EU PPWR 2026: Hotel Operator's Reference to Regulation (EU) 2025/40

Regulation (EU) 2025/40 on packaging and packaging waste — the PPWR — replaces Directive 94/62/EC and restructures how packaging is regulated across the European Union. It is not an update to the previous directive. It is a rewrite. For hotel operators, several provisions are directly relevant: a prohibition on specific amenity formats, recyclability requirements that take effect before the format ban, and documentation obligations that run alongside the formulation compliance requirements already in place under EU Cosmetic Regulation. (Full text of Regulation (EU) 2025/40 on EUR-Lex)

This reference covers the provisions that affect hotels, the dates they apply, how they interact with Spanish and Balearic national law, and what documentation is required.

Key dates for hotel operators

The August 2026 and January 2030 dates are not interchangeable. Different obligations apply at each. Operators who defer action until 2030 on the basis that the miniature prohibition has not yet taken effect may still be non-compliant from August 2026 under the recyclability provisions.

What PPWR requires from August 2026

The recyclability and reusability requirements in PPWR apply from the date the regulation takes general effect — August 2026 — not from the Annex V prohibition date.

From August 2026, packaging placed on the EU market must demonstrate one of the following:

- A documented recycling pathway — the material is collected, sorted, and processed in existing recycling infrastructure. This must be verifiable, not assumed from material type. - Recyclability by design — the packaging is designed to be recyclable, meeting specific criteria for material compatibility, label removability, and component separability. - A documented reuse pathway — the packaging functions in a reuse system: it is collected, cleaned, refilled, and redistributed. This includes wall-mounted dispensing systems with documented refill cycles.

Packaging that cannot demonstrate one of these pathways is not PPWR-compliant from August 2026, regardless of what format it takes. Single-use miniatures that are made of technically recyclable material but are not recycled in practice — too small for sorting, contaminated by product — do not meet the standard.

For hotel operators, this means the packaging your amenity supplier uses needs verification before August 2026, not before January 2030.

Annex V — prohibited packaging formats

Annex V of PPWR lists single-use packaging formats that will be prohibited. For the hotel sector, the relevant entry is single-use amenity packaging: shampoo, conditioner, body wash, lotion, and soap in individually sealed packaging format. The prohibition takes effect on 1 January 2030.

The Annex V prohibition applies to the act of placing the packaging on the market. By 2030, suppliers cannot supply hotel miniatures in this format, and operators cannot receive or use them.

The scope is format-specific, not size-specific. Products in sealed individual containers below a certain volume threshold are the target, not small packaging in general. Miniature-format amenities in certified compostable packaging that meets EN 13432 certification are not prohibited under Annex V.

How PPWR interacts with Spanish national law

Spain's Royal Decree 1055/2022 (transposing Directive 94/62/EC before it was replaced) and Law 7/2022 on waste and contaminated soil introduced a national packaging levy and extended producer responsibility (EPR) framework. These remain in force independently of PPWR and impose obligations on producers and distributors placing packaging on the Spanish market.

For hotel operators, the relevant interaction is that amenity packaging is subject to both the PPWR requirements from August 2026 and the Spanish national EPR levy. Compliance with PPWR does not exempt a product from national levy obligations. A supplier providing PPWR-compliant packaging into Spain should also be able to demonstrate their EPR registration status under the Spanish national framework.

How PPWR interacts with Balearic Law 8/2019

Balearic Law 8/2019 predates PPWR and imposes stricter requirements for operators in Mallorca, Ibiza, Menorca, and Formentera. The Balearic prohibition on single-use plastic amenity items has been in force since 2019 — over a decade before the PPWR Annex V prohibition takes effect.

For Balearic operators, PPWR is not the primary regulatory concern. Law 8/2019 already requires compliance. The PPWR general-effect date in August 2026 adds recyclability documentation requirements on top of the existing format prohibition.

Operators outside the Balearics but within Spain face the January 2030 Annex V date as their first format-specific deadline, with the August 2026 recyclability requirements applying from that date. (Balearic Law 8/2019 full compliance guide for hotel operators)

CPNP registration: the parallel compliance requirement

PPWR regulates packaging. The formulations inside that packaging are regulated separately under EU Cosmetic Regulation (EC) No 1223/2009, which requires CPNP registration for every cosmetic product placed on the EU market.

These are two independent compliance requirements. A hotel can have PPWR-compliant packaging around a product with inadequate CPNP documentation, or fully CPNP-registered formulations in packaging that does not meet PPWR recyclability requirements. Compliance with one does not create compliance with the other.

Both requirements apply simultaneously. For operators evaluating their amenity supplier, both need to be verified. (Full guide to CPNP registration for hotel operators)

What documentation hotel operators need to maintain

Under PPWR and the parallel requirements, the following documentation should be on file for every amenity product in active use:

Packaging documentation: - Supplier declaration confirming the packaging format (not single-use miniature, or if it is, confirming transition timeline before January 2030) - Recyclability evidence: material composition, recycling pathway documentation, or reuse cycle documentation for dispensing systems - For dispensing systems: documented refill protocol and tamper-evidence specification

Formulation documentation: - CPNP notification number for each specific product as supplied (not the base formulation) - Safety assessment (CPSR) signed by a qualified EU Cosmetic Safety Assessor - Product Information File (PIF) reference, held by the Responsible Person - ISO 11930 preservative efficacy test result

For Balearic operators, additionally: - Circularity Plan (annual, if the property meets the qualifying threshold under Decree-Law 3/2022) - Local sourcing percentage documentation for amenity ingredients - Supplier compliance declarations referencing Law 8/2019 and PPWR

Inspections — whether by Balearic environmental authorities under Law 8/2019 or by national authorities under the Spanish PPWR enforcement framework — typically request supplier declarations and CPNP records first. Properties that cannot produce them on the day are flagged for follow-up.

Common compliance gaps

Assuming the supplier has handled it. Most mid-market amenity suppliers in Spain have not completed CPNP registration for every product in their range, and have not assessed their packaging against PPWR recyclability requirements. The operator carries liability alongside the Responsible Person.

Confusing biodegradable with compliant. Products labelled biodegradable or eco-friendly are not necessarily compliant with PPWR recyclability requirements (which require verifiable recycling pathways, not material properties) or with the EN 13432 certification required for the compostable exemption under Balearic Law 8/2019.

Treating January 2030 as the only deadline. The Annex V miniature prohibition takes effect then. PPWR recyclability and reusability obligations apply from August 2026. Operators who wait for 2030 are already non-compliant from mid-2026.

Custom branding without checking CPNP status. Custom-labelled amenities — hotel logo, property name — are notifiable as new products on the CPNP. A supplier may hold registration for their base formulation but not for the custom-branded variant. The hotel's name on the bottle does not transfer the compliance.

Evaluating your current supplier

Before August 2026, hotel operators should request the following from their amenity supplier:

- CPNP notification number for each specific product as supplied to the property - Written confirmation of who holds the Responsible Person designation for each product - Recyclability pathway documentation for each packaging format - For dispensing systems: tamper-evidence specification and documented refill protocol - Circularity Plan-relevant local ingredient sourcing data (for Balearic properties)

A supplier who can provide these within 48 hours is prepared. A supplier who cannot is a compliance risk, not a partner.

FAQ

What is the PPWR general-effect date for hotel operators? August 2026. From that date, packaging placed on the EU market must demonstrate recyclability, recyclability by design, or a documented reuse pathway. The Annex V hotel miniature format prohibition takes effect separately on 1 January 2030.

Does PPWR apply to hotels directly, or only to their suppliers? Primarily to producers and importers placing packaging on the market — your amenity supplier. But as the operator using the packaging and in some cases carrying the Responsible Person designation for custom-branded products, you carry associated liability. Verify your supplier's compliance before August 2026.

Are refillable dispensers PPWR-compliant? Dispensing systems with a documented reuse pathway — recorded refill cycles, tamper-evident closures, operational protocol — satisfy the PPWR reuse requirement. The formulation inside must also be separately CPNP-registered and ISO 11930-tested.

Does an amenity in certified compostable packaging avoid the Annex V prohibition? Yes, if it meets EN 13432 industrial composting certification. Biodegradable without this specific certification is not sufficient. The certification must be held by the packaging supplier and verifiable on request.

What is the fine exposure for non-compliance with PPWR? PPWR enforcement is handled by national authorities. Spain has not yet published a specific fine schedule for PPWR violations as of 2026. The Balearic Islands has a separate enforcement framework under Law 8/2019 with documented fines ranging from €200 (minor) to €150,000 (very serious). Balearic operators face both frameworks.

Where can I read the full regulation text? The full text of Regulation (EU) 2025/40 is available on EUR-Lex: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R0040

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Looking for a hotel amenity supplier with documented PPWR compliance? The SOSOO programme guide covers what a compliant programme looks like in practice.