PPWR applied on 12 August 2026 under Article 71, but only the substance limits and the administrative duties bite today. Recyclability, recycled content, empty space and reuse start in 2030, labelling in 2028 and deposit systems in 2029. Several of those dates move with implementing acts still to be adopted.
Article 71 provides that the Regulation applies from 12 August 2026, with Article 67(5) applying from 12 February 2029. Everything else sits on the phased schedule below.
What binds when
| From | Obligation | Fixed or conditional |
|---|---|---|
| 12 August 2026 | Article 5(5) PFAS limits in food-contact packaging; Article 5(4) heavy-metal cap of 100 mg/kg; Article 15 and Article 18 documentation, identification and importer duties | Fixed |
| 12 August 2028 | Article 12 harmonised material-composition labelling | Or 24 months from the paragraph 6 or 7 implementing acts, whichever is latest |
| 1 January 2029 | Deposit and return systems with 90 percent separate collection of single-use plastic beverage bottles and metal beverage containers | Fixed |
| 1 January 2030 | Article 6 recyclability in grades A, B or C; Article 7 recycled content; Article 24 empty space; Article 29 reuse targets | Article 6 runs 24 months from its delegated acts, Article 7 three years from its implementing act, whichever is latest |
| 1 January 2035 | Recycled-at-scale assessment added to recyclability | Or five years from the relevant implementing acts |
| 1 January 2038 | Only grades A or B may be placed on the market | Fixed |
Why the conditional dates matter commercially
Article 7(1) opens with the words “By 1 January 2030 or 3 years from the date of entry into force of the implementing act referred to in paragraph 8 of this Article, whichever is the latest”. Article 6 and Article 12 use the same construction against their own acts. As of this writing the Commission lists those acts as in preparation, so a plan built on 2030 as a hard deadline may be planning against a date that has not yet started running.
The duties that are unconditional are the ones already in force, and they are documentary rather than design-led. Directive 94/62/EC was repealed from 12 August 2026 by Article 70, with four provisions continuing on their own timetables.
Sources: Regulation (EU) 2025/40, PPWR Frequently Asked Questions, second edition
Sequencing work against the fixed dates first, then the conditional ones, is how EU PPWR solutions phases an engagement. The full schedule is set out in the PPWR compliance guide.