Analyses and Case Studies
PPWR: The New EU Packaging Regulation Already Applies — What Should Have Been Ready
While everyone was watching CBAM and the deforestation regulation, a piece of legislation that affects far more companies than both combined quietly became applicable on 12 August 2026. PPWR makes no distinction between a food producer, a machine builder and an online shop — if you place anything packaged on the EU market, it applies to you.
And since the date has passed, the question is no longer “how do we prepare” but “what is missing from our file right now”.
Key Takeaways
- Regulation (EU) 2025/40 (PPWR) has applied since 12 August 2026 and replaces Directive 94/62/EC. As a regulation it applies directly, with no transposition into national law.
- The scope is every packaging unit placed on the EU market — primary, grouped and transport — regardless of material and of whether the company makes packaging or merely packs its own output.
- Obligations that apply from day one: restrictions on PFAS and heavy metals, technical documentation structured to Annex VII, and the EU declaration of conformity.
- The long-horizon requirements — detailed design-for-recycling criteria, minimum recycled content and reuse targets — mostly start in 2030 and depend on delegated acts.
- Packaging is now a “product” in the legal sense. It has a technical file and a declaration, exactly like a machine or a medical device.
- The most common mistake: assuming that buying packaging from a supplier moves the obligation to that supplier. Whoever places the packed product on the market carries their own responsibility.
What PPWR is
PPWR is Regulation (EU) 2025/40 on packaging and packaging waste, which entered into force on 11 February 2025 and applies from 12 August 2026. It repeals Directive 94/62/EC and ends a thirty-year period in which every Member State applied the rules in its own way.
The change of instrument is the heart of the reform. A directive set an objective and left each country to transpose it — the result was 27 different regimes, different fees and different definitions of “recyclable”. A regulation applies directly and identically everywhere. For exporters that is good news: one regime instead of twenty-seven.
A point on terminology. “Packaging” under the Regulation is not only the box on the shelf. It covers primary packaging (in contact with the product), grouped packaging (combining several units) and transport packaging (cartons, stretch film, pallet wrap). A company that produces nothing packaged, but ships on pallets with stretch film, still has packaging within the meaning of the Regulation.
Who carries the obligation
| Role | Who it covers | Core obligation |
|---|---|---|
| Packaging manufacturer | Companies producing packaging materials and articles | Conformity of the packaging itself, technical file, declaration |
| Producer of packed goods | Anyone who packs and places a product on the market under their own brand | Responsible for the packaging of their product, whoever made it |
| Importer | Imports packaging or packed products from third countries | Verifies the supplier met the requirements; retains the documentation |
| Distributor | Makes available without altering the product | Due care — does not supply a product known to be non-compliant |
The second row is the one that surprises people. A company that buys ready-made packaging from a local supplier and packs its own production in it is a producer under the Regulation for that packaging. The supplier’s declaration is important evidence, but it does not transfer responsibility.
What applies right now
- Restrictions on hazardous substances. The Regulation restricts PFAS — the “forever chemicals” — in food-contact packaging and retains the thresholds for lead, cadmium, mercury and hexavalent chromium. This requires composition data from suppliers, not assumption.
- Technical documentation. Each packaging unit needs a file structured to Annex VII demonstrating conformity with the applicable requirements. It is not submitted anywhere, but it must be producible on inspection.
- EU declaration of conformity. The declaration accompanies the packaging and binds whoever signs it. In form it is the same declaration as under any other EU product legislation.
If you do not have these three things today, you are non-compliant — not “in preparation”. The good news is that for most companies the work is collecting information from suppliers, not changing the product. Start with a letter to every packaging supplier requesting a declaration and composition data.
What is coming and when
| Period | What takes effect |
|---|---|
| 11 February 2025 | The Regulation enters into force |
| 12 August 2026 | General application — substance restrictions, technical file, declaration of conformity |
| 2028–2029 | Delegated acts with the detailed design-for-recycling and labelling criteria |
| 1 January 2030 | Detailed recyclability requirements, minimum recycled content, reuse targets, bans on certain formats |
| 2040 | A second, higher recycled-content threshold |
The most quoted future threshold is 30 % recycled content for single-use plastic beverage bottles from 2030, rising towards roughly 65 % by 2040. The exact percentages per category, however, are set in delegated acts and depend on the availability of recycled material.
How to read the post-2026 dates. Publications on PPWR contain contradictory statements about recyclability — some place it in 2026, others in 2030. The reason is that the general principle that packaging must be designed for recycling sits in the main text, while the measurable criteria against which it is judged arrive with the delegated acts. For concrete decisions, rely on Articles 6 and 7 of the Regulation and the current delegated acts rather than on summaries.
What changes in practice
Packaging becomes subject to a product file
Until now packaging was a cost and a marketing element. It is now a product with documentation — the same logic as a machine under Regulation (EU) 2023/1230. That means version control: changing supplier or film thickness requires updating the file.
Over-packaging becomes measurable
The Regulation sets limits on empty space in grouped and transport packaging and requires packaging to be reduced to the minimum volume and weight necessary for functionality and safety. A box in which the product occupies a third of the volume is no longer merely uneconomic — it is potentially non-compliant.
Labelling is harmonised
Harmonised symbols for composition and separate collection remove national differences. For companies exporting to several countries, that means one label design instead of several.
How it connects to an ISO 14001 system
An ISO 14001 certificate does not demonstrate PPWR compliance — the Regulation does not recognise certificates. What an environmental management system gives you is the mechanism by which compliance is maintained rather than achieved once:
- A register of applicable requirements — PPWR and its delegated acts go in it and are reviewed periodically.
- Evaluation of compliance (clause 9.1.2) — a planned check that declarations and files are current.
- Change control — switching packaging goes through a process, not an email.
- Supplier management — composition and declaration requirements go into contracts. How that works in practice is covered in our article on supplier audits.
- Internal audit — the gap is found by you, not by the market surveillance authority.
Six steps if you have not started
- List every packaging unit. Primary, grouped and transport, per article. Most companies find the number is in the tens, not the hundreds.
- Request declarations and composition data from every packaging supplier, with a specific deadline.
- Compile the technical file to the Annex VII structure for each packaging unit.
- Sign the EU declarations of conformity for the packaging for which you are the producer under the Regulation.
- Review over-packaging. Where empty space is significant, the change also delivers a direct saving.
- Put PPWR into your system. Into the legal register, the internal audit plan and the change control procedure.
No technical file for your packaging?
We review the scope, prepare the Annex VII files and declarations, and embed the control in your ISO 14001 system — so the next packaging change does not start from scratch.
Conclusion
PPWR is one of those regulations nobody notices until the first inspection or the first customer asking for a declaration. The technical work is moderate — most companies manage in weeks. The hard part is organisational: packaging has to stop being a purchasing decision and become a decision with documentation.
If 12 August 2026 passed you by, that is not cause for panic but for one afternoon’s review: how many packaging units you use, what declarations you hold for them, and who signed those. The answers to those three questions show exactly how much work is left.
Frequently Asked Questions
What is PPWR and when does it apply?
PPWR is Regulation (EU) 2025/40 on packaging and packaging waste. It entered into force on 11 February 2025 and applies from 12 August 2026, repealing Directive 94/62/EC. Because it is a regulation rather than a directive, it applies directly in all Member States without transposition into national law.
Who does PPWR apply to?
PPWR applies to every economic operator placing packaging or packed products on the EU market — packaging manufacturers, producers of packed goods, importers and distributors. The scope covers primary, grouped and transport packaging, regardless of material.
What must be in place right now?
Since 12 August 2026 the restrictions on hazardous substances, including PFAS and heavy metals, the obligation to hold technical documentation structured to Annex VII, and the EU declaration of conformity for each packaging unit all apply. These requirements do not depend on delegated acts and are in force immediately.
Am I responsible if I buy ready-made packaging from a supplier?
Yes. A company that packs its product and places it on the market under its own brand carries its own responsibility for the conformity of that packaging. The packaging supplier’s declaration is important evidence and part of the file, but it does not transfer responsibility to them.
When do the recycled content requirements start?
The main minimum recycled content thresholds apply from 1 January 2030, with a second, higher threshold towards 2040. The most frequently quoted figure is 30 percent recycled material for single-use plastic beverage bottles. The exact percentages per category are set through delegated acts.
Does ISO 14001 replace the PPWR requirements?
No. PPWR is product legislation and does not accept certificates as evidence of conformity. ISO 14001 does, however, provide the mechanism through which compliance is maintained — a register of applicable requirements, evaluation of compliance, change and supplier control, and internal audit.
Do I need to redesign my packaging now?
In most cases not immediately. The requirements in force from 2026 concern composition and documentation rather than redesign. The design-for-recycling criteria and the restrictions on certain formats mainly apply from 2030, so design changes are best planned into the next scheduled redesign.