Updated: April 2026 · Incorporates the official clarifications published by the European Commission on 30 March 2026
Regulation (EU) 2025/40 — known as the PPWR — is already in force and its general application begins on 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 ready, 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. Companies cannot wait for their country to interpret it; the framework is the same from day one of application.
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
August 2026 is the general application date, but not all obligations enter into force on exactly that day. Some are enforceable from the outset; others have staggered deadlines extending to 2028, 2030 and beyond. The Commission confirmed this phased structure in its clarifications of 30 March 2026.
What Applies from August 2026
Conformity assessment and technical documentation
Manufacturers must ensure that all packaging placed on the EU market has undergone a conformity assessment procedure (Article 38 and Annex VII of the PPWR) and is backed by an EU declaration of conformity with technical documentation demonstrating compliance with the requirements of Articles 5 to 11. This is not a future aspiration: it is enforceable from August 2026.
Restriction of substances of concern
Packaging must be manufactured so as to minimise the presence of substances of concern. For food-contact packaging, specific restrictions apply to certain compounds (PFAS) directly from 12 August 2026, with no transition period.
Recyclability principle
All packaging must be recyclable from August 2026. However, the harmonised Design for Recycling (DfR) technical criteria will be set by delegated acts before January 2028. The principle is enforceable now; the precise technical thresholds will come in 2028.
Minimisation and empty space
For grouped and transport packaging, empty space must not exceed 50%. For e-commerce packaging, the Commission has confirmed a limit of 40%, unless technically unavoidable.
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
The digital labelling system with identifiers (QR codes or similar) linking to environmental information is scheduled to apply from 2027. The detailed technical specifications depend on delegated acts still in preparation.
Recyclability grades
The PPWR classifies packaging by recyclability grade (A, B, C, D). The technical criteria defining each grade will be set before January 2028. From 2030, only packaging with grade C or above may be placed on the market.
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 whoever produces the packaging — or has it produced — and places it on the market under their name. If you put your name on the packaging and are the first to introduce it to the EU market, you are most likely the manufacturer under the PPWR, even if the packaging was produced by a third party. The manufacturer is responsible for the conformity assessment and technical documentation.
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 and marketplace sellers
Distributors must verify compliance before making packaging available on the market. Own-brand (private label) companies often assume responsibilities equivalent to those of the manufacturer. Marketplace platforms are explicitly recognised by the PPWR as actors with responsibilities when they handle packaging or logistics on behalf of third-party sellers.
Documentation You Need to Have Ready Before August 2026
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.
The technical documentation must demonstrate that the packaging meets the applicable requirements: material composition, packaging function, evidence on recyclability and minimisation, and the basis for the declaration of conformity. The full detail of what it must contain is set out in Annex VII of Regulation (EU) 2025/40.
For importers, receiving a document from the supplier and filing it is not enough. A reasonable verification that the document has a real and up-to-date basis is expected.
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
For transport or e-commerce packaging, verify that empty space does not exceed 50% (or 40% for e-commerce).
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 is urgent (documentation, empty space, substances) from what still depends on further development.
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."I'll deal with it after August 2026."
Technical documentation, the declaration of conformity and restrictions on empty space and substances are enforceable from that day, with no additional margin. Waiting can create problems at customs, on marketplaces or with clients who request documentation before that date.
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 aren't finalised until 2028, nothing is urgent."
That part is correct — the Design for Recycling criteria will be finalised in 2028 — but it is not valid as a reason not to act now. The obligations on documentation, conformity assessment, declaration of conformity and substance restrictions already apply in August 2026.
Frequently Asked Questions About the PPWR and Consumer Products
What to Keep in Mind Before Selling in Europe
The PPWR affects any company placing packaging on the European market: manufacturers, importers, distributors and marketplace sellers. The date of 12 August 2026 is real and approaching fast.
Some obligations enter into force that day without exception: technical documentation, declaration of conformity, restrictions on empty space and restrictions on substances. Others — technical recyclability criteria, digital labelling, bans on certain packaging formats — have later deadlines. Knowing that difference is the first step to prioritising correctly.
Companies that review their packaging and documentation before August will have far more room to manoeuvre than those who wait until the problem appears at customs, in a client request or in a platform requirement.
You can find out more about how we support companies through regulatory compliance processes at Conformity Point.
Need to review whether your packaging, documentation or responsibility structure is aligned with the PPWR before August 2026? Tell us about your case and we will analyse together what applies to your specific situation.
Tell us about your caseOfficial Sources
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: April 2026