PPWR 2026 and French EPR: Practical Impact Guide for Foreign Sellers

PPWR and French EPR: two layers of obligation

The EU Packaging and Packaging Waste Regulation (PPWR, Regulation EU 2025/40) enters general application on August 12, 2026. Unlike the previous Packaging Directive which required national transposition, the PPWR is a regulation that applies directly in all EU Member States.

For foreign sellers in France, this means two overlapping compliance layers. French national EPR (existing): registration with Citeo, IDU from ADEME, annual declarations, eco-contribution payments. This continues unchanged. EU PPWR (new from August 2026): packaging design requirements, recyclability grades, documentation obligations, labelling harmonisation. These are additional requirements on top of French EPR.

The PPWR does not replace French EPR. It adds to it.

What the PPWR requires from August 2026

PFAS restrictions: per- and polyfluoroalkyl substances are banned in food-contact packaging above defined thresholds. Substance restrictions: lead, cadmium, mercury, and hexavalent chromium remain limited to 100 mg per kilogram total. Documentation obligations: producers and importers must ensure technical documentation is available for each packaging type placed on the EU market.

The producer under PPWR is defined as the manufacturer of the packaging, the importer if the manufacturer is outside the EU, or the brand owner if they modify the packaging. Foreign sellers importing packaged products into France are typically classified as importers under PPWR.

The recyclability grade system coming in 2030

From January 1, 2030 (or 24 months after delegated act publication), all packaging must achieve a minimum recyclability grade of C on a scale from A (best) to E (worst). Grades D and E will be banned from the EU market. From 2038, only grades A and B will be permitted.

The European Commission will publish the detailed methodology before January 2028. The core criteria are already known: design for recycling compatibility with existing sorting infrastructure, availability of large-scale collection systems, and effective recycling achieving quality output.

Packaging types at highest risk of failing grade C include multi-material laminates such as plastic-aluminium sachets, dark or coloured rigid plastics not detectable by optical sorting, and packaging with non-removable labels or incompatible adhesives. If your product uses any of these packaging types, redesign should begin now.

Recycled content requirements from 2030

Plastic packaging will require minimum recycled content percentages from 2030, with progressive increases through 2040. Contact-sensitive packaging like food containers will have lower initial requirements than non-contact packaging. Producers must provide documentation proving the percentage and origin of recycled content.

Void ratio limits for e-commerce packaging

The PPWR limits the void ratio (empty space) in grouping and e-commerce packaging to a maximum of 50 percent from 2030. Filler materials count as void. This directly affects e-commerce sellers who use oversized boxes with excessive void fill. Packaging must be the minimum size necessary for product protection and information display.

How to prepare now

Step 1: audit your current packaging against PPWR requirements. Identify any packaging that uses PFAS, restricted substances, or non-recyclable designs. Step 2: begin redesigning problematic packaging. Allow 12 to 18 months for R and D, testing, industrial validation, and deployment. Step 3: structure your packaging data (materials, weights, compositions, recycled content percentages) for future documentation requirements. Step 4: ensure your French EPR compliance is current, as PPWR adds to but does not replace national EPR.

We provide integrated PPWR plus French EPR compliance services. Our recyclability pre-assessment identifies packaging at risk and recommends design changes. Contact us to prepare your packaging for 2026 and beyond.

The recyclability grade pre-assessment service

While PPWR recyclability grades are not mandatory until 2030, we offer a pre-assessment service that evaluates your current packaging against the expected grade criteria. This identifies packaging at risk of grade D or E classification (which will be banned) and recommends design changes. Combined with Citeo eco-modulation optimisation, this pre-assessment generates immediate savings through bonus exploitation while preparing you for future PPWR requirements.

The Digital Product Passport (DPP) connection

The ESPR regulation (Ecodesign for Sustainable Products) will require Digital Product Passports accessible via QR code for certain product categories starting in 2027 (batteries first). The data required for DPP overlaps significantly with EPR declaration data (materials, composition, recyclability, recycled content). Companies that structure their product data for EPR now are simultaneously preparing for DPP. Our mandataire service helps you build this data foundation. Contact us to future-proof your compliance.

The recyclability pre-assessment: act now, save later

While PPWR recyclability grades are not mandatory until 2030, we offer a pre-assessment service that evaluates your packaging against the expected criteria. This identifies packaging at risk of grade D or E classification (which will be banned in 2030) and recommends design changes with 12 to 18 months of lead time for R and D, testing, and deployment.

Combined with current Citeo eco-modulation criteria, this pre-assessment generates immediate savings. A packaging redesigned for PPWR recyclability will also earn Citeo's recyclability bonus (up to minus 8 percent) and potential recycled content premiums (40 to 55 euro cents per kilogram). The pre-assessment pays for itself through reduced eco-contributions before PPWR even takes effect.

The Digital Product Passport connection

The EU Ecodesign for Sustainable Products Regulation (ESPR) will require Digital Product Passports accessible via QR code. Batteries are first (2027), followed by textiles and electronics. The data required for DPP overlaps with EPR declaration data: materials, composition, recyclability, recycled content. Companies structuring their product data for French EPR now are simultaneously preparing their DPP infrastructure. Our mandataire service helps you build this data foundation.

Why foreign sellers should care about PPWR now

PPWR creates both risk and opportunity for foreign sellers. The risk: non-compliant packaging will be banned from the EU market. The opportunity: companies that redesign early gain competitive advantage through lower eco-contributions, PPWR compliance ahead of competitors, and stronger positioning with environmentally conscious European buyers.

Integrated PPWR plus French EPR service

We provide a single service covering both current French EPR compliance and PPWR preparation. Packaging audit, recyclability grade pre-assessment, eco-contribution optimisation, mandataire representation, and ongoing regulatory monitoring. One provider for your entire French environmental compliance. Contact us below.