and CSDDD, and simplified reporting requirements.

Around 80% of companies previously covered by CSRD could be exempt from reporting obligations, now only companies that have more than 1,000 employees and either a turnover above €50M or a balance sheet above €25M are obligated to report.

The “stop the clock” proposal adopted in April 2025 grants a 2-year delay for companies in the second and third waves of CSRD. It also grants a 1-year delay for companies in the scope of CSDDD.

The Omnibus package is still being discussed and negotiated with subsequent delegated acts adopting some of the proposed language expected by December 2025.

European Union Deforestation Regulation (EUDR)

This EU Deforestation Regulation (2023/1115) is a policy framework that entered into force on June 29, 2023. It is aimed at preventing deforestation caused by products consumed in the EU. The due diligence reporting requirements apply to cattle, cocoa, coffee, palm oil, rubber, soy, and wood. Companies who place these commodities on the EU market, or exports from it, must be able to prove that the products do not originate from recently deforested land or have contributed to forest degradation.

The implementation timeline of EUDR:

• December 30, 2025: Compliance required for large and medium-sized companies
• June 30, 2026: Compliance required for micro and small enterprises

Key information requirements of EUDR include precise geolocation coordinates of the land where commodities were produced, date or time range of production, supply chain transparency, deforestation-free verification, and due diligence statement.

In the context of packaging and packing materials, packing material placed or made available on the market or exported as products in their own right and containers which give a product its essential character are subject to EUDR. Packing material presented with goods inside and used exclusively to support, protect or carry another product are not subject to EUDR. Also, products made entirely from recycled materials are exempt from the EUDR. However, if they contain any portion of non-recycled or non-recovered material, that portion falls under the regulation—for example, virgin pulp used in paper production or timber used for pallet repairs.

Green Claims Directive

The Green Claims Directive is a proposed new EU law, introduced in March 2023, to address greenwashing and misleading claims about environmental advantages of companies products or services. It is aimed to ensure credible and trustworthy labels/claims to allow consumers to make better-informed purchasing decisions.

The proposal includes clear criteria on how companies should prove their environmental claims and labels, requirements for these claims and labels to be checked by an independent and accredited verifier, and new governance rules of environmental labeling.

Summary

Overall, the packaging regulatory landscape is quickly evolving across the EU and the world. This is not an exhaustive list of the relevant packaging regulations in the European Union, and we will continue to update this page with the latest guidance/information.

ThermoSafe is staying close to this space, supporting our customers, and providing a vast portfolio of temperature-controlled packaging to meet the needs, priorities and changing landscape.

[1] Please note that ThermoSafe’s interpretation is not meant to constitute legal advice, and ThermoSafe assumes no responsibility for the decisions made by producers in determining their obligations. We suggest that companies work with their legal teams to review the relevant statutes, rules and regulations to determine their responsibilities.

Need to get up to speed with USA’s EPR regulations as well? Review the comprehensive EPR blog post that is being updated regularly.