EU Regulation 2025/40 — the Packaging and Packaging Waste Regulation, known as PPWR — is the most significant overhaul of EU packaging law in three decades. It replaces Directive 94/62/EC, which had governed packaging and packaging waste across the EU since 1994, and introduces a binding regulatory framework that will reshape how all packaging materials — including glass — are specified, labelled, recovered, and reported across the EU single market.
For glass packaging specifically, PPWR brings both good news and new obligations. The good news: glass is inherently recyclable, has established collection and recycling infrastructure across the EU, and is well-positioned under the regulation's recyclability framework compared to many plastic alternatives. The new obligations: EPR registration requirements that affect importers of glass-packaged goods, reuse targets that create strategic decisions for brands investing in new EU market packaging, and labelling requirements that will standardise how recyclability is communicated on packaging placed in EU commerce.
This guide is written for non-EU brands, importers, and packaging teams managing glass bottle specifications for EU market sales. It explains what PPWR requires, what the timeline looks like, where glass packaging is favourably positioned, and what compliance steps are needed now versus what remains subject to delegated acts still being finalised. For the earlier sustainability context — EU recyclability regulation before PPWR — see our guide on recyclable glass beverage bottles and EU sustainability regulations; this article focuses specifically on PPWR as the current binding regulatory instrument.
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Quick Answers
What is EU PPWR (Regulation 2025/40) and does it apply to glass packaging?
PPWR (Regulation (EU) 2025/40 on packaging and packaging waste) is the EU regulation that replaces the 1994 Packaging Directive. It applies to all packaging placed on the EU market — including glass bottles — regardless of where the packaging was manufactured. The regulation covers recyclability requirements, recycled content targets, reuse targets, EPR obligations, and labelling. Glass packaging is covered by PPWR, though several of its most demanding provisions — particularly mandatory recycled content requirements — target plastics rather than glass.
Does PPWR require glass bottles to contain a minimum percentage of recycled content?
PPWR's mandatory recycled content targets focus primarily on plastic packaging. PET beverage bottles face binding recycled content thresholds — 30% by 2030, 65% by 2040. Glass packaging is not subject to equivalent mandatory recycled content requirements under PPWR. However, the regulation does encourage recycled cullet use in glass production through the broader framework of EPR fee structures and recyclability assessment, and the European Commission may introduce glass-specific recycled content measures through future delegated acts.
What are PPWR's recyclability grading requirements and where does glass sit?
PPWR establishes a harmonised recyclability grading system (Grades A through D) for all packaging. Packaging must achieve a minimum grade by set deadlines — Grade C or above by 2030 for most categories, Grade B or above by 2035. Glass bottles, as an established recyclable format with high-quality recyclate recovery, are expected to achieve Grade A or B under the methodology being developed through delegated acts. This is a significantly stronger position than many plastics and composite materials.
Who is responsible for PPWR compliance for imported packaged goods?
PPWR defines the "producer" responsible for compliance as the EU-established entity that first places packaged goods on the EU market. For goods imported from outside the EU, this is typically the EU importer of record or authorised representative. Non-EU brands do not directly bear PPWR registration obligations — their EU importer does. However, non-EU brands are responsible for ensuring that their packaging specifications meet PPWR's design requirements (recyclability, minimisation) before goods are shipped, as these cannot be corrected at the EU border.
Does PPWR apply to spirits glass bottles, or only to beverage and food packaging?
PPWR applies to all packaging placed on the EU market, including spirits glass bottles. There is no categorical exemption for alcohol packaging. The regulation's requirements — recyclability, EPR, labelling, minimisation — apply to spirits bottles just as they do to mineral water bottles or food containers. The practical implications differ by product category, particularly around reuse targets, which are most directly relevant to high-volume beverage categories, but the regulatory coverage is universal.
1. What PPWR Is and Why It Matters for Glass Packaging Now
The EU's previous packaging regulation — Directive 94/62/EC — established recycling rate targets and basic EPR principles but left significant implementation flexibility to member states. The result was a patchwork of national EPR schemes, inconsistent recyclability definitions, and packaging design standards that varied across the EU single market.
PPWR replaces this directive with a directly applicable regulation — meaning it requires no transposition into national law and creates identical obligations across all 27 EU member states. This is a fundamental shift. A brand placing glass-packaged spirits or beverages on the French market faces the same PPWR requirements as one placing the same product on the Polish or Spanish market.
For glass packaging, the timing of PPWR matters because several of its design requirements apply to packaging placed on the market now — not only to new product launches from 2030 onwards. Packaging minimisation requirements, recyclability design obligations, and EPR registration requirements for importers are in effect or phasing in during 2025–2027. Brands that delay PPWR assessment until the 2030 deadline dates risk finding that their existing bottle specifications or importer relationships do not meet current-phase requirements.
2. PPWR's Key Provisions: What Applies to Glass and What Does Not
PPWR is a comprehensive regulation covering multiple dimensions of packaging design, recovery, and reporting. Not all provisions create equal compliance burden for glass packaging. Understanding which requirements are relevant — and which target other materials — allows packaging teams to focus effort efficiently.
Provisions That Apply Directly and Significantly to Glass
Recyclability requirements: All packaging placed on the EU market must be recyclable. Glass must achieve a defined recyclability grade by the applicable deadline.
Packaging minimisation: Packaging must be reduced to the minimum necessary. Empty space ratios and unnecessary packaging layers are regulated. For glass bottles, this primarily means bottle weight and design must not exceed what is functionally required — though glass bottles generally have established weight standards that align with this principle.
Extended Producer Responsibility: Importers of packaged goods must register with EPR schemes in each EU member state where they place goods on the market and pay fees that fund packaging collection and recycling infrastructure.
Labelling: Packaging must carry standardised recyclability labels and, where required, QR codes providing access to digital packaging information.
Reuse targets: Certain beverage categories face targets for the percentage of volume offered in reusable packaging formats by 2030 and 2035.
Provisions That Primarily Target Plastics, Not Glass
Mandatory recycled content thresholds: The binding percentage requirements (30% for PET beverage bottles by 2030; 65% by 2040) apply to plastic packaging. Glass does not face equivalent mandatory thresholds under the current regulation text.
Single-use plastic packaging restrictions: Several PPWR provisions restrict or phase out specific single-use plastic packaging formats. Glass is not affected.
Contact-sensitive packaging recycled content: Certain recycled content rules for food-contact plastics do not apply to glass, which is addressed under the food contact materials framework (Regulation 1935/2004) rather than PPWR's recycled content provisions.
3. Recyclability Requirements and the Grading System
PPWR's recyclability framework establishes a harmonised methodology for assessing and grading packaging recyclability across the EU. The grading system replaces the fragmented national recyclability standards that previously varied by member state.
The Recyclability Grades
Under PPWR, packaging is assessed and assigned a recyclability grade on a scale from A to D:
Grade
Description
PPWR Status
A
Recyclable at scale — high collection rates, high recyclate quality, well-established infrastructure across the EU
Preferred; qualifies for lowest EPR fee rates
B
Recyclable — good recyclate quality but collection rates or infrastructure not yet at scale in all member states
Acceptable; intermediate EPR fee structure
C
Recyclable in some markets — infrastructure or collection systems exist but are not universal across the EU
Minimum acceptable grade by 2030 for most packaging
D
Not yet recyclable at meaningful scale — to be redesigned or phased out
Non-compliant from 2030; cannot be placed on EU market
Glass's expected position: Standard soda-lime glass bottles — the format used for the vast majority of spirits and beverage packaging — are expected to achieve Grade A under the PPWR methodology being developed through delegated acts. Glass has established collection infrastructure across the EU, generates high-quality recyclate used back in glass production, and has no inherent design features that reduce recyclability. This Grade A positioning translates into the most favourable EPR fee rates under the regulation's modulated fee structure.
A practical note on decorated glass bottles: certain decoration techniques — in particular full-sleeve labels with non-removable adhesives, or mixed-material decoration systems — may complicate the recyclability assessment for a specific bottle design. Pure glass bottles with pressure-sensitive paper labels, ceramic screen printing (ACL), or no decoration achieve clean Grade A recyclability. Brands using complex label or decoration systems should confirm recyclability grade assessment for their specific bottle design with their EU importer or a packaging compliance assessor.
4. Reuse Targets: The Most Operationally Significant Requirement for Glass
Among PPWR's provisions, reuse targets create the most significant strategic decisions for brands investing in new glass bottle packaging for EU market entry. The regulation introduces mandatory targets for the share of beverages in certain categories that must be offered in reusable packaging formats.
How Reuse Targets Work
PPWR's reuse targets are set at the level of the "producer" (importer/brand owner) and the retailer, not the packaging specification itself. A brand is not required to change its current single-use bottle to a returnable format immediately. Instead, the target requires that a defined percentage of the brand's EU beverage sales volume be offered in reusable packaging by the applicable deadline.
Key reuse target parameters under PPWR (subject to finalisation through delegated acts):
By 2030: 10% of beverages in covered categories must be offered in reusable or refillable packaging
By 2040: Higher percentage targets applying to a broader range of categories
Covered categories include soft drinks, water, beer, and certain other beverage types — the precise scope is defined in the regulation's annexes
What This Means for Glass Bottle Strategy
For brands using single-use glass bottles for EU beverage sales, the reuse targets affect their EU distributor or retailer partners' compliance obligations, which in turn affect how distributors structure their product listings and logistics. Reusable glass bottle formats — such as standardised returnable glass formats used in Germany's Mehrweg system — are specifically favoured as compliant solutions under PPWR's reuse framework.
Brands entering the EU beverage market with new glass packaging should discuss reuse strategy with their EU importer at the planning stage, particularly for high-volume mineral water and soft drink categories where reuse targets are most directly applicable. For spirits glass, the reuse target impact is currently less direct — though the regulation's scope may extend further over time through delegated acts.
5. Extended Producer Responsibility Under PPWR
PPWR harmonises and strengthens EPR requirements across all EU member states, building on existing national EPR schemes and introducing more consistent obligations for producers (including importers) of packaged goods.
Who Bears the EPR Obligation
The "producer" under PPWR is the EU-established entity responsible for first placing packaged goods on the EU market. For imported goods, this is the EU importer of record or, where an authorised representative has been designated, that representative. Non-EU brands do not directly register for PPWR EPR — but they are indirectly affected through their importer relationship and through the packaging design requirements that determine the EPR fee level their importer pays.
Modulated EPR Fees: Why Glass Recyclability Affects Your Importer's Costs
PPWR requires that EPR fees be modulated based on the recyclability grade of the packaging. Grade A packaging — where glass bottles are expected to land — attracts the lowest EPR fee rates. Grade D packaging attracts the highest fees as a financial incentive to redesign or phase it out. This modulated fee structure creates a direct commercial benefit to importers for sourcing packaging with high recyclability grades, which in turn creates a preference signal from European importers toward glass and away from hard-to-recycle plastics and composite materials.
CSRD Overlap
For brands subject to the EU Corporate Sustainability Reporting Directive (CSRD), PPWR compliance data — packaging volumes by material, recyclability grades, EPR registration status — is also relevant to the packaging and product stewardship disclosures required in CSRD sustainability reports. For guidance on collecting and structuring the ESG data that supports both PPWR reporting and CSRD disclosure, see our guide on glass packaging carbon footprint and ESG reporting.
6. Labelling and Information Requirements
PPWR introduces standardised labelling requirements for packaging placed on the EU market, designed to provide consumers with consistent recyclability information across all member states.
Recyclability Label
Packaging must carry a label indicating its recyclability status based on the harmonised grading system. The specific label format — symbol design, placement, and size requirements — is being defined through delegated acts under PPWR. Glass bottles with established recycling symbols (the widely used recycling loop symbol with or without material type indicator) are already communicating recyclability; the PPWR standardised label will progressively replace or supplement these.
QR Code / Digital Product Passport
PPWR requires that packaging carry a QR code or equivalent digital identifier providing access to a standardised set of packaging information: material composition, recyclability instructions, recycled content data, and other prescribed fields. This is the PPWR equivalent of a Digital Product Passport for packaging. For glass bottles, the QR code requirement intersects with the EU spirits nutritional declaration QR code already required under Commission Delegated Regulation (EU) 2021/1756 — brands should plan label panel space for both functions, either as a combined QR code or as two separate codes, depending on the technical capabilities of their labelling system.
Material Type Identification
PPWR requires that packaging materials be identified using standardised codes. Glass packaging should carry the appropriate material identification mark — for glass, the established international code is GL with the relevant sub-code (GL 70 for clear glass, GL 71 for green glass, GL 72 for brown glass). These codes must appear on the packaging and align with the recyclability labelling.
7. PPWR Timeline: What Is Required and When
PPWR's requirements phase in over a decade, with different obligations entering into force at different stages. The following is a framework timeline; specific dates for some provisions depend on the finalisation of delegated acts, which were in development as of mid-2025.
Timeline
Key Requirement
Relevance to Glass
2025 (now)
PPWR in force; transition period for national EPR scheme alignment; packaging design requirements begin applying
Standardised recyclability labelling requirements begin phasing in; Digital Product Passport / QR code requirements for certain categories
Label panel planning for PPWR QR code; material identification codes on bottles
2030
All packaging must achieve minimum Grade C recyclability; 30% recycled content in PET beverage bottles; 10% beverage volume reuse target; harmonised EPR modulation fully operational
Glass confirms Grade A/B recyclability assessment; reuse target strategy confirmed with EU importer; Grade C minimum is a non-issue for standard glass
2035
All packaging must achieve minimum Grade B recyclability; higher recycled content thresholds for PET; expanded reuse targets
Grade B minimum still comfortably met by glass; expanded reuse targets may affect more beverage categories
2040
65% recycled content in PET beverage bottles; maximum reuse targets; full digital product passport for all packaging
Glass competitiveness vs PET further improved by PET's escalating recycled content costs; full Digital Product Passport required
PPWR does not apply to the UK. As covered in our guide on UK glass packaging regulations after Brexit, the UK operates its own separate Extended Producer Responsibility scheme which has different requirements and a different fee structure. Brands selling glass into both EU and UK markets need to manage both frameworks independently.
8. Practical Compliance Checklist for Glass Packaging Importers
Use this checklist to assess your current PPWR compliance position for EU-market glass bottle orders.
Packaging Design
☐ Confirm that your glass bottle specification does not include decoration systems (full-sleeve non-removable labels, mixed-material composite elements) that may compromise recyclability grade assessment
☐ Confirm bottle weight and void space comply with PPWR minimisation requirements — standard production glass bottles generally meet this, but custom shapes with unusually thick bases or large empty headspace should be reviewed
☐ Confirm material identification code (GL 70/71/72 as applicable) is present on the bottle or label
Recyclability
☐ Request from your glass supplier confirmation of the expected recyclability grade for your bottle design under the PPWR methodology — Grade A for standard glass is the expected outcome
☐ Confirm recyclability label format and placement on the bottle or label panel, aligning with the harmonised PPWR label as delegated act requirements are finalised
☐ Plan label panel space for PPWR QR code requirements (minimum 1.5 cm × 1.5 cm, high contrast, not obscured by curvature) — this may overlap with the EU spirits nutritional declaration QR code requirement
EPR and Importer Obligations
☐ Confirm your EU importer holds or is obtaining EPR registration in each EU member state where your products are placed on the market
☐ Confirm your importer agreement specifies who bears responsibility for EPR compliance and fee payment
☐ Provide your EU importer with accurate packaging weight data by material type (glass weight per bottle, label material weight, closure material weight) for their annual EPR reporting
☐ Confirm importer's understanding of the modulated EPR fee benefit associated with Grade A recyclable glass — this affects their total compliance cost
Reuse Strategy
☐ Confirm with your EU importer whether your product category falls within PPWR's reuse target scope for 2030
☐ If relevant, discuss whether a reusable glass format is part of your EU market roadmap, or whether reuse target obligations will be met through other means in the importer's portfolio
Forward Planning
☐ Review the PPWR timeline for requirements entering into force in 2027–2028 (labelling, Digital Product Passport) and factor label panel and bottle specification reviews into your production planning cycle
☐ If subject to CSRD, confirm that PPWR compliance data (packaging volumes, recyclability grades, EPR registration) is being captured in your sustainability data collection process
FAQ
Does my glass bottle need to carry PPWR recyclability labelling?
PPWR introduces standardised recyclability labelling requirements for packaging placed on the EU market. The regulation mandates packaging carry a label indicating its recyclability status under the harmonised grading system, alongside a QR code or equivalent digital identifier providing access to standardised packaging information. The specific format and mandatory timing for these labels are being defined through delegated acts — as of mid-2025, these were still being finalised. Glass bottles already carry established recycling symbols; the PPWR harmonised label will progressively standardise these. Confirm current mandatory label requirements with your EU importer or a packaging compliance consultant as delegated act timelines are confirmed. Plan label panel space now so that PPWR labelling can be accommodated without a full label redesign when requirements become binding.
How do PPWR's reuse targets affect my glass bottle strategy for the EU market?
PPWR's reuse targets require that a defined percentage of beverages in covered categories be offered in reusable packaging by 2030. For brands using single-use glass bottles, these targets primarily affect their EU importer or retailer partner's portfolio-level obligations rather than requiring an immediate specification change for any single product. However, for brands planning new glass packaging investments for EU beverage categories at meaningful volume, discussing reuse format options with the EU importer at the planning stage is worthwhile — a reusable glass bottle format satisfies reuse targets directly and is positively positioned under PPWR's broader framework. For spirits glass in particular, the reuse target application is currently less direct than for high-volume water and soft drink categories, but the regulatory scope may expand through future delegated acts.
As a non-EU brand, how do I ensure my EU importer is correctly handling PPWR EPR obligations?
Under PPWR, the EU-established importer of record bears the primary EPR registration, reporting, and fee-payment obligations for goods imported from outside the EU. To ensure correct compliance, confirm in your importer agreement that the importer accepts EPR responsibility and holds or is actively obtaining EPR registration in all relevant EU member states. Request evidence of registration and confirm that your packaging weight data — glass weight per unit, closure and label material weights — is being accurately provided to the importer for their annual reporting. For importers who are smaller operations or new to PPWR obligations, proactively sharing accurate packaging weight data and requesting confirmation of their EPR status protects you from downstream compliance risk. If the importer cannot demonstrate EPR registration in a market where you are placing significant volume, this is a material gap that needs to be resolved before your next production shipment.
How does PPWR change the cost comparison between glass and PET for EU market packaging decisions?
PPWR has shifted the long-term cost equation in glass's favour for EU market packaging in several compounding ways. PET beverage bottles face mandatory recycled content requirements — 30% by 2030, rising to 65% by 2040 — that significantly increase PET material costs relative to virgin PET, with recycled-content PET commanding a price premium that is expected to grow as demand increases. Glass faces no equivalent mandatory recycled content thresholds under PPWR. EPR fee modulation rewards Grade A recyclable packaging with lower fee rates — glass consistently achieves this grade, while some plastic formats require reformulation to maintain high recyclability grades under the PPWR methodology. Brands currently weighing glass versus PET for EU market entry should model the full PPWR-adjusted cost of PET over a 5–10 year horizon, not the current unit price, when making packaging format decisions. The glass versus PET total cost comparison is shifting materially in glass's direction as PPWR requirements phase in.
Selling Glass-Packaged Products Into Both EU and US Markets? Your Compliance Obligations Differ
PPWR applies to all packaging placed on the EU market. The United States has no equivalent federal regulation — US packaging sustainability is governed by a patchwork of state-level EPR schemes, none of which replicates PPWR's scope or structure. Brands running glass packaging programmes for both EU and US markets are managing two genuinely different regulatory environments, and the bottle specification and compliance documentation that satisfies one market does not necessarily map directly to the other.
Where HUIHE can help with dual-market planning:
Confirming which of your glass bottle specifications achieve Grade A recyclability under PPWR without design changes
Advising on label panel requirements that accommodate both PPWR QR code obligations (EU) and TTB labelling requirements (US) on a single label where possible
Providing the ESG and recyclability data your EU importer needs for PPWR EPR reporting and your sustainability team needs for CSRD disclosure
Identifying where separate EU and US bottle specifications are genuinely needed versus where a single specification can serve both markets
Send us your current bottle specification and target markets. We will map which PPWR requirements apply, which your existing specification already satisfies, and where action is needed.
