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PPWR Is Already Law: What's Required From August 2026

Part 1 of 2 — the EU Packaging and Packaging Waste Regulation, explained

Published: August 26, 2026
Author: Siobhan King-Hughes

If your business places packaging on the EU market, the Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40 came into force on 11 February 2025 and its first provisions apply from 12th August 2026.

Further changes are phased in through to 2030 and beyond. Because these requirements affect how packaging is designed and labelled – not only how it’s disposed of — businesses may need to act sooner than the full 2030 deadline suggests.

This is the first of two articles. This one covers what’s already required. The second covers what’s coming next – the key dates through to 2040, and where to go for help building a plan around them.

Four things to know

  • It’s a Regulation, not a Directive. It applies directly and identically in all 27 Member States – replacing the old Directive 94/62/EC. There’s no transposition into national law, and no room for the national variation that the old Packaging and Packaging Waste Directive allowed.
  • It applies to all packaging, of all materials. Sales, grouped, transport and e-commerce packaging are all in scope, across every packaging material – not plastic alone.
  • A compliance file is now required. From 12 August 2026, that means technical documentation and an EU Declaration of Conformity, producible on request by market surveillance authorities.
  • More changes are coming, running up to 2030. Recyclability grades, minimum recycled content, format bans and reuse targets are still to arrive – more on that in Part 2.

Responsibility is assigned by role, not by industry

PPWR doesn’t ask “what sector are you in” – it asks “what do you do to this packaging.” Each role carries its own obligations, and most companies hold more than one at once.

RoleTriggered byCore obligation
Manufacturer (Art. 15)Making packaging, or having it made, under your own brandOwn the conformity assessment, the technical file and the Declaration of Conformity; identification on the pack
Importer (Art. 18)Bringing packaging or packaged goods in from outside the EUVerify the manufacturer has done the above; add your own name and address; hold the Declaration
Supplier (Art. 16)Supplying packaging or materials to a manufacturerGive your customer the information they need to assess conformity
Distributor (Art. 19)Selling on, or making available, within the EUVerify the producer is EPR-registered and the pack is correctly labelled
Producer (Arts. 44–45)Placing packaging on a national market for the first timeRegister in that Member State, pay EPR fees, report tonnages annually
Fulfilment provider (Art. 20)Warehousing or fulfilling orders for othersCheck producer registration and self-certification

What’s new compared to the old Directive

The old Directive set out requirements for packaging. PPWR keeps much of that same substantive ground, but adds a requirement for evidence, and names exactly who is responsible for holding it.

Under the old Directive, until 11 Aug 2026Under PPWR, from 12 Aug 2026
Essential requirements existed; conformity was presumed where harmonised standards were followedThe same ground is covered by Articles 5-12, but conformity must be actively assessed and documented
No EU-level declaration of conformityAn EU Declaration of Conformity is required for every packaging type
No mandatory EU technical fileTechnical documentation is required, retained for 5 or 10 years
Transposed into national law: 27 different variantsOne Regulation, directly applicable, no national variation
Duties framed around Member StatesDuties framed around named roles: manufacturer, importer, distributor, producer
No PFAS limit for food-contact packagingPFAS limits now apply to food-contact packaging
No supply-chain traceability requirementTraceability records required in both directions, held 5 or 10 years
Packaging claims governed by general consumer lawClaims can only be made where they exceed PPWR minimums, and must be evidenced

The immediate change isn’t primarily what packaging has to be. It’s that a business must now be able to prove it, per packaging type, on request.

What became enforceable on 12 August 2026?

  • Producer registration and EPR, per market. – EPR continues through existing national schemes (Repak, in Ireland). EU-wide producer registers aren’t yet operational but will be established.
  • PFAS ban in food-contact packaging. – Limits apply: 25 ppb for any single PFAS substance, 250 ppb for the sum of PFAS, and 50 ppm total including polymeric PFAS
  • Heavy metals cap. Lead, cadmium, mercury and hexavalent chromium combined must not exceed 100 mg/kg
  • The compliance file. Technical documentation and an EU Declaration of Conformity
  • Operator obligations go live. Manufacturer and importer identification on the pack; distributors must verify EPR registration; traceability records are required.
  • Environmental claims are restricted. Claims may only be made where they exceed PPWR minimums, and must be evidenced in the technical file.

Packaging already placed on the market before 12 August 2026 can remain there, and existing stock doesn’t need to be destroyed or relabelled.

Next in this series: what changes between now and 2040 — recyclability grades, recycled content targets, reuse obligations, and a practical three-stage plan for getting ahead of it.

If you have questions, contact us to set up a discussion on how this impacts the packaging that you use within your business.


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