Updated: September 2026 · Reviewed following the start of the PPWR’s general application and the official guidance published by the European Commission in 2026.
Regulation (EU) 2025/40 — known as the PPWR — entered into force on 11 February 2025 and has applied generally since 12 August 2026. For companies that manufacture, import, distribute or sell packaged products on the European market, this affects packaging design, the documentation that must be available, and the allocation of responsibilities between operators.
This article explains what actually changes from that date, who is affected and what needs to be reviewed now. It also clarifies which matters still depend on further technical development, so you can distinguish between what is urgent and what is still pending.
What Is the PPWR and Why It Matters Now
The PPWR — Packaging and Packaging Waste Regulation — replaces the old Packaging Directive 94/62/EC, which had been in force for almost 30 years. It was published in the EU Official Journal on 22 January 2025 and entered into force on 11 February 2025.
The shift from Directive to Regulation has a direct implication: it applies uniformly across all Member States without the need for national transposition. However, producer registers, extended producer responsibility (EPR) and certain collection and return measures continue to have national layers that must be checked country by country.
The PPWR covers all packaging types — primary, grouped, transport, service, e-commerce — regardless of material. Its main pillars are: sustainable design, recyclability, minimisation, recycled content, labelling and extended producer responsibility.
What Changes from 12 August 2026 — and What Does Not
The PPWR has applied generally since 12 August 2026, but not all obligations became enforceable on that day. Some already apply; others have staggered deadlines extending to 2028, 2030 and beyond. The Commission clarified this phased structure in its 2026 guidance and official FAQ.
What Applies from August 2026
Conformity assessment and technical documentation
Since 12 August 2026, manufacturers must assess packaging conformity, prepare the technical documentation required by Annex VII and issue an EU declaration of conformity for requirements that are already applicable. The specific recyclability assessment under Article 38 and Annex VII will be required when the delegated acts under Article 6(4) enter into force.
Restriction of substances of concern
Since 12 August 2026, food-contact packaging may not be placed on the market if it exceeds the PPWR limits for PFAS. There is no general stock exhaustion rule merely because packaging was manufactured before that date; packaging already placed on the market before 12 August 2026 may continue to be made available.
Heavy metal restrictions
The existing limit is maintained: the sum of lead, cadmium, mercury and hexavalent chromium must not exceed 100 mg/kg.
What Still Depends on Further Development
Recycled content in plastics
The PPWR sets minimum recycled content targets with increasing thresholds for 2030 and 2040. The calculation methodology and specific exemptions are pending implementing acts.
Harmonised labelling
Harmonised labelling will apply from 12 August 2028 or 24 months after the relevant implementing acts enter into force, whichever is later. It will provide information on material composition; digital means will only supplement the label where the PPWR so provides.
Recyclability grades
The PPWR provides only grades A, B and C; packaging below grade C is technically non-recyclable. The A/B/C system will apply from 2030 or 24 months after the relevant delegated acts enter into force, whichever is later. From 2038, packaging must achieve at least grade B.
Empty space
A harmonised maximum empty-space ratio of 50% will apply to grouped, transport and e-commerce packaging from 1 January 2030 or three years after the implementing act establishing the calculation methodology enters into force, whichever is later. It is not an obligation applicable since August 2026.
Ban on certain single-use formats
Certain single-use plastic formats (such as individual portion packs for condiments in the HORECA sector) will be banned from 1 January 2030, not from August 2026.
Who Is Affected by the EU Packaging Regulation
The PPWR applies to all operators that place packaging or packaged products on the EU market, regardless of origin. The specific responsibilities depend on the role each company plays in the supply chain.
Manufacturers
The manufacturer is not always the company that physically produces the packaging. For sales and grouped packaging, it is generally the operator that performs the final packaging operations and places the packaged product on the market, often the brand owner. For transport and service packaging, it is generally the packaging manufacturer, unless the packaging is marketed under the user’s name or trademark. Specific exceptions exist for micro-enterprises, so the role must be analysed case by case.
Importers
Companies established in the EU that introduce packaged products manufactured outside the EU have their own obligations: verifying that the manufacturer has carried out the conformity assessment, that adequate technical documentation exists, and that the declaration of conformity is available. This responsibility cannot be delegated to the overseas supplier without genuine verification.
Distributors, own-brand labels, marketplaces and fulfilment providers
Distributors must exercise due diligence and carry out the checks required by the PPWR, rather than verify every aspect of conformity. They may assume manufacturer obligations if they market packaging under their own name or trademark, or modify it in a way that may affect conformity. Online platforms and fulfilment service providers have their own duties concerning producer information, EPR registration and data reliability, but do not automatically become manufacturers.
Documentation You Need to Have Ready Now
The PPWR introduces for packaging a documentary structure with a logic similar to that which exists for products subject to other European regulatory frameworks: conformity assessment, supporting technical documentation and EU declaration of conformity. These are different frameworks and must not be confused, but the operational logic is similar.
If the company is the PPWR manufacturer, it must prepare its own technical documentation and EU declaration of conformity, using supplier data as supporting evidence. The documentation must cover the applicable requirements and follow Annex VII of Regulation (EU) 2025/40.
If the company is an importer, it must verify that the manufacturer has completed the required process. A standalone supplier document does not automatically replace the technical documentation, conformity assessment or declaration required for the operator’s role.
How to Run a Practical Review Step by Step
Map your packaging
Inventory all types you use: primary, grouped, transport, e-commerce, service. Note the material, function, supplier and country of manufacture.
Identify your role as an economic operator
Manufacturer, importer or distributor? This determines what specific obligations apply to you under the PPWR.
Collect technical data on the packaging
Material composition, weight, volume, proportion of empty space where applicable, and supplier information on recyclability.
Review minimisation and empty space
Review packaging minimisation now and prepare for the harmonised 50% empty-space limit for grouped, transport and e-commerce packaging when its later application date is reached.
Review the status of your technical documentation
Does it exist? Is it up to date? Do you have the EU declaration of conformity or can you request it from your supplier?
Identify gaps and prioritise
Separate what already applies (documentation and applicable substance restrictions) from later requirements on recyclability, labelling and empty space.
Decide whether you need external support
If the review reveals significant gaps or uncertainty about your operator role or the documentation required, this is the time to seek a specific assessment.
Common Mistakes When Interpreting the New Packaging Regulation
1."The PPWR still has not started to apply."
Its general application began on 12 August 2026. The conformity assessment, technical documentation and EU declaration obligations already apply to applicable requirements, as do the PFAS limits for food-contact packaging.
2."The obligation only falls on the packaging manufacturer."
The PPWR distributes responsibilities between manufacturers, importers and distributors. If you introduce packaged products manufactured outside the EU onto the EU market, you have your own verification obligations, regardless of what the overseas supplier does.
3."Since the technical recyclability criteria are still pending, nothing is urgent."
The specific recyclability assessment depends on the delegated acts under Article 6(4), but this does not postpone obligations already applicable since 12 August 2026, including documentation, conformity assessment for applicable requirements and substance restrictions.
Frequently Asked Questions About the PPWR and Consumer Products
What to Keep in Mind Before Selling in Europe
The PPWR has applied generally since 12 August 2026 and affects manufacturers, importers, distributors, online platforms and fulfilment providers according to their specific role.
Conformity assessment for applicable requirements, technical documentation, the EU declaration of conformity and PFAS limits for food-contact packaging already apply. The specific recyclability assessment, harmonised labelling and the harmonised empty-space limit follow later timetables.
Companies should therefore separate current obligations from later milestones and review their packaging, documentation and supply-chain responsibilities on that basis.
Need to review whether your packaging, documentation or the allocation of responsibilities in your supply chain is aligned with the PPWR? Tell us about your case and we will analyse which requirements apply to your specific situation.
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Author
Written by Juan Manuel Beltrán, Founder & Product Compliance Consultant at Conformity Point. Specialist in consumer product compliance for the European market, he helps manufacturers, importers and brands sell consumer products in Europe.
Reviewed and updated: September 2026