Implementation
PPWR secondary legislation tracker
Last regulatory verification: 12 August 2026 · 4 official sources
A maintained tracker of the delegated and implementing acts under Regulation (EU) 2025/40: what each covers, its date, status and who it affects.
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Regulation (EU) 2025/40 sets obligations and dates; a series of delegated and implementing acts sets the methods behind them. Until an act is adopted, the obligation and its date stand but the measurement rule does not exist yet. This tracker records where each act stands and which of our guides has to be re-checked when it moves.
The tracker
Status reflects the public record at the verification date shown at the foot of this page, checked against the Commission implementation hub, the comitology register and the waste expert group. Where you need certainty for a decision, confirm against the primary sources listed below rather than relying on this summary.
Design-for-recycling criteria and recyclability performance grades
Pending secondary act- Instrument
- Delegated act
- Legal basis
- Article 6, Regulation (EU) 2025/40
- Statutory deadline
- 1 January 2028
The criteria that decide whether packaging is grade A, B or C, by packaging category. Until adopted, recyclability cannot be assessed definitively against the 2030 threshold.
Affects: All packaging categories · Design decisions with long tooling lead times
Recycled at scale methodology
Pending secondary act- Instrument
- Delegated act
- Legal basis
- Article 6, Regulation (EU) 2025/40
- Statutory deadline
- 1 January 2030
Sets how the EU-wide recycling volumes behind the 2035 'recycled at scale' test are measured and published.
Affects: Packaging formats near the scale threshold
Recycled content calculation, verification and documentation
Pending secondary act- Instrument
- Implementing act
- Legal basis
- Article 7, Regulation (EU) 2025/40
- Statutory deadline
- 31 December 2026
Defines how the recycled share is calculated and verified per unit, and what documentation must follow the material through the chain. This is the act that determines what suppliers must give you.
Affects: Plastic packaging · Contact-sensitive plastic packaging
Harmonised labelling: symbols, formats and data carriers
Pending secondary act- Instrument
- Implementing act
- Legal basis
- Article 12, Regulation (EU) 2025/40
- Statutory deadline
- 12 August 2026
Fixes the harmonised material and sorting symbols and the specification of the data carrier. Artwork should not be finalised for the harmonised regime until this is published.
Affects: All labelled packaging · Artwork and print cycles
Compostable packaging specification
Pending secondary act- Instrument
- Delegated act
- Legal basis
- Article 9, Regulation (EU) 2025/40
- Statutory deadline
- 12 February 2028
Technical specification for the formats that must be compostable, including the conditions the packaging must be compostable in.
Affects: Tea and coffee single-serve units · Fruit and vegetable labels · Carrier bags
Minimisation and empty space methodology
Pending secondary act- Instrument
- Implementing act
- Legal basis
- Articles 10 and 24, Regulation (EU) 2025/40
- Statutory deadline
- 1 January 2030
Methodology for assessing minimisation and for calculating the empty space ratio consistently across Member States.
Affects: E-commerce packaging · Grouped and transport packaging
Substances of concern reporting and further restrictions
Pending secondary act- Instrument
- Delegated act
- Legal basis
- Article 5, Regulation (EU) 2025/40
- Statutory deadline
- Rolling
ECHA's supporting work feeds the Commission's assessment of further substance restrictions in packaging beyond those already set.
Affects: All packaging · Food-contact packaging in particular
EN 18120 and the design-for-recycling standards family
Draft / proposed- Instrument
- Harmonised standard
- Legal basis
- Standardisation request supporting Article 6
- Statutory deadline
- Ongoing
European standardisation work on recyclable plastic packaging. A standard only creates a presumption of conformity once cited in the Official Journal.
Affects: Plastic packaging design
How to read 'pending'
Why this tracker exists
Most PPWR commentary either ignores secondary legislation or quotes draft numbers as though they were adopted. Both mislead. Keeping the acts visible, with their statutory deadlines and their dependent guidance, is what lets a compliance plan distinguish between "we do not know yet" and "we have not looked".
How it is maintained
The comitology register, the implementation hub and the waste expert group pages are checked weekly; EUR-Lex is the controlling source for anything adopted. When an act moves, this page and every dependent guide listed against it are updated together, and both the verification date and the modification date on those pages change. See our methodology.
Official sources for this page
Every statement above is written against these sources. Where a Commission document and the Regulation differ, the Regulation controls.
- Regulation (EU) 2025/40 — EUR-LexBinding law
- PPWR Implementation HubCommission guidance
- Commission Expert Group on Waste E03343Official implementation / research
- European Commission Comitology RegisterOfficial implementation / research
- Sources last verified
- 12 August 2026
- Content last updated
- 12 August 2026
- First published
- 12 August 2026
Written and maintained by the PPWRDeclaration.com editorial team. General information about Regulation (EU) 2025/40 — not legal advice.
Why this matters
What happens if the documentation isn't there
The packaging can be restricted
Packaging without valid technical documentation is treated as non-compliant. Market surveillance authorities can require corrective action, restrict sale, or withdraw it from the market.
Penalties apply per Member State
Each Member State sets its own penalties for non-compliance, and they apply where the packaging is placed on the market — not where your business sits.
Buyers block you first
Retailers, distributors and importers increasingly ask for the Declaration and supporting evidence before onboarding. No file usually means no listing.
Late evidence costs more
Supplier declarations and lab testing have long lead times. Discovering a gap close to a deadline forces rushed testing or packaging redesign.