Europe’s New Packaging Rule Hits Cannabinoid Beverages: PPWR 2025/40 Deadlines, Reuse Targets, and E‑Commerce Duties

Introduction

The EU Packaging and Packaging Waste Regulation (PPWR) 2025/40 marks a pivotal transformation in European packaging, affecting all sectors—including the growing hemp and cannabinoid beverage market. As of February 11, 2025, the PPWR is law throughout the European Union, with an 18-month transition that culminates in core compliance obligations from August 12, 2026. For cannabis beverage brands, these changes are a double-edged sword: while advancing the circular economy, they also impose complex compliance requirements, especially for companies accustomed to U.S.-style packaging and cross-border digital sales.

This update will equip industry players with a clear roadmap to compliance, focusing on EU PPWR 2025 cannabis beverage packaging compliance and touching on:

• Harmonized design-for-recycling and recyclability rules
• Material, labeling, and reuse targets
• Future deposit-return (DRS) and extended producer responsibility (EPR)
• E-commerce duties for online/overseas sellers
• Risk zones for aluminum cans and hybrid packaging formats

PPWR at a Glance: Key Dates and Applicability

PPWR (EU 2025/40) applies to all packaging placed on the EU market, whether imported or locally manufactured.

Key Milestones:

• February 11, 2025 — Regulation enters into force
• August 12, 2026 — Most core provisions become applicable (end of transition)
• 2030 — First major recyclability performance thresholds

If your cannabinoid beverages are legally sold anywhere within the EU—whether as hemp-derived functional drinks or low-THC cannabis sodas—PPWR applies regardless of your company’s HQ, production site, or ecommerce platform.

Read the full PPWR on the European Commission’s site.

Design-for-Recycling: New Mandates for All Beverage Packaging

Recyclability is Non-Negotiable

From August 2026, all packaging must be designed to be recyclable according to harmonized criteria. As of 2030, packaging will be considered market-compliant only if it achieves a recyclability performance grade of at least 70%.

• Composite, multi-material, or PFAS-containing packaging will face restrictions or outright bans.
• Brands must avoid mixed-materials (e.g., shrink sleeves on aluminum cans, labels using incompatible adhesives, or multi-layer plastics) in favor of mono-material solutions.
• Aluminum cans—preferred for many hemp/cannabinoid drinks—must not use plastic shrink sleeves or decorative wraps unless the entire assembly can be readily separated in standard EU recycling streams.

Takeaway for U.S. brands: U.S.-style aluminum cans with plastic wraps or sleeves are at high risk. Full-coverage labels and sleeves often render aluminum non-recyclable under EU rules; this could disqualify your SKUs from legal sale post-2026.

• SKU-by-SKU audit: Systematically review each beverage SKU for recyclability and material separation. Consult third-party recyclability standards recognized in the EU, and where possible, replace shrink sleeves/multilayer formats with direct-print cans or fully peel/tear-off sleeves.

Material & Labeling Restrictions

• PFAS ban: By August 2026, eliminate PFAS and other forever chemicals used in liners or coatings.
• Plastic targets: Rigid plastics must hit 10–65% post-consumer recycled (PCR) content, depending on type and contact sensitivity.
• Labeling: All packaging must provide clear sorting/recycling instructions using harmonized EU symbols by late 2026.

Reuse, Refill, and Deposit-Return: Ambitious Circular Targets

Reuse/Refill Obligations for Beverage Packaging

Non-alcoholic and functional beverage categories—where cannabinoid drinks typically sit—face progressive reuse/refill targets, meant to counteract single-use discards. By 2030,

• At least 10–25% of beverage products (category-dependent) must be supplied in reusable/refillable packaging for brands above certain volume thresholds.

Operators should be prepared to:

• Launch/expand refillable bottle/can programs (where legal and practical)
• Partner with regional logistics and cleaning providers
• Track SKU-level flows to distinguish single-use from refill lines

Deposit-Return Schemes (DRS)

All EU countries will be required to roll out deposit-return systems for beverage containers (including cannabinoid drinks) by 2029, if not before. Even small brands must:

• Participate in national DRS (register, report, pay fees)
• Design packaging (including labeling/marking) compatible with DRS machinery and guidelines

More information is available from TOMRA’s summary.

E-Commerce & Cross-Border Sales: New Duties for Non-EU Sellers

Extended Producer Responsibility (EPR): Registration & Reporting

Under the new regulation, all brands selling packaged cannabinoid beverages to EU consumers—including via e-commerce or fulfillment services—must:

• Register for EPR in any country where products are offered
• File annual packaging data reports
• Pay local EPR fees/take-back costs
• Ensure authorized representatives are present in the EU if headquartered abroad

Failure to register before the deadline will likely bar products from being lawfully offered for sale, and risk heavy penalties.

Online Platform and Distance Sales: No Loopholes

E-commerce operators and platforms must also comply. Each product shipment is traceable, and penalties for non-compliant packaging or missing registrations are severe. Non-EU brands using fulfillment services (e.g., Amazon FBA) face the same obligations as local producers.

See compliance guidance for e-commerce packaging at ecosistant.

Timeline: Readiness Countdown for Cannabis Beverage Brands

Q1–Q3 2025:

• Audit all beverage SKUs for material composition, recyclability, labeling compliance
• Begin R&D to shift away from non-compliant formats (e.g., shrink sleeves on cans)
• Evaluate warehousing/production for switching to mono-material and PCR-compliant plastics

Q4 2025 – Q2 2026:

• Substitute PFAS and other restricted substances as needed
• Develop or expand reuse/refill lines for beverage containers
• Register for all required national EPR systems in sales markets

Q3 2026 (by August 12):

• Finalize PPWR-compliant packaging—no more non-recyclable, mixed, or unregistered SKUs
• Update digital product listings with correct packaging details and compliance symbols
• Prepare for potential DRS integration where local laws are already active

Pitfalls & How to Avoid Them

1. U.S.-Style Aluminum Can Formats with Shrink Sleeves

Aluminum cans covered in plastic shrink sleeves or non-removable wraps are likely non-compliant. The presence of plastics or adhesives which cannot be easily removed in European recycling processes drastically reduces recyclability and may expose your business to enforcement actions or recalls.

2. Multi-Material Packaging

Mixed-material (composite) bottles, caps, or labels—common in U.S. beverage styling—will fall foul of recyclability and labeling rules.

3. Missed EPR/DRS Registrations

An easy-to-overlook compliance failure that results in product bans. Prepare documentation and registers now for each EU country of operation.

4. Ignoring Reuse/Refill Targets

Brands over certain sales thresholds must prove a proportion of product lines is reusable/refillable or be forced to reduce market offerings.

5. Neglecting B2C E-Commerce Duties

Online and direct-to-consumer portfolios require full registration and reporting, mirroring in-country physical sales.

Final Thoughts: Compliance is Not Optional

The EU PPWR 2025 cannabis beverage packaging compliance agenda is rigorous, and the consequences of non-compliance range from sales bans to costly recalls and fines. With the transition clock already ticking, cannabis and hemp beverage brands must prioritize:

• Immediate self-audits
• Early adoption of mono-materials and PCR-content
• Registration in national EPR databases
• Adaptation of labeling and design for easy consumer recycling

For real-time regulatory guidance, news on implementation in key EU member states, and direct assistance with packaging audits or SKU compliance evaluation, turn to CannabisRegulations.ai—your trusted partner for cannabis industry compliance in Europe and beyond.