Written on: September 1, 2026 by Cassandra Taylor
The European Union (EU) continues to advance its circular economy objectives with the Packaging & Packaging Waste Regulation (PPWR), one of the most significant packaging reforms in decades. The regulation entered into force on Feb. 11, 2025, replacing the previous Packaging & Packaging Waste Directive (94/62/EC), with most requirements becoming applicable as of Aug. 12, 2026.
The packaging industry is one of the largest users of raw materials in the EU, accounting for approximately 40% of plastic use and 50% of paper consumption, according to the European Chemicals Agency (ECHA). In response, the PPWR aims to reduce packaging waste, improve recyclability, encourage reusable and refillable packaging systems and support the broader transition to a circular economy. A key focus is reducing unnecessary packaging and limiting single-use and overpackaged products.
For manufacturers, importers and brand owners, PPWR introduces several new obligations. Packaging placed on the EU market will need to meet enhanced recyclability requirements and include standardized labeling to facilitate proper sorting and disposal. The PPWR also establishes mandatory minimum recycled plastic content targets for certain categories of plastic packaging, with phased implementation beginning in 2030 and increasing in 2040. In addition, the PPWR includes measures to minimize unnecessary packaging and limit the use of substances of concern.
Recognizing the complexity of the new requirements, the European Commission recently published an official Guidance and a comprehensive frequently asked questions (FAQ) document in response to numerous implementation questions raised by Member States and industry stakeholders. These documents are intended to promote the consistent application of the PPWR throughout Member States by clarifying the interpretation of several provisions within the regulation.
Main Provisions of the PPWR
The PPWR introduces several ambitious targets intended to reduce packaging waste and increase the sustainability of packaging placed on the European market. Member States are expected to reduce packaging waste by 5% by 2030, 10% by 2035 and 15% by 2040, compared with 2018 levels. In addition, all packaging placed on the EU market is expected to be recyclable in an economically viable manner by 2030.
To support these objectives, the regulation establishes reuse targets for selected transport, e-commerce and beverage packaging while prohibiting certain single-use packaging formats beginning Jan.1, 2030. Mandatory deposit-return systems will also be introduced for beverage cans and plastic bottles, accompanied by harmonized packaging labels to help consumers correctly sort packaging waste within the European Union.
PPWR applies broadly to virtually all packaging placed on the EU market, regardless of material type. Its requirements extend throughout the supply chain and cover consumer, commercial, industrial, transport, grouped, e-commerce and reusable packaging.
One of the key design principles introduced by the PPWR is packaging minimization. Packaging must be limited to the minimum weight, volume and empty space necessary to ensure product protection, safety, hygiene, transportation and functionality. Oversized packaging, excessive void space, decorative layers and unnecessary secondary packaging intended primarily for marketing purposes are specifically discouraged.
PPWR promotes the transition from single-use to reusable packaging systems by introducing reuse targets and refill requirements for selected packaging sectors. The regulation establishes provisions for reusable transport and beverage packaging, while also supporting refill systems, including the use of consumer-provided containers in certain takeaway settings. In parallel, it restricts several single-use packaging applications, including selected hotel toiletries, condiment sachets, produce packaging and other convenience packaging formats. These measures are intended to reduce packaging waste and encourage the adoption of more resource-efficient packaging solutions throughout the supply chain.
The regulation also introduces restrictions on substances of concern. Per- and polyfluoroalkyl substances (PFAS) are prohibited in food-contact packaging above specified thresholds. It establishes limits of 25 ppb for any individual PFAS (measured by targeted PFAS analysis, excluding polymeric PFAS), 250 ppb for the sum of targeted PFAS and 50 ppm for total PFAS (including polymeric PFAS) where the total fluorine content exceeds 50 mg/kg. Although these provisions are primarily directed at food-contact packaging, they align with the EU’s objective of reducing the use of persistent chemicals in packaging materials.
The PPWR also introduces provisions relating to compostable packaging and establishes clear distinctions between biodegradable, compostable, industrially compostable and home compostable materials. Under the regulation, certain packaging applications may be required to be industrially compostable, subject to final implementing measures and the availability of appropriate collection and treatment infrastructure within Member States. Unlike home composting, which depends on variable environmental conditions, industrial composting occurs under controlled high-temperature and high-humidity conditions designed to facilitate the breakdown of compostable materials. Examples identified by the European Commission include tea bags, coffee pods, produce stickers and certain lightweight food-contact packaging.
Another significant change is the introduction of harmonized packaging labeling requirements across the EU. As implementing acts continue to be adopted, companies can expect additional artwork and labeling obligations, including standardized sorting symbols and other information intended to improve consumer understanding and support recycling initiatives.
Implications for the aerosol industry
Although the PPWR is not specific to aerosol dispensers, many of its requirements apply to the packaging materials and components used throughout the aerosol industry. Manufacturers should assess secondary packaging, plastic components such as caps and actuators, packaging artwork and labeling, and supplier documentation to determine whether changes are needed to meet the regulation’s requirements. While metal aerosol cans already benefit from well-established recycling systems, companies may still need to demonstrate compliance with recyclability, recycled content, labeling and documentation requirements. Working closely with packaging suppliers will help ensure the necessary technical documentation and material information are available to support compliance.
Looking ahead
The EU continues to lead the development of packaging sustainability regulations, and the PPWR is likely to influence future legislation in other markets. Similar initiatives are already emerging around the world, including extended producer responsibility (EPR) programs, recycled content mandates, packaging reduction targets and harmonized recycling labels. While the specific requirements vary by jurisdiction, the overall direction is clear: Packaging is increasingly being regulated not only for its role in protecting products and facilitating distribution, but also for its environmental impact throughout its entire life cycle.
For aerosol manufacturers and brand owners selling internationally, staying informed of these developments will be essential. Companies that proactively review their packaging portfolios and supply chains will be better positioned to adapt as packaging sustainability requirements continue to evolve both within Europe and globally. SPRAY
