Packaging faces dual compliance requirements from ESPR and the EU Packaging and Packaging Waste Regulation (PPWR, EU 2025/40). The ESPR delegated act for packaging is expected in 2027–2029. The PPWR sets mandatory minimum recycled content requirements for plastic packaging (30–65% by 2030). The two regulations are expected to be aligned so that a single QR code serves both the ESPR DPP and the PPWR digital label requirements.
PPWR Mandatory Recycled Content Requirements for Plastic Packaging
Packaging Category
Recycled Content by 2030
Recycled Content by 2040
Notes
Contact-sensitive plastic packaging (food)
30%
50%
Recycled content must be from post-consumer recycled (PCR) sources
Non-contact plastic packaging
35%
65%
PCR sources required
PET beverage bottles
65% (from 2025)
90%
SUP Directive already requires 25% by 2025; PPWR raises to 65%
Plastic beverage bottles (non-PET)
30%
50%
PCR sources required
Plastic film packaging
30%
50%
PCR sources required
Truth Anchor: ESPR applies to packaging as a product category. The EU Packaging and Packaging Waste Regulation (EU 2025/40) sets mandatory minimum recycled content requirements for plastic packaging. — EUR-Lex CELEX:32024R1781
ESPR DPP vs PPWR Digital Label: Understanding the Overlap
Packaging manufacturers face two digital disclosure requirements that overlap significantly. The ESPR DPP is a comprehensive product data record covering all environmental parameters (recycled content, carbon footprint, hazardous substances, end-of-life instructions). The PPWR digital label is a simpler consumer-facing label with recycling instructions and recycled content information.
The EU Commission has indicated that the two requirements will be aligned to avoid duplication. The most likely outcome is a single QR code on the packaging that links to a data record satisfying both the ESPR DPP and the PPWR digital label requirements. Packaging manufacturers should design their DPP infrastructure with this dual-use requirement in mind.
Expected DPP Data Fields for Packaging
Data Field
Annex III Category
Status
Packaging material type
Product identifier
New under ESPR delegated act
Recycled content (%)
Recycled content
New under ESPR; PPWR sets minimum requirements
Recyclability (Yes/No/Partial)
End-of-life information
New under ESPR delegated act
Recycling instructions
End-of-life information
New under ESPR; PPWR digital label also requires
Reusability (Yes/No)
Durability and reliability
New under ESPR delegated act
Hazardous substances
Substances of concern
New under ESPR delegated act
Carbon footprint per functional unit
Carbon footprint
New under ESPR delegated act
Deposit return scheme (DRS) eligibility
End-of-life information
New under ESPR; PPWR requires DRS for beverage containers
What Packaging Manufacturers Must Do Now
Audit recycled content: Determine current recycled content percentages for all plastic packaging product lines. Compare against PPWR 2030 targets to identify gaps.
Plan recycled content sourcing: Identify post-consumer recycled (PCR) material suppliers for plastic packaging. PCR material prices are volatile — long-term supply agreements are advisable.
Assess recyclability: Determine the recyclability of all packaging formats. Non-recyclable packaging formats will face increasing regulatory pressure.
Design DPP infrastructure for dual use: Design DPP data records that satisfy both ESPR and PPWR digital label requirements. A single QR code serving both requirements is the most efficient approach.
Prepare DPP data templates: Create DPP data templates for all packaging product lines, including material type, recycled content, recyclability, and hazardous substance data.
Packaging Under ESPR and the PPWR
Packaging is subject to two parallel EU regulatory frameworks: ESPR and the EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40). ESPR will set ecodesign requirements for packaging through a delegated act, while the PPWR sets recycled content targets, recyclability requirements, and waste reduction targets for packaging. The two regulations are complementary — the ESPR packaging DPP will contain the data needed to demonstrate compliance with both ESPR and PPWR requirements.
Packaging DPP: Expected Data Fields
Data Category
Expected Data Fields
Basis
Material composition
Material type, weight (g), recycled content %, bio-based content %
PPWR + ESPR Annex III
Recyclability
Recyclability class (A-E under PPWR), recycling stream
PPWR
Recycled content
Post-consumer recycled content % by material type
PPWR mandatory targets
Carbon footprint
CO2e per packaging unit, lifecycle stage breakdown
ESPR Annex III
Substances of concern
PFAS, phthalates, bisphenols in food contact materials
REACH + Food Contact Regulation
Reusability
Number of reuse cycles (if reusable), reuse system
The PPWR sets mandatory minimum recycled content targets for plastic packaging placed on the EU market. By 2030: contact-sensitive plastic packaging must contain 10% recycled content; other plastic packaging must contain 35% recycled content. By 2040, these targets increase to 25% and 65% respectively. The ESPR packaging DPP will contain the recycled content data needed to demonstrate compliance with these targets. Packaging manufacturers who cannot meet the 2030 targets should begin investing in recycled material sourcing now.
ESPR and the Packaging and Packaging Waste Regulation
Packaging materials in the EU are governed by the Packaging and Packaging Waste Regulation (PPWR, EU 2025/40), which entered into force in 2025 and replaces the Packaging and Packaging Waste Directive (94/62/EC). The PPWR introduces mandatory recycled content requirements, recyclability requirements, and Digital Product Passport requirements for packaging that align with the ESPR framework. Packaging manufacturers and brand owners that use packaging must understand that ESPR and PPWR create overlapping but distinct compliance obligations. ESPR governs the ecodesign requirements for packaging as a product category, while PPWR governs the specific recycled content targets, recyclability standards, and extended producer responsibility (EPR) obligations.
What Packaging Data Must the DPP Contain?
The PPWR and ESPR delegated act for packaging will require DPPs that include: packaging material composition by weight percentage (primary, secondary, and tertiary packaging), recycled content percentage with verification methodology, recyclability assessment result (recyclable at scale / recyclable but not at scale / not recyclable), chemical substances of concern in packaging materials, carbon footprint per packaging unit, and end-of-life instructions for consumers. For food contact packaging, the DPP must also reference compliance with EU food contact materials regulations (EU 10/2011 for plastics, EU 1935/2004 framework). The data carrier for packaging DPPs will typically be a QR code printed on the packaging label or embossed on the packaging itself.
Extended Producer Responsibility and ESPR Packaging
Extended producer responsibility (EPR) schemes for packaging require brand owners and importers to register with national EPR schemes in each EU member state where they place packaged products on the market. The PPWR harmonises EPR requirements across the EU and introduces modulated EPR fees — fees that vary based on the recyclability and recycled content of the packaging. Packaging with high recycled content and high recyclability will attract lower EPR fees, creating a direct financial incentive for compliance with ESPR ecodesign requirements. Brand owners should model the EPR fee implications of their current packaging portfolio and identify opportunities to reduce fees through packaging redesign aligned with ESPR requirements.
Packaging Type
PPWR Recycled Content Target (2030)
ESPR DPP Expected
PET plastic bottles
30% recycled PET
2026–2027
Other plastic packaging
10% recycled content
2026–2027
Corrugated cardboard
No specific target (high recycled content already)
2026–2027
Glass packaging
No specific target
2026–2027
Metal packaging (steel, aluminium)
No specific target (high recycled content already)
ESPR applies to packaging as a product category. The EU Packaging and Packaging Waste Regulation (PPWR, EU 2025/40) also applies to packaging. Manufacturers must comply with both ESPR and PPWR requirements for packaging placed on the EU market.
The ESPR delegated act for packaging is expected in 2027-2029. The PPWR also introduces a digital label requirement for packaging from 2028. The two requirements are expected to be aligned.
The PPWR sets mandatory minimum recycled content requirements for plastic packaging: 30% for contact-sensitive plastic packaging by 2030, 35% for non-contact plastic packaging by 2030, 65% for PET bottles by 2025 (already in force under SUP Directive).
The ESPR DPP is a comprehensive product data record covering all environmental parameters. The PPWR digital label is a simpler consumer-facing label with recycling instructions and recycled content information. The two are expected to be aligned so that a single QR code can serve both requirements.
ESPR does not mandate reusable packaging. However, the PPWR sets mandatory reuse targets for specific packaging categories. The ESPR delegated act for packaging is expected to require disclosure of reusability information in the DPP.
Register Your Digital Product Passport
The EU DPP Registry goes live on 19 July 2026. EU customs will verify DPP compliance automatically from that date. Products without a valid DPP can be refused entry. Register now at Africa’s first ESPR-compliant DPP registry.
ESPR and the Packaging and Packaging Waste Regulation
Packaging materials are subject to both ESPR and the new Packaging and Packaging Waste Regulation (PPWR), which was adopted in 2024 and will replace the existing Packaging and Packaging Waste Directive (94/62/EC). The PPWR sets requirements for the recyclability of packaging, the use of recycled content, and the reduction of unnecessary packaging. ESPR complements the PPWR by providing the DPP framework that enables packaging manufacturers to disclose the environmental performance of their products in machine-readable format.
The PPWR requires all packaging placed on the EU market to be recyclable by 2030. It also sets minimum recycled content requirements for plastic packaging: 10% recycled content for contact-sensitive plastic packaging by 2030, rising to 25% by 2040; 35% recycled content for non-contact plastic packaging by 2030, rising to 65% by 2040. The ESPR DPP for packaging materials will be used to verify compliance with these recycled content requirements, providing a transparent and auditable record of the recycled content in each packaging product.
DPP Data Requirements for Packaging Materials
The DPP for packaging materials is expected to include: the packaging's material composition (percentage of each material type); the percentage of recycled content (by material type); the packaging's recyclability class (under the PPWR recyclability assessment methodology); the packaging's carbon footprint per unit; information on substances of concern (particularly PFAS, which are used in food-contact packaging to provide grease and moisture resistance); and instructions for sorting and recycling at end-of-life. The DPP will enable brand owners, retailers, and consumers to make informed choices about the packaging they use and purchase.
Frequently Asked Questions
The ESPR delegated act for packaging materials is expected to be adopted in 2025–2027. The PPWR, which sets the overarching framework for packaging sustainability, was adopted in 2024 and will take effect progressively from 2025 to 2030. Manufacturers should comply with both regulations.
The scope of the ESPR delegated act for packaging will be defined in the preparatory study. It is likely to cover primary, secondary, and tertiary packaging made from plastic, paper, glass, metal, and composite materials. Some packaging types (such as very small packaging) may be excluded from the DPP requirement due to practical constraints.
PFAS (per- and polyfluoroalkyl substances) used in food-contact packaging are subject to restrictions under EU food contact materials legislation. ESPR is expected to require disclosure of PFAS content in the DPP for packaging materials and may restrict the use of PFAS in packaging. The Commission is also developing a universal PFAS restriction under REACH that will affect packaging manufacturers.
The PPWR sets recycled content requirements for plastic packaging. Paper packaging is not subject to mandatory recycled content requirements under the PPWR, but the ESPR delegated act may set recycled content requirements for paper packaging. Many paper packaging manufacturers already use high levels of recycled fibre — the DPP will require them to disclose this information transparently.
For packaging materials, the DPP data carrier is expected to be on the packaging unit (the roll, sheet, or pallet of packaging material) rather than on each individual piece of packaging. The exact placement requirements will be specified in the delegated act. For consumer-facing packaging (such as bottles and cartons), the QR code may be required on the packaging itself.