In short
- The next fixed date is 12 February 2028, when the Commission must adopt the empty space calculation methodology and fillers must minimise empty space.
- 12 August 2026 has already passed. PPWR was not delayed, and the obligations that started are narrower than the coverage suggests.
- Most 2030 dates carry a whichever is the latest clause, so they can move later, never earlier.
The next fixed date in PPWR is 12 February 2028, by which the Commission must adopt the implementing act establishing how empty space is calculated, and by which economic operators filling sales packaging must reduce empty space to the minimum necessary under Article 24(4). The date most people are still treating as upcoming, 12 August 2026, has already passed. Regulation (EU) 2025/40 has applied since then and it was not delayed. What has to be true today is narrow: substance limits, and a claim about packaging you can substantiate.
Which dates are spent, and which are ahead?
| Date | Status | What it does | What has to be true |
|---|---|---|---|
| 11 February 2025 | Spent | Entry into force, twenty days after publication in the Official Journal on 22 January 2025 | The text is fixed. The micro-enterprise definition is frozen at this date |
| 12 August 2026 | Spent | The Regulation applies. Article 71: it shall apply from 12 August 2026 | You are inside the regime, by role rather than by size |
| 12 August 2026 | Spent | Article 5(5) PFAS limits in food-contact packaging: 25 ppb single, 250 ppb sum, 50 ppm including polymeric | Non-conforming food-contact packaging cannot be placed on the market |
| 12 August 2026 | Spent | Article 5(4) sum of lead, cadmium, mercury and hexavalent chromium not above 100 mg/kg. Article 5(1) substances of concern minimised | You can evidence composition per packaging component |
| 12 August 2026 | Spent | Article 14 restriction on environmental claims about packaging properties PPWR regulates | Every live claim exceeds the minimum requirement and is demonstrated in the Annex VII technical documentation |
| 12 February 2028 | Ahead | Article 24(2) implementing act on the empty space methodology is due. Article 24(4) duty on fillers to minimise empty space | Your filling operation can show empty space is the minimum necessary |
| 12 August 2028 | Ahead | Article 12 harmonised labelling on material composition, Article 13 labels on waste receptacles | Artwork and tooling changed, on whichever of the two clocks runs longer |
| 1 January 2029 | Ahead | Article 49 mandatory 90 percent separate collection objectives, Article 50 deposit and return system minimum requirements | Mostly a Member State and scheme duty, felt through your EPR fees |
| 1 January 2030 | Ahead | Article 6 recyclability grades A, B or C. Article 7 minimum recycled content in plastic packaging. Article 10 minimisation. Article 24(1) maximum 50 percent empty space ratio. Article 25 ban on Annex V formats. Article 29 reuse targets | Portfolio redesigned, recycled content traceable by polymer |
What has already happened that people still describe as upcoming?
The application date itself. PPWR was not postponed, and a postponement is not expected to arrive retrospectively. Where a 2026 guide describes the regulation as "coming", it was written before 12 August 2026 or copied from something that was.
The second thing already in the past is the argument about whether it would be reopened. Treat any page that hangs an obligation on a simplification proposal as unusable: a proposal is not law, and we do not restate one.
The third is more subtle. Because application started in 2026, a great deal of writing front-loads obligations onto that date which do not begin until 2028 or 2030. Recyclability grading, recycled content, minimisation, banned formats and reuse targets are 2030. Harmonised pictograms are 2028. If a compliance calendar puts any of those in 2026, it is describing a regulation that does not exist.
Why is the 40 percent empty space date wrong twice?
Because both halves of the sentence are wrong, and they reinforce each other.
The number is 50 percent, not 40. Article 24(1) sets the maximum empty space ratio for grouped, transport and e-commerce packaging at 50 percent.
The date is 1 January 2030, not 12 August 2026, and even that is the earlier of two possibilities. Article 24(1) applies from 1 January 2030 or three years after the entry into force of the implementing act adopted under Article 24(2), whichever is the latest. That implementing act is not itself due until 12 February 2028, so a late act pushes the obligation past 2030.
What is genuinely nearer is the other half of Article 24. From 12 February 2028, economic operators filling sales packaging must reduce empty space to the minimum necessary. That is a duty on the filler, expressed as a standard rather than as a ratio, and it arrives two years before the ratio does.
What does "whichever is the latest" actually do to a deadline?
It converts a date into a floor.
Most of the 2030 cluster, and both labelling dates, are written as a fixed date or a number of years from the entry into force of a delegated or implementing act, whichever is the latest. The delegated and implementing acts are separate instruments the Commission still has to adopt. Until they exist, the fixed date is the earliest the obligation can bite, not a settled one.
The planning consequence is asymmetric and worth stating plainly. These dates can slip later. They cannot arrive earlier. So the correct posture is to build against the fixed date and treat any delay as recovered time, rather than the reverse.
Which date should be in your own calendar?
Not one of the regulation's, in most cases.
The claims review. Article 14 is live. Every environmental claim about a packaging property PPWR regulates is already in scope, and unlike a 2030 requirement it applies to statements you made years ago that are still in market. That review has no statutory date because it is already overdue. Our claims checklist covers what substantiation has to look like.
Your next specification change. Recycled content and recyclability are 2030 obligations that are decided at design time, and packaging designs have long lives. The date that binds is the next time the format is opened, not the compliance date.
Your supplier declaration cycle. Article 5 evidence comes from the people who sell you material. Whatever cadence you renew those declarations on is the practical deadline for knowing what is in your packaging.
Where does carbon accounting sit on this timeline?
Nowhere, and it is worth saying so.
PPWR creates no greenhouse gas obligation on any of these dates. No footprint, no inventory, no product carbon footprint. The reason the two calendars get merged is that the same person handles both, and the material composition data behind PPWR is the data an EPD needs, which makes the work reusable without making it the same work.
If you keep an organisational inventory alongside this, the Hedgehog platform is where that side lives, with 5,000+ users reported on its platform page. The limitation worth weighing against a deadline calendar: a mid-market reviewer on G2 in June 2026 said they would like more integrations with other software in the future, so if a date in your plan depends on an automated feed out of a purchasing system, test that before you schedule around it. And if the organisational footprint itself is the gap, that is carbon footprint consulting work rather than a packaging compliance question.
Sources: Regulation (EU) 2025/40 (OJ L, 2025/40, 22 January 2025), European Commission news item of 11 August 2026, Hedgehog platform, Hedgehog on G2. Verified 28 August 2026.
Facts on this page were last verified on 2026-09-17.
