from when must my packaging be recyclable by law

Recyclability applies from a later date than the PPWR itself

The PPWR requires that packaging is recyclable, but this requirement has its own entry into force date that is separate from the date on which the regulation itself begins to apply. In the text of Regulation (EU) 2025/40, the recyclability requirement is linked to a later moment, giving manufacturers and importers time to adapt their packaging design, material choices and production processes accordingly. Until that date, the regulation already applies to other aspects, such as requirements on substances in packaging and information that must appear on the packaging or in the statement of conformity.

For those already designing or purchasing packaging now, it is practical to look ahead to what the recyclability requirements will entail: not only the material itself, but also components such as labels, adhesives and closures count towards the assessment. This affects, among other things, the question what data you must request from your packaging supplier, because recyclability is something that is determined throughout the supply chain and not solely by your own packaging line. The requirements on minimum packaging volume and weight, such as when determining whether a box is too large or too heavy, are also linked to the same design process in which recyclability plays a role.

Where this follows from: Article 24 and Article 7 of the PPWR

Article 24 of Regulation (EU) 2025/40 governs the void ratio in packaging and Article 7 sets requirements for the share of recycled content in plastic packaging; both articles are part of the same broader package of design requirements that also includes the recyclability obligation. Because the PPWR is a regulation, these requirements apply as such equally in every Member State: there is no need for national transposition and no Member State can set its own, different date for when packaging must be recyclable. What does differ from country to country is not the requirement itself but its registration and enforcement: which register checks compliance, what thresholds apply and which authority exercises supervision differ between, for example, Germany, France and the Netherlands. In the Netherlands, there is also a threshold of 50,000 kg of packaging material per year, but this threshold is not a permanent exemption: it is expected to expire from August 2027 onwards, and until then the substantive design requirement from the regulation remains in full force, even for those below the threshold. For a broader overview of how the various dates in the regulation relate to each other, there is the page on what the PPWR is and since when it has applied.