PPWR readiness: Assess now before 2030

Phase 3 of PPWR lands in 2030 and is where the regulation stops being about paperwork and starts reshaping packaging itself: void space limits, reuse and refill targets, outright bans on specific single-use plastic formats, and binding recycled content minimums. This is the phase with the most direct impact on packaging design, sourcing, and logistics, and because reformulation, supplier changes, and stock depletion take years, the transition work needs to start well before the 2030 deadline, not in 2029. Below is the full Phase 3 section from Simvia's 5-step PPWR readiness checklist: packaging performance and recycled content.

3.1 Minimisation and void space

From 2030, packaging exceeding a 50% empty-space ratio will be non-compliant. This pushes companies to reassess oversized packaging, unnecessary layers and inefficient transport formats. The EU has not yet released the final methodology for how empty space will be calculated and justified, this will be released in February 2028, but companies can already identify high-risk formats.

Ask yourself:

Have you assessed packaging for weight and empty space efficiency? Yes / No

3.2 Reuse and refill targets

PPWR introduces binding reuse targets from 2030, but they apply differently depending on packaging category. The categories in scope include transport packaging, grouped packaging, beverage packaging, and e-commerce packaging. Not all companies will be affected equally, the targets and timelines differ per category and some formats are exempt.

Ask yourself:

Do you use any of the following packaging categories that fall under PPWR reuse targets?

Transport packaging / Grouped packaging / Beverage packaging / E-commerce packaging / None of the above

Have you identified whether any of your current packaging formats would qualify as reusable under PPWR's definition? Yes / No

For those that apply, have you assessed what reuse or refill targets will mean for your packaging design and logistics? Yes / No

3.3 Restricted formats and bans

From January 2030, the following single-use plastic packaging formats will be prohibited: grouped convenience wraps (e.g. shrink-wrapped multipacks), pre-packed fresh fruit and vegetables under 1.5kg, on-site food and drink packaging in hospitality (plates, cups, trays), single-portion condiment or sauce packs (sachets, tubs), single-use hotel toiletries (mini bottles, sachets), and lightweight plastic carrier bags. Transition planning should start now, packaging redesign, supplier alignment, and stock depletion can take years.

Ask yourself:

If any of your current packaging formats appear on the restricted list, have you identified compliant alternative formats? Yes / No / Partially / Not applicable

Do you have a transition timeline in place for phasing out restricted formats before January 2030? Yes / No

3.4 Recyclability data and grades

From January 2030, minimum recycled content targets apply to plastic packaging by category: contact-sensitive PET at 30%, other contact-sensitive plastic at 10%. These targets increase again in 2040. They are calculated as an average per manufacturing plant per calendar year, not per individual packaging unit.

Ask yourself:

If you use plastic packaging in any of the categories above, do you currently know the recycled content percentage of each plastic packaging unit? Yes / No / Partially / Not applicable

Have you identified which plastic packaging units are likely to fall below the 2030 minimum targets? Yes / No / Partially

3.5 Recycled content tracking

Producers must substantiate recycled content claims through verified chain-of-custody evidence, a supplier saying "this contains 30% recycled content" is not sufficient. The Commission will adopt a standard verification methodology by December 2026, becoming mandatory from January 2029. Companies should begin aligning their evidence collection with that standard now.

Ask yourself:

Do you track recycled content percentage per plastic packaging unit? Yes / No / Partially

Is that data backed by chain-of-custody certificates or equivalent third-party verification from your suppliers? Yes / No / Partially

Phase 3 is where PPWR moves from documentation to physical change, redesigning packaging, renegotiating with suppliers, and in some cases exiting formats entirely. Several of the underlying methodologies (void space calculation, chain-of-custody verification) aren't finalised yet, but the deadlines they feed into are fixed, so the risk of waiting is running out of runway for redesign and supplier alignment, not being caught off guard by the rule itself. Recycled content and recyclability grades both depend on data tracked at the individual packaging unit or plant level, reinforcing that the data foundation built in Phase 1 carries through every later phase.

Download the full PDF checklist to work through Phases 1, 2, 4 and 5, and calculate your overall PPWR readiness score.