Most companies that follow packaging regulations have planned around two deadlines, 2025 and 2027, set by the loi AGEC (French anti-waste law for a circular economy). These are milestones, not an end point. Behind them, a second timeline, this time at EU level, takes over with obligations that run until 2040. Here is what is already known, what is likely, and what remains uncertain beyond 2027.
What is settled: the end of the 2021-2025 French framework
Decree No. 2022-507 of April 8, 2022, which sets the French reuse trajectory (5% in 2023, 10% in 2027), is part of a five-year strategy known as “3R” (reduction, reuse, recycling), whose first period, 2021-2025, has now ended.
A recent parliamentary question confirms that a revision of this framework for 2026-2030 is under consideration, in the wake of the projet de loi DDADUE (bill adapting French law to European Union law). Two things are therefore certain: there will be a new framework, and it will have to work alongside the EU PPWR regulation, which applies in parallel. What is not yet certain is the exact level of the French thresholds after 2027. Wait for the text to be published before building an investment plan on a figure that has not yet been set.
What is likely: the shift to the EU timeline
From August 12, 2026, Regulation (EU) 2025/40, known as the PPWR, applies directly in all Member States, without waiting for transposition into French law. In practice, it becomes the reference framework for the years after 2027, with a timeline already published up to 2040:
- 2028-2029: harmonized labeling rules come into force across the European Union.
- January 1, 2030: a major turning point. The lowest-performing recyclability classes (D and E) are banned. Empty space in grouped, transport and distance-sales packaging is capped at 50% of volume. The first reuse quotas for transport packaging (pallets, pallet boxes, returnable crates, drums, pallet wrapping films) take effect, at 40%.
- 2035 and 2038: additional intermediate steps, whose precise details depend on delegated acts still pending.
- 2040: the reuse quota for transport packaging rises to 70%.
The direction of travel is therefore clear: requirements that keep rising over a long period, well beyond the 2027 horizon where many French companies stopped their planning.
What remains uncertain
Three gray areas are worth monitoring rather than treating as settled. The first concerns the PPWR delegated acts: several calculation methods, including the one for the transport packaging reuse rate, have not yet been set by the European Commission. At the Environment Council in June 2026, eight Member States reported implementation difficulties, and in August 2026 the Commission said it was making progress on the necessary secondary legislation. The overall timeline should not move, but some detailed thresholds may still be clarified, or even adjusted.
The second concerns how French and EU thresholds fit together. The French décret 3R (3R decree) and the EU PPWR pursue the same goal, but with different calculation logics: sales units on the French side, packaging families and uses on the EU side. How France will, or will not, align its national framework with the EU regulation after 2027 has not yet been publicly decided.
The third concerns the timeline of the extended producer responsibility (EPR) scheme for B2B packaging (filière REP emballages professionnels). This scheme, separate from the PPWR but tied to the same reuse and recycling goals, was already postponed once in 2026: its launch, planned for July 1, was pushed back to January 1, 2027. Its financial ramp-up, which targets €600 million in annual eco-contributions by 2030, remains a stated goal, not a given.
What this means for an e-commerce or logistics SME or mid-sized company
Limiting your thinking to 2027 would be a timing mistake. An investment in reusable packaging, with an organized return loop, pays back over several years, and the 2030 and 2040 thresholds already known for transport are more relevant to an investment decision than the 10% threshold for 2027, which is only a waypoint. The 50% maximum empty space rule points the same way: it will only apply from 2030 to grouped, transport and distance-sales packaging, but it requires redesign work on formats that takes time. A company that waits until 2029 to look into it will start late.
Finally, there are two timelines to follow, not one. The French framework (3R, EPR scheme) and the EU framework (PPWR) evolve at their own pace, with interactions that are not all settled yet. A twice-yearly review that cross-checks both timelines limits the risk of discovering an obligation after it has come into force.
Forward-looking timeline
| Deadline | What is expected | Level of certainty |
|---|---|---|
| 2026-2030 | Revision of the French 3R framework | Announced, thresholds unknown |
| January 1, 2027 | Launch of the B2B packaging EPR scheme | Set, unless postponed again |
| 2028-2029 | PPWR harmonized labeling | Set by the EU regulation |
| January 1, 2030 | 50% empty space, ban on classes D/E, 40% transport reuse | Set by the regulation, calculation methods to be clarified |
| 2035-2038 | PPWR intermediate steps | Announced, details to be published |
| 2040 | Transport reuse raised to 70% | Set by the regulation |
One thing, at least, is beyond doubt: every known revision since 2020, French and European alike, has pointed in the same direction. None has yet eased the pressure on reuse, and nothing suggests the next one will.
This article is for information only and does not replace legal advice. The post-2027 deadlines presented here rely partly on texts still under discussion or on unpublished delegated acts: check their status before any investment decision.
Sources
- Parliamentary question on the revision of the 3R decree
- Detailed PPWR timeline, Projet Celsius
- Reuse quotas by packaging category, Projet Celsius
- Postponement of the B2B packaging EPR scheme's entry into force, Banque des Territoires
- Overview of the regulation, European Commission Circular Economy platform