If you place packaged products on the EU market, 2030 is a critical compliance milestone under the EU’s Packaging and Packaging Waste Regulation (PPWR).
From 1 January 2030, certain packaging formats are restricted outright, and a number of design requirements become conditions for placing packaging on the market. In practice, this means packaging that does not meet these requirements may no longer be legally supplied in the EU.
This article outlines four of the most commercially important ways packaging may become non-compliant by 2030 and what producers should do now to reduce risk.
What “non-compliant” means under PPWR
In practice, packaging may not be placed on the EU market if it:
- falls within a restricted packaging format listed in Annex V, or
- does not meet applicable PPWR requirements, such as recyclability, minimisation, or recycled content obligations
PPWR applies from 12 August 2026, but many of the most significant packaging design restrictions and requirements take effect from 1 January 2030.
The 4 most common ways packaging becomes non-compliant in 2030
1. Your packaging format is restricted (Annex V)
From 1 January 2030, economic operators may not place on the market certain packaging formats listed in Annex V of PPWR.
These restrictions primarily target avoidable or unnecessary single-use plastic packaging, particularly in applications where alternatives are available.
In summary, Annex V includes restrictions on:
- Certain single-use plastic grouped packaging at the point of sale, where it is designed to encourage the purchase of multiple items and is not necessary for handling or logistics
- Pre-packed fresh fruit and vegetables under 1.5 kg, with limited exemptions where packaging is necessary to prevent spoilage, damage, contamination, or to separate products (e.g. organic vs non-organic)
- Single-use plastic packaging for food and beverages consumed on-site in Hotels, Restaurants, and Cafés/ Catering (HORECA) settings (e.g. disposable plates, cups, trays and containers), with limited exceptions
- Single-use plastic single-portion packaging in HORECA for condiments, sauces, creamers, sugar and seasonings (e.g. sachets and tubs), with certain exemptions
- Single-use plastic toiletry packaging in accommodation (e.g. small shampoo or lotion bottles intended for single use per booking)
- Very lightweight plastic carrier bags, except where required for hygiene or to prevent food waste
If your packaging falls within these categories and no exemption applies, it cannot be placed on the EU market from 2030.
2. Your packaging does not meet recyclability requirements
Recyclability becomes a key requirement for placing packaging on the EU market from 2030.
Under PPWR, packaging must be designed for recycling and assessed against harmonised recyclability criteria. Packaging performance will be classified using recyclability performance grades.
Packaging that does not meet the required recyclability performance threshold will be considered non-compliant and may not be placed on the market.
From 2038, requirements become more stringent, with only the highest-performing recyclability grades expected to remain compliant.
3. Your e-commerce, transport or grouped packaging exceeds the empty space limit
PPWR strengthens packaging minimisation requirements, particularly for e-commerce and logistics.
From 1 January 2030, grouped, transport and e-commerce packaging must not exceed an empty space ratio of 50%.
This means that no more than half of the packaging volume may consist of empty space, including space filled with materials such as void fill or padding.
This requirement is expected to significantly impact oversized packaging and inefficient packing practices.
4. Your plastic packaging does not meet recycled content requirements
From 2030, plastic packaging must contain minimum levels of post-consumer recycled (PCR) content.
The headline targets include:
- 30% for contact-sensitive PET packaging (excluding single-use beverage bottles)
- 10% for contact-sensitive plastic packaging other than PET (excluding single-use beverage bottles)
- 30% for single-use plastic beverage bottles
- 35% for other plastic packaging
These targets are calculated as an average across a manufacturing plant over a given period and will require robust data and supplier traceability.
Prepare for 2030
PPWR covers the full packaging lifecycle, from design through to waste management. While 2030 may seem some time away, packaging changes often require multiple development cycles, supplier engagement, and investment decisions.
A practical starting point is to carry out a structured review of your highest-volume packaging formats.
Producer checklist
- Is the packaging format restricted under Annex V?
- Can it meet recyclability requirements by 2030?
- Are there known recyclability barriers (e.g. multi-layer materials, full sleeves, coatings, adhesives or pigments)?
- For e-commerce and transport packaging: is empty space ≤ 50%?
- For plastic packaging: can you evidence recycled content and supplier traceability?
In summary
Producers should assess whether their packaging could become non-compliant – and therefore unable to be placed on the EU market – by 2030.
The most common risks arise where packaging:
- is restricted by format under Annex V
- does not meet recyclability requirements
- exceeds minimisation thresholds
- fails to meet recycled content obligations
While this article highlights four of the most commercially important risks, PPWR introduces a wider set of requirements that will continue to evolve through implementing legislation.
To stay ahead, producers should treat 2030 as a design and data challenge today, not a compliance issue to address later.
How Clarity can help
Clarity supports producers in turning PPWR from uncertainty into an actionable plan, from identifying high-risk packaging formats to building the data needed for confident decision-making.
Contact us today to see how we can support your PPWR compliance journey.
