# The EU produced 4.2% more packaging waste per person in 2024 than in 2018, so the PPWR’s “5% less by 2030” is a cut of almost 9% from where Europe stands, and of 20% or more in eight Member States

> Article 43 of Regulation (EU) 2025/40 requires each Member State to cut packaging waste generated per person by at least 5% by 2030, 10% by 2035 and 15% by 2040 against its 2018 figure; with the EU at 180.99 kg per person in 2024 against 173.64 kg in 2018, the 2030 level of about 164.96 kg is 8.9% below today, and by SPI's calculation Spain needs 21.2% and Poland 24.2%, which national governments will pass to brands through EPR fees, prevention plans and reuse rules.

Publisher: Strategic Packaging Insights  
Published: 2026-10-30  
Last updated: 2026-10-30  
Page: https://www.strategicpackaginginsights.com/insights/ppwr-waste-prevention-targets-per-capita-2030/

**Article 43 of Regulation (EU) 2025/40 requires each Member State to cut packaging waste generated per person by at least 5% by 2030, 10% by 2035 and 15% by 2040 against its 2018 figure; with the EU at 180.99 kg per person in 2024 against 173.64 kg in 2018, the 2030 level of about 164.96 kg is 8.9% below today, and by SPI's calculation Spain needs 21.2% and Poland 24.2%, which national governments will pass to brands through EPR fees, prevention plans and reuse rules.**

Strategic Packaging Insights (SPI) set the per capita series that Eurostat released on 22 October 2026 against the Article 43 baseline for every Member State, sorted the 27 into four groups by distance to target, and modelled 2030 outcomes for the EU, Spain and Poland. The result is a market by market reading of where brands should expect prevention pressure first, measured in kilograms per person only.

## Executive summary

The PPWR's prevention target is usually quoted as "5% by 2030". That figure is measured from 2018, and most of Europe has moved the wrong way since then. Eurostat's 2024 data, released on 22 October 2026, put EU packaging waste at 181.0 kg per person, up 3.2 kg on 2023. The EU figure for 2018 in the same series is 173.64 kg, so the EU stood 4.2% above its baseline in 2024, by SPI's calculation (Exhibit 1).

Article 43 places the target on each Member State, not on companies. Paragraph 1 sets reductions of at least 5% by 2030, 10% by 2035 and 15% by 2040 against the per capita figure each state reported for 2018. Paragraph 5 asks Member States to adopt prevention measures, naming economic instruments, incentives in extended producer responsibility (EPR) schemes and duties on producers to adopt waste prevention plans (Article 43, German text as reproduced by LX Gesetze).

The distance to target varies by a factor of ten. Four Member States, Germany, Sweden, Estonia and France, are already 5% or more below 2018. Eight, including Spain and Poland, are more than 20% above it and need cuts of 21.2% to 39.0% from their latest level to reach the 2030 line (Exhibit 5). Spain also carries its own national target under Royal Decree 1055/2022: 15% less packaging waste by weight in 2030 than in 2010, against tonnage that Eurostat shows 28.6% above 2010 in 2024 (Exhibit 8).

For brands, the target arrives indirectly but it arrives in the markets that are furthest away first. On flat volumes, an EU state at the average would need about 1.5% less packaging waste per person every year from 2024 to 2030; Spain would need 3.9% a year and Poland 4.5% a year, by SPI's calculation (Exhibit 7).

Brand owners should map their packaging tonnage per unit sold, market by market, against the four groups in Exhibit 6, and treat Spain, Poland and the other far-off markets as the places where fee modulation, prevention plans and national reuse quotas are most likely to tighten before 2030.

## Key findings

1. Article 43(1) requires each Member State to reduce packaging waste generated per capita by at least 5% by 2030, 10% by 2035 and 15% by 2040, compared with the figure it reported for 2018 under Decision 2005/270/EC (Article 43, German text as reproduced).
2. Eurostat reports 81.5 million tonnes of EU packaging waste in 2024, or 181.0 kg per inhabitant, against 173.64 kg in 2018 in the env_waspac series, a rise of 4.2% by SPI's calculation.
3. **SPI calculation:**  21 of 27 Member States were above their 2018 level in their latest reported year; only Germany, Sweden, Estonia and France were 5% or more below it.
4. **SPI calculation:**  Spain generated 194.43 kg per person in 2024, 20.6% above its 2018 figure of 161.27 kg, so its 2030 level of 153.21 kg is 21.2% below its 2024 level.
5. **SPI calculation:**  Poland's provisional 2024 figure of 180.43 kg is 25.3% above its 2018 figure of 143.98 kg; its 2030 level of 136.78 kg is 24.2% below the 2024 level.
6. Recital 120 estimates that the 5%, 10% and 15% per capita steps equal absolute reductions of about 19%, 29% and 37% against the baseline scenarios for 2030, 2035 and 2040.
7. **SPI calculation:**  at the EU's 2018 to 2024 trend of plus 0.69% a year, EU packaging waste would reach 188.65 kg per person in 2030, 23.69 kg above the 2030 level.

## What Article 43 says, paragraph by paragraph

SPI tracks the prevention targets as [PR-EU-011](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-011/) in the [regulation tracker](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-011/). SPI read Article 43 in the German text as reproduced by LX Gesetze, an unofficial reproduction, and translated it. Exhibit 2 sets out the nine paragraphs.

**The target is national and per person.**  Paragraph 1 contains no company duty and no material split. The Commission's guidance says so directly in its section on national exemptions from the reuse targets, where it ties those exemptions to the Article 43 result (Commission Notice C/2026/3084, section 24). A Member State can meet its target with any mix of materials, which is why the same 5% will mean heavier fee pressure on some formats in one country and on others elsewhere.

**The baseline is the reported 2018 figure.**  Article 43(1) refers to the figure each Member State reported for 2018. SPI uses the current Eurostat env_waspac series, which holds those reports as Eurostat now publishes them; if a state's 2018 figure has been revised since, the baseline the Commission uses may differ from the one in Exhibit 1. SPI has not yet confirmed whether any Member State asked for a different base year under Article 43(8) by the 31 December 2025 deadline.

**Plastic gets an effort duty, not a number.**  Paragraph 4 is worded as an endeavour, unlike the fixed percentages of paragraph 1. Plastic was 35.9 kg of the 181.0 kg per person in 2024, Eurostat says, and SPI's [Eurostat news piece](https://www.strategicpackaginginsights.com/news/eurostat-plastic-packaging-recycling-2024-42-4/) covers the plastic recycling side of that release; this piece does not repeat it.

**National measures carry the brand impact.**  Paragraph 5 lists economic instruments and other incentives that apply the waste hierarchy, EPR incentives, and obligations on producers or producer responsibility organisations to adopt waste prevention plans. Paragraph 7 limits them: proportionate, non-discriminatory, no trade barriers, and no push from heavier to lighter packaging materials. Recital 121 repeats that last warning and asks Member States to prioritise measures that minimise the risk (EUR-Lex, recitals).

## How Europe got further from 2018

The EU series has not moved in a straight line. Exhibit 3 shows it from 2014, so the 2018 baseline can be read against the years around it.

Three things stand out. First, 2018 was a slightly lower year than 2017, at 173.64 kg against 174.21 kg, so the baseline is not inflated. Second, the 2021 peak of 190.28 kg sat 9.6% above the baseline, by SPI's calculation, and the fall to 2023 took most of that back. Third, the 2024 rise of 3.2 kg per person, which Eurostat reported, ended the fall: 2024 is 4.2% above 2018 and 16.03 kg per person above the 164.96 kg line for 2030, so the cut needed from 2024 is 8.9% of the 2024 figure.

Eurostat's method note matters for brands reading these numbers. The figures cover packaging waste generated by the whole economy, households, businesses and government, and per capita figures divide national totals by the average resident population of the year (Eurostat news item, 22 October 2026). Commercial and industrial packaging is therefore inside the number. Recital 120 says per capita targets cannot apply as such to commercial and industrial packaging waste, because its generation is not related to household consumption, and Article 43(3) lets states with separate systems keep them (EUR-Lex, recital 120).

## Why 5% per person is bigger than it sounds

The legislature itself sized the targets in absolute terms. Recital 120 compares each step with a baseline scenario in which nothing changes, and Exhibit 4 sets the two measures side by side.

Recital 120 says that meeting the 5% target by 2030 should entail an overall absolute reduction of about 19% on average across the Union, compared with the 2030 baseline scenario. The gap between the two numbers is growth: the baseline scenario assumes packaging keeps rising with consumption and population, so holding per capita waste 5% below 2018 removes far more tonnage than 5%.

SPI analysis

For a brand, the absolute figure is the better guide. A business that grows unit sales in a market while its packaging grams per unit stay flat adds to the national tonnage that the per capita figure divides. The national measure will be designed to bend that curve, and a brand whose grams per unit fall slower than the market's will carry a growing share of whatever fee or plan the state uses.

## Every Member State's 2030, 2035 and 2040 level

Exhibit 5 converts Article 43 into kilograms per person for each Member State, using the 2018 figure in Eurostat's current series, and shows how far each must cut from its latest reported level.

**SPI calculation.**  Each level is the 2018 figure times 0.95, 0.90 or 0.85. The cut needed is one minus the 2030 level divided by the latest figure. For Spain: 161.27 x 0.95 = 153.21 kg; 1 minus 153.21 / 194.43 = 21.2%. For the EU: 173.64 x 0.95 = 164.96 kg; 1 minus 164.96 / 180.99 = 8.9%.

The ranking by kilograms and the ranking by effort are different lists. Germany generated 214.72 kg per person in 2024, the fourth highest figure in the table after Italy, Ireland and Luxembourg, and yet it was 0.6% inside its 2030 level. Croatia generated 82.10 kg, among the lowest, and needs a 19.6% cut. Article 43 rewards movement from a state's own 2018 figure, not a low level of waste, so a brand cannot read national pressure from the kilograms alone.

Two cautions apply. First, Article 43(2) asks the Commission to set a tourism correction factor by 12 February 2027, based on packaging waste per tourist and changes in tourist numbers since 2018 (Article 43, German text as reproduced). SPI has not yet confirmed which states the factor will change, or by how much, so the levels in Exhibit 5 are before any correction. Second, several series carry Eurostat flags, and three states have no value for 2024.

## A framework: four groups by distance to target

SPI's organising device for this piece sorts the 27 Member States by one number: the change in packaging waste per person from 2018 to the latest year. Exhibit 6 sets out the four groups that result and what each means for a brand selling there.

**Group A, already below.**  Germany, Sweden, Estonia and France reached their 2030 line on Eurostat's latest figures. Germany is only 0.6% inside it and needs a further 4.6% for 2035; France, at 7.3% inside, has room until 2035 and needs 4.0% for 2040. Brands should not read this as a free pass, because national laws in these markets already carry their own reduction aims, such as France's single-use plastic decree.

**Group B, within reach.**  Six states need cuts of 1.6% to 9.1%. Italy, with the highest per capita figure in the EU at 221.22 kg, sits here because its 2018 figure was also high.

**Group C, stretch.**  Nine states need 10.0% to 20.2%. Denmark is the outlier by level: 197.09 kg per person in 2024, the highest figure outside Italy, Ireland, Luxembourg and Germany, and 13.9% above its 2018 figure.

**Group D, far off.**  Eight states need more than a fifth. They include the two markets this piece looks at in detail below, Spain and Poland, and several others where the tourism correction factor may change the level.

SPI analysis

The groups give brands a sequence. Article 43(5) leaves the choice of instrument to each state, but a state in group D cannot reach its 2030 line with the EU-wide design rules alone, and its EPR scheme, its prevention plan rules and its reuse policy are where the gap will be closed. The [2025 packaging targets scorecard](https://www.strategicpackaginginsights.com/insights/2025-packaging-targets-scorecard/) shows how far brand pledges set on a 2018 base have travelled; Article 43 now sets a national 2018 base on top of them.

## Scenarios: three paths to 2030

The per capita figure for 2030 depends on what happens to packaging per person between now and then. Exhibit 7 tests three paths for the EU, Spain and Poland.

**SPI calculation, base case.**  Held flat at 180.99 kg, the EU figure would be 16.03 kg above the 164.96 kg line in 2030. To reach it from 2024, packaging waste per person must fall by 1.53% a year for six years. Spain would need 3.89% a year, from 194.43 kg to 153.21 kg, and Poland 4.51% a year, from 180.43 kg to 136.78 kg.

The low case is the useful one. The EU fell by 1.65% a year from 2021 to 2024, from 190.28 kg to 180.99 kg, a fall that took in the 2023 drop and the 2024 rebound. If that pace held to 2030, the EU total would just clear its line, at 163.75 kg. The same pace would leave Spain 22.70 kg and Poland 26.46 kg short, because they start from further above their baselines.

SPI analysis

For a brand, the gap between the base and low cases is what national measures have to deliver. A market that needs 3.9% to 4.5% less packaging per person every year, as Spain and Poland do in the base case, needs more than a light touch on fees.

## What the national cut means per pack

A national per capita figure becomes a brand question once it is turned into grams per unit. SPI priced one illustrative food brand that sells 100 million units a year in Spain, each with 40 grams of packaging across primary, grouped and transport layers, so it places 4,000 tonnes of packaging on the Spanish market a year.

**SPI calculation, illustrative brand.**  If the brand's unit sales stay flat and it matches the national cut of 21.2% from 2024 to 2030, its packaging per unit falls from 40.0 grams to 31.5 grams, and its tonnage from 4,000 tonnes to 3,152 tonnes, a reduction of 848 tonnes. Matching the 10% step for 2035 from the same start, a 25.3% cut, takes it to 29.9 grams per unit. If instead unit sales grow by 2% a year while grams per unit stay at 40.0, tonnage reaches 4,505 tonnes in 2030, 505 tonnes more than in 2024. These figures are SPI assumptions, kept in tonnes and grams, and are not a forecast for any company.

The example shows why prevention is a portfolio question rather than a pack question. A brand can meet the national pace through lighter primary packs, fewer grouped layers, reusable transport packaging, refill formats or a change in sales mix, and each of those moves sits under a different PPWR article. Recital 119 lists the same levers: removing excess packaging and certain formats, longer packaging life, redesigned products and sales models including bulk, and a shift from single-use to reusable packaging (EUR-Lex, recitals; [PR-EU-011](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-011/)).

SPI analysis

Three cautions apply to the per pack view. First, Article 43(7) and recital 121 warn against measures that simply move packaging from heavier to lighter materials, so a weight cut that swaps glass for plastic may meet a national limit even if it lowers kilograms. Second, commercial and industrial packaging sits inside Eurostat's per capita figure, but recital 120 says per capita targets cannot apply as such to it, so a brand's transport packaging may be treated differently from its consumer packs in national rules. Third, national schemes measure tonnage placed on the market, which is the figure a brand already reports to its EPR scheme each year; that report is the most likely route by which a prevention measure will reach the brand's costs.

## Spain: a national target on top of the EU one

Spain is the one market in this piece with a prevention target already in national law. Article 6 of Royal Decree 1055/2022 sets a reduction in the weight of packaging waste produced of 13% in 2025 and 15% in 2030, against 2010 (BOE; [PR-ES-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/spain/pr-es-002/)). Exhibit 8 sets the two Spanish targets side by side.

**SPI calculation.**  7,389,590 x 0.87 = 6,428,943 tonnes for 2025 and 7,389,590 x 0.85 = 6,281,152 tonnes for 2030. Against 9,502,487 tonnes in 2024, that is 32.3% and 33.9% less. The per capita figure rose from 179.20 kg in 2023 to 194.43 kg in 2024, up 8.5%; SPI's [Eurostat news piece](https://www.strategicpackaginginsights.com/news/eurostat-plastic-packaging-recycling-2024-42-4/) notes a break in Spain's plastic series in 2024, and SPI has not yet confirmed whether the total series is affected in the same way.

The two targets measure different things. The decree counts tonnes from 2010 and the PPWR counts kilograms per person from 2018. Spain's population growth means the tonnage target is the harder of the two: tonnage rose 26.0% from 2018 to 2024 while kilograms per person rose 20.6%, by SPI's calculation. MITECO's clarifying note of 19 May 2026 says the decree now governs only the matters the regulation does not cover or does not contradict, with a successor decree in preparation (MITECO; SPI's Spain note). SPI has not yet confirmed whether the successor will keep the 2010 tonnage target.

The decree also names the measures. Article 7 requires food shops of 400 m2 or more to give at least 20% of their sales area to products sold without primary packaging, including bulk and reusable containers, requires whole fresh fruit and vegetables to be offered loose with exceptions, and requires event promoters to replace single-use cups from 1 July 2023 (BOE, article 7). The [Spain cost stack piece](https://www.strategicpackaginginsights.com/insights/spain-packaging-decree-plastic-tax-cost-stack/) covers the fee and tax side of the decree; this piece does not repeat it.

In practice: Ecoembes.

Spain's main household packaging scheme runs a business prevention and ecodesign plan for its member companies. The trade publication Corresponsables reported on 19 November 2024 that 2,048 companies applied more than 10,400 ecodesign measures under the 2021 to 2023 plan, that 7,071 of them, or 68%, aimed at reduction, and that they saved 78,600 tonnes of raw material; SPI has not yet confirmed those figures in Ecoembes' own publications. Set against Spain's 9.50 million tonnes of packaging waste in 2024, three years of plan savings equal 0.8% of one year's tonnage, by SPI's calculation.

## Poland: the steepest climb from the lowest baseline

Poland's path to 2030 starts from a 2018 figure that sits below the years around it. Exhibit 9 shows the series.

**SPI calculation.**  The 2018 figure was 6.5% below 2017 and 2019 was 15.7% above 2018. In tonnes, Eurostat shows 5.85 million in 2017, 5.47 million in 2018 and 6.32 million in 2019. The 2030 level of 136.78 kg is lower than any Polish figure since 2015.

That shape is the case Article 43(8) was written for: a Member State could ask the Commission, by 31 December 2025, to use another base year if it showed a significant rise caused only by changes in reporting methods and not by consumption (Article 43, German text as reproduced). SPI has not yet confirmed what caused the 2018 dip in Poland's series, or whether Poland made such a request.

Poland also has no national prevention target in its packaging law, to SPI's knowledge. Its deposit system began on 1 October 2025, and the ministry reports about 5 billion containers returned on operator data for October 2025 to September 2026 (SPI's Poland note). The government's packaging bill, UC100 on the legislative list, is meant to implement the PPWR and adapt EPR; the ministry's reply of 18 February 2026, signed by an undersecretary of state, sets out a reform model focused on EPR financing and recycling levels and gives no date for the bill (Ministry of Climate and Environment, reply to interpellation 14977). That reply does not mention Article 43. SPI's [Poland piece](https://www.strategicpackaginginsights.com/insights/poland-packaging-epr-deposit-system/) covers the deposit and EPR detail.

SPI analysis

Poland combines a 24.2% cut, the sixth largest in the EU, with a reform bill that has no date. A brand selling in Poland should expect the prevention lever to arrive inside UC100's EPR design, through fee modulation or prevention plan duties, rather than as a separate law.

## Where national measures land on a brand

Article 43(5) gives Member States a menu, and other PPWR articles add tools that count towards the same target. Exhibit 10 maps each lever to the part of a brand's business it reaches.

**Fees.**  EPR incentives are the most direct lever, because they price packaging by weight. SPI's [fee per tonne piece](https://www.strategicpackaginginsights.com/insights/epr-fees-per-tonne-2026/) compares scheme rates; under Article 43(5) the per tonne rate itself becomes a prevention tool.

**Reuse quotas.**  A state may set reuse targets above the EU ones only under Article 51. The Commission's guidance lists cumulative conditions: the new targets must be necessary for the state to reach its waste reduction targets, must not distort the internal market and must be notified through the TRIS procedure; it adds that higher national prevention targets cannot justify raising the EU reuse targets (Commission Notice, section 27). SPI's [reuse targets piece](https://www.strategicpackaginginsights.com/insights/ppwr-reuse-targets-transport-grouped-packaging-pallets-crates/) covers the EU reuse levels.

**Design rules.**  The Commission's guidance says packaging minimisation requirements help Member States reach their packaging waste reduction targets in a harmonised manner (Commission Notice, section 10). The 2030 format bans and empty space limit therefore count towards Article 43 without any national law.

In practice: France's 3R decree.

France measured its own single-use plastic reduction goal from 2018, the same base year as Article 43. Décret 2021-517 set a 20% cut in single-use plastic packaging by 31 December 2025, at least half through reuse, and the ministry's June 2025 interim review recorded a 3.3% rise between 2018 and 2021 instead (SPI tracker, [PR-FR-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/france/pr-fr-001/)). Over the same 2018 to 2024 window France's total packaging waste per person fell 11.5%, by SPI's calculation from Eurostat. The two measures differ in scope, and a cut in all materials per person does not mean a cut in single-use plastic.

In practice: Nestlé.

Corporate targets often share the 2018 base. Nestlé reports that its plastic packaging fell from 1.7 million tonnes in 2018 to about 0.86 million tonnes in 2025, and its September 2026 strategy sets 12% to 17% less virgin plastic by 2030 against an adjusted 2018 baseline of 611 kt that excludes Nestlé Waters and Premium Beverages (SPI Buyers Database, Nestlé profile). These are global group figures in tonnes and cannot be read against any national per capita series.

## Industry reaction

> "In 2024, 81.5 million tonnes of packaging waste were generated in the EU, or 181.0 kg per inhabitant."

***Eurostat** , [news item on plastic packaging waste](https://ec.europa.eu/eurostat/web/products-eurostat-news/w/ddn-20261022-1), 22 October 2026*

The figure is the first full EU number since the PPWR began to apply on 12 August 2026, and it is the one against which the first progress reports will be read.

> "Packaging waste per capita increased by 3.2 kg compared with 2023, and by 19.6 kg compared with 2014."

***Eurostat** , [news item on plastic packaging waste](https://ec.europa.eu/eurostat/web/products-eurostat-news/w/ddn-20261022-1), 22 October 2026*

The 19.6 kg rise over ten years matches SPI's reading of the env_waspac series, from 161.44 kg in 2014 to 180.99 kg in 2024.

> "There is no material-specific waste prevention target."

***European Commission** , [Commission Notice C/2026/3084, guidance document for Regulation (EU) 2025/40](https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52026XC03084), section 24*

The Commission makes the point when it explains how a Member State's prevention result affects national exemptions from the reuse targets. For brands it means each state chooses which materials and formats carry its cut.

## What leaders should do now

1. **Packaging and sustainability directors, by mid 2027:**  build a market by market table of packaging grams per unit sold and tonnes placed on the market, dated from 2018 where data allow, so the brand's own trend can be set against Exhibit 5.
2. **Regional general managers, in the 2027 planning round:**  place every European market in one of the four groups of Exhibit 6 and plan reduction projects first for group D markets, including Spain and Poland.
3. **EPR and compliance teams, from now:**  track each national EPR reform and prevention plan rule, starting with Poland's UC100 bill and Spain's successor decree, and record where fee modulation by weight or format is proposed.
4. **Public affairs teams, on each TRIS notification:**  check national reuse quotas against the Article 51 conditions the Commission lists, and respond within the notification window where a quota touches your formats; check with counsel where it applies.
5. **Packaging engineers, by 2028:**  prioritise weight cuts that do not shift material from heavier to lighter formats in a way Article 43(7) and recital 121 warn against, so projects do not run into national limits.
6. **Finance teams, in the 2028 budget:**  model fee exposure under the base case of Exhibit 7 for group D markets, scheme by scheme and in each scheme's own currency.
7. **Retail and food service customers' account teams, during 2027:**  prepare for bulk, refill and tap water rules of the kind Spain's decree and Article 43(6) set, which change the mix of packaged and unpackaged sales.

## Questions for your board

- In which of our European markets is national packaging waste per person furthest above 2018, and what share of our sales do they carry?
- Do we know our own packaging grams per unit sold by market, from 2018 to today?
- Which national EPR schemes we pay into are likely to add weight-based or prevention incentives before 2030?
- Do any of our formats depend on a shift to lighter material that a national measure could treat as moving the problem?
- How exposed are we to national reuse quotas justified by Article 43, and who reviews TRIS notifications?
- Do our corporate packaging targets, set on our own baselines, help or hinder the national cuts our largest markets must make?

## What to watch

- **12 Feb 2027:**  the Commission's tourism correction factor under Article 43(2) and the Article 56(7) reporting implementing act are due.
- **During 2027:**  Spain's successor packaging decree and Poland's UC100 bill, the two national texts most likely to carry prevention measures for brands in group D markets.
- **Autumn 2027:**  Eurostat's 2025 packaging waste data, on its usual release pattern, the first calendar year with the PPWR in force.
- **2028:**  the 3% per capita reduction against 2018 that Article 29(14) requires before a state can exempt operators from the reuse targets.
- **31 Dec 2030:**  the first Article 43 target year, at least 5% less packaging waste per person than in 2018.
- **12 Feb 2032:**  the Commission's review of the targets under Article 43(9).

## Methodology

- **Data used:**  Article 43 of Regulation (EU) 2025/40, read in the German text as reproduced by LX Gesetze, an unofficial reproduction, and translated by SPI; recitals 119 to 121 in the English Official Journal text on EUR-Lex; Commission Notice C/2026/3084, sections 10, 24 and 27; Eurostat's news item of 22 October 2026 and its env_waspac dataset, packaging waste generated in kg per inhabitant and tonnes; Royal Decree 1055/2022, articles 6 and 7; Poland's ministry reply of 18 February 2026; SPI tracker entries [PR-EU-011](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-011/), [PR-EU-006](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-006/), [PR-ES-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/spain/pr-es-002/) and [PR-FR-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/france/pr-fr-001/) and SPI's Spain and Poland notes, rechecked on 30 October 2026.
- **Counting rules:**  changes, levels and cuts are by SPI's calculation in kg per person, or in tonnes for Spain's national target; no currency figures are used. Levels for 2030, 2035 and 2040 are 95%, 90% and 85% of each state's 2018 figure in Eurostat's current series. The latest year is the most recent year with a value. EU 27 rows are for reference, since Article 43 binds each state.
- **Scenarios:**  the three paths in Exhibit 7 are SPI assumptions built from Eurostat's own rates; they are not forecasts.
- **Cut-off:**  30 October 2026.
- **Limitations:**  paragraph numbers in Article 43 rest on the unofficial text and SPI has not yet confirmed them against the Official Journal article text. Article 43(1) uses the 2018 figure each state reported, which may differ from Eurostat's current series. The tourism correction factor is not yet set. Several 2024 values are provisional. This is not legal advice; check with counsel where it applies.

## Sources

1. LX Gesetze, Art. 43 PPWR, Vermeidung von Verpackungsabfällen, German text of Regulation (EU) 2025/40 as reproduced, [https://lxgesetze.de/ppwr/43](https://lxgesetze.de/ppwr/43), consulted 2026-10-30.
2. EUR-Lex, Regulation (EU) 2025/40 on packaging and packaging waste, OJ L 22.1.2025, recitals 119 to 121, [https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202500040](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202500040), consulted 2026-10-30.
3. EUR-Lex, Commission Notice C/2026/3084, guidance document for Regulation (EU) 2025/40, sections 10, 24 and 27, [https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52026XC03084](https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52026XC03084), consulted 2026-10-30.
4. Eurostat, Plastic packaging waste in the EU: 35.9 kg per person, news item, 22 October 2026, [https://ec.europa.eu/eurostat/web/products-eurostat-news/w/ddn-20261022-1](https://ec.europa.eu/eurostat/web/products-eurostat-news/w/ddn-20261022-1), consulted 2026-10-30.
5. Eurostat, env_waspac, packaging waste generated, kg per inhabitant, all reporting countries, 2018 to 2024, [https://ec.europa.eu/eurostat/api/dissemination/sdmx/2.1/data/env_waspac/A.W1501.GEN.KG_HAB.?format=TSV&amp](https://ec.europa.eu/eurostat/api/dissemination/sdmx/2.1/data/env_waspac/A.W1501.GEN.KG_HAB.?format=TSV&amp);startPeriod=2018, consulted 2026-10-30.
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