PPWR: what has been in effect since August 12, 2026?

What is the PPWR?

The PPWR is the European Packaging and Packaging Waste Regulation, formally Regulation (EU) 2025/40. It was adopted on December 19, 2024, entered into force on February 11, 2025, and has been applicable since August 12, 2026. It replaces Directive 94/62/EC, which served as the foundation for thirty years.

The fact that the regulation only applies eighteen months after entering into force is stated in Article 71.

The difference with that directive is not just in the content. A directive had to be transposed into national law by each Member State, resulting in differing requirements per country. A regulation applies directly and uniformly in all Member States.

What applies since August 12, 2026

Since August 12, 2026, three types of obligations apply: limit values for substances in the packaging, a unique marking with manufacturer details, and a declaration of conformity supported by technical documentation. Redesigning packaging is not part of this; that will follow in 2030.

This is where reporting often goes wrong. Those who only read headlines about recyclability and empty space might think that the packaging itself must be modified now.

Limit values for substances, Article 5

For each limit value, you must keep proof in your file in the form of a test report or a signed supplier declaration.

• Heavy metals. The sum of lead, cadmium, mercury, and hexavalent chromium may not exceed 100 mg/kg. This applies to all packaging.
• PFAS, only for food contact. Maximum 25 ppb per individual PFAS, 250 ppb for the sum, and 50 ppm for all PFAS combined, including polymers.
• SVHC from the REACH Candidate List. None above 0.1% by weight. If they are present, you must specify which ones.
• REACH Annex XVII and the POP Regulation. Existing restrictions remain fully applicable.

Marking of packaging, Article 15

Packaging placed on the market from August 12, 2026, must bear information that allows it to be uniquely identified: a type, batch, or serial number. Another means of identification is also permitted. Additionally, the name or registered trademark of the manufacturer plus the postal address must be included. This may also be provided via a QR code or another digital data carrier.

Not every component needs to be marked individually. For a cup with a lid and label, it is sufficient for the information to appear on one component.

Declaration of Conformity and technical file, Article 39

You must draw up an EU declaration of conformity according to the model in Annex VIII, supported by technical documentation. The assessment procedure is Module A, internal production control, from Annex VII. You perform this yourself; no notified body is involved.

What happens to your stock

Packaging already placed on the market before August 12, 2026, may remain there, even if it does not comply with the PPWR. Packaging that has already been produced but is still in stock does not need to be destroyed, remade, or relabeled.

This is the most frequently asked question. The Commission answers it in the second edition of its FAQ. This exception is limited in three ways.

• For stock from before that date, the unique identification and manufacturer details may be provided in an accompanying document instead of on the packaging itself.
• For packaging produced after August 12, 2026, such an accompanying document is only permitted if it is truly impossible to apply the information to the packaging.
• If your supplier no longer exists or does not cooperate, an obligation of best effort applies. Document what you have tried, as this is what you can demonstrate later.

What comes later

The most well-known PPWR requirements apply later. Packaging minimization, recyclability classes, the minimum share of recycled content, and the rule regarding a maximum of fifty percent empty space will take effect on January 1, 2030. Harmonized labeling follows earlier, on August 12, 2028. In 2038, recyclability requirements will be further tightened.

The Commission explicitly confirms in its FAQ that Article 10 on minimization will only apply in its entirety as of January 1, 2030. Until the end of 2029, the essential requirements of the old Packaging Directive remain in force.

The main focus is on January 1, 2030. That is when minimization, recyclability classes, recycled content, and the empty space rule all take effect simultaneously. The full timeline with references is provided in the table below.

All dates at a glance

The full timeline at a glance, from the requirements in effect since August 12, 2026, to the steps following until 2040. For each date, it specifies what changes and to whom it applies, so you can see which requirement you need to address now and which you can plan for.

Two dates are subject to an implementing act. The rule regarding empty space takes effect on January 1, 2030, or three years after the implementing act containing the calculation method, whichever is later. That method will be published by February 12, 2028, at the latest.

Are you a manufacturer?

Under the PPWR, a manufacturer is whoever puts their name or brand on the packaging, even if another party produces or fills it. Those who order custom packaging without branding are also considered manufacturers, as that party determines the design specifications. The regulation does not recognize a separate role for a brand owner.

The reason is stated in the Commission’s guidance document: that party holds the decisive power in the contractual relationship and can therefore determine the characteristics of the packaging. This applies even if another brand is also present on the packaging.

If you sell under your own name as an importer or if you modify the packaging, you are also designated as a manufacturer under Article 21. If you have products manufactured in Asia with your own brand on them, you are both manufacturer and importer simultaneously.

What you should arrange now

Start with your role and the substances. Determine for each type of packaging whether you are the manufacturer, importer, or distributor, and request information from your suppliers regarding the substances contained within. Then, ensure that you can provide the declaration and the technical file within ten days.

1. Determine your role for each type of packaging: manufacturer, importer, or distributor. Often, you may hold multiple roles simultaneously.
2. Request information on the substances contained for each material type and supplier. Article 16 obliges your supplier to provide this information in a language you easily understand.
3. Check whether each piece of packaging bears a unique identification plus your name and postal address.
4. Draw up the declaration of conformity according to Annex VIII and compile the supporting technical file.
5. Ensure that you can provide that file within ten days. That is the deadline that matters.