PPWR Glossary
PPWR stands for the Packaging and Packaging Waste Regulation, a new EU regulation (2025/40) that came into force on 11 February 2025, replacing the older Packaging Directive. It sets binding, directly applicable rules across all 27 EU member states on how packaging must be designed, documented, labelled, and managed. The regulation generally applies from 12 August 2026.
PPWR affects any company that places packaged products on the EU market, not just packaging manufacturers, but also the businesses that fill and sell the final product.
Below you'll find an alphabetical overview of the key terms you'll come across when working on PPWR compliance.
Annex VII The section of PPWR specifying what a Technical Dossier must contain, including descriptions, drawings, standards applied, and test reports.
Annex VIII The section of PPWR providing the model structure for the EU Declaration of Conformity (DoC).
Articles 5–12 The core packaging requirements at the heart of PPWR, the rules your packaging is actually assessed against. They cover substances in packaging (Art. 5), recyclability (Art. 6), recycled content (Art. 7), biobased content (Art. 8), compostability (Art. 9), packaging minimisation (Art. 10), reusability (Art. 11), and labelling (Art. 12). Before packaging can be placed on the EU market, the manufacturer must demonstrate conformity with these articles, which is what the conformity assessment, technical dossier, and EU Declaration of Conformity exist to prove. Note that some requirements phase in later, for example recyclability and recycled content from 2030.
CoA (Certificate of Analysis) A lab report proving that PFAS and/or heavy metals levels in packaging materials fall within the PPWR limits. Required as part of the Technical Dossier. Note: check with your Simvia contact for the exact terminology used in the platform.
Conformity Assessment The process a manufacturer must complete before placing packaging on the EU market, to verify it meets PPWR's essential requirements.
Contact Sensitive Packaging components that directly touch the product, such as food, cosmetics, medical devices, or pharmaceuticals. Food-contact packaging specifically is subject to PPWR's PFAS limits.
DoC (EU Declaration of Conformity) A formal statement confirming that packaging meets PPWR requirements. Must follow the Annex VIII model and be retained for 5 years (single-use packaging) or 10 years (reusable packaging); the same retention period applies to the technical dossier.
End User The party that empties and discards the packaging, either a consumer (B2C) or a professional (e.g. hospitality, catering). Intermediaries and traders are not considered end users under PPWR.
EPR (Extended Producer Responsibility) A system where companies placing packaging on the EU market pay fees to fund collection, sorting, and recycling of packaging waste. Fees are paid per country of sale.
GS1 The global standards organisation for product identification. Packaging compliance data should be stored in GS1-based format, which also serves as the foundation for EPR reporting.
Grouped Packaging Secondary packaging that groups multiple sales units together for retail display or convenience (e.g. a multipack or shrink wrap around several products). Subject to PPWR requirements where applicable.
Heavy Metals Lead, cadmium, mercury, and chromium VI, toxic substances with a combined cap of 100 mg/kg under PPWR (Art. 5(4)). This limit isn't new, it carries over from the 1994 Packaging Directive and has applied for decades.
Manufacturer Under PPWR (Art. 3(13)), the party that manufactures packaging or a packaged product, or has it made under its own brand, often the brand owner that fills the packaging, not necessarily the packaging maker. Responsible for the conformity assessment and technical dossier.
Material Layer A single layer within a composite packaging component (e.g. a barrier layer or seal layer in a multilayer film). PFAS limits apply to the packaging material as a whole, not per individual layer.
Packaging Component An individual part of a packaging unit (e.g. tray, lid, label, film). Each component has its own material composition and must be tracked separately.
Packaging Unit The complete packaging as a whole, the level at which PPWR compliance is assessed.
PFAS (Per- and Polyfluoroalkyl Substances) "Forever chemicals" sometimes used in food-contact packaging for grease or water resistance. Under Art. 5(5), PPWR sets three limits on food-contact packaging: 25 ppb for any single PFAS substance, 250 ppb for the sum of all PFAS, and 50 ppm including polymeric PFAS, all measured in the packaging material.
Placing on the Market Under Art. 3(10), the first making available of packaging (empty or with a product) on the Union market, meaning the first supply for distribution, consumption, or use in a commercial activity. This is the trigger for PPWR compliance obligations.
ppb (Parts Per Billion) The unit used to measure PFAS concentration limits under PPWR for food-contact packaging. The thresholds are 25 ppb per single substance and 250 ppb for the sum of all PFAS.
PPWR (Packaging and Packaging Waste Regulation) EU Regulation 2025/40, which came into force in 2025. It replaces the older Packaging Directive with directly applicable rules across all EU member states on packaging design, recyclability, labeling, and waste management.
PRO (Producer Responsibility Organisation) An organisation that collects EPR fees and manages packaging waste on behalf of producers. Examples include Verpact (Netherlands) and Der Grüne Punkt (Germany).
QR Code Labeling PPWR's harmonised labelling requirements (Art. 12) will use standardised, EU-wide labels, including QR codes, to show recyclability and material composition. These obligations apply from 12 August 2028 (or 24 months after the relevant implementing acts, whichever is later); reusability labels apply from 12 February 2029.
Recyclability The ability of packaging to be collected, sorted, and recycled at scale. PPWR requires packaging to meet minimum recyclability thresholds, assessed through a grading system still being defined at EU level, applying from 2030.
Sales Packaging Primary packaging that reaches the end user (consumer or professional). Subject to the full PPWR requirements.
Technical Dossier Documentation proving that packaging meets the essential requirements of Articles 5–12. Includes descriptions, drawings, specifications, standards used, and test reports. Must be in place before placing packaging on the market.
Transport Packaging Also known as tertiary packaging, this is used for logistics and shipping and is removed before the consumer stage. Subject to different requirements than sales packaging.
Verpact The Dutch PRO scheme for EPR registration and fee collection.
Void Space Percentage The proportion of empty space in packaging relative to the product. PPWR sets limits (e.g. less than 30%) to reduce unnecessary waste.
Looking for more context? Read our Introduction to PPWR article or visit the Simvia PPWR FAQ.