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.
| Role | Triggered by | Core obligation |
| Manufacturer (Art. 15) | Making packaging, or having it made, under your own brand | Own 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 EU | Verify the manufacturer has done the above; add your own name and address; hold the Declaration |
| Supplier (Art. 16) | Supplying packaging or materials to a manufacturer | Give your customer the information they need to assess conformity |
| Distributor (Art. 19) | Selling on, or making available, within the EU | Verify the producer is EPR-registered and the pack is correctly labelled |
| Producer (Arts. 44–45) | Placing packaging on a national market for the first time | Register in that Member State, pay EPR fees, report tonnages annually |
| Fulfilment provider (Art. 20) | Warehousing or fulfilling orders for others | Check 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 2026 | Under PPWR, from 12 Aug 2026 |
| Essential requirements existed; conformity was presumed where harmonised standards were followed | The same ground is covered by Articles 5-12, but conformity must be actively assessed and documented |
| No EU-level declaration of conformity | An EU Declaration of Conformity is required for every packaging type |
| No mandatory EU technical file | Technical documentation is required, retained for 5 or 10 years |
| Transposed into national law: 27 different variants | One Regulation, directly applicable, no national variation |
| Duties framed around Member States | Duties framed around named roles: manufacturer, importer, distributor, producer |
| No PFAS limit for food-contact packaging | PFAS limits now apply to food-contact packaging |
| No supply-chain traceability requirement | Traceability records required in both directions, held 5 or 10 years |
| Packaging claims governed by general consumer law | Claims 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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