PPWR Starts on 12 August 2026: Is Your Packaging Ready?

Understanding the New EU Packaging Regulation

For years, packaging compliance in the European Union has largely been driven by national Extended Producer Responsibility (EPR) schemes. Companies selling products into Europe have become familiar with registrations such as LUCID in Germany, Citeo in France, and Ecoembes in Spain.

On 12 August 2026, however, the regulatory landscape changes significantly.

The Packaging and Packaging Waste Regulation (PPWR) becomes generally applicable across the European Union. Unlike the previous Packaging Directive, the PPWR is a directly applicable EU Regulation, creating harmonised packaging requirements for every Member State. Its objective is not simply to improve recycling rates, but to fundamentally redesign how packaging is designed, manufactured, labelled, reused, recycled, and managed throughout its entire lifecycle.

The European Commission explains that the PPWR covers all packaging placed on the EU market, regardless of the material used or whether it is manufactured inside or outside the European Union. (European Commission: Packaging Waste)

If your company manufactures products, imports goods into the EU, sells through Amazon or other online marketplaces, or exports products from outside the European Union, the PPWR is likely to affect your business.

This article explains:

• what the PPWR is,
• why 12 August 2026 is an important date,
• who must comply,
• how it differs from existing EPR obligations, and
• what businesses should begin preparing today.

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What is the PPWR?

The Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40) replaces the former Packaging and Packaging Waste Directive 94/62/EC, which had governed packaging legislation for more than thirty years.

The previous Directive established common objectives while allowing each Member State to implement its own national legislation. As a result, businesses operating across Europe often had to navigate different rules relating to:

• packaging design requirements,
• labelling,
• producer obligations,
• reporting,
• enforcement, and
• waste management systems.

The PPWR fundamentally changes this approach.

Because it is an EU Regulation, its provisions apply directly across all Member States without requiring national transposition into domestic law. This creates a much more harmonised legal framework for packaging throughout the European Union while reducing barriers to the internal market.

According to the European Commission, the PPWR is one of the central legislative measures supporting the European Green Deal and the Circular Economy Action Plan. It aims to reduce packaging waste, improve recyclability, increase resource efficiency, and encourage a transition towards a circular economy.

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Why was a new Regulation necessary?

Packaging waste has become one of Europe's fastest-growing waste streams.

According to data published by the European Commission:

• Packaging accounts for approximately 40% of plastics used in the EU.
• It represents roughly 50% of paper consumption.
• In 2022, every EU citizen generated approximately 186.5 kg of packaging waste.

Without legislative action, packaging waste would continue to increase significantly over the coming decades. 

The PPWR therefore introduces measures designed to:

• prevent unnecessary packaging,
• reduce packaging waste generation,
• improve recyclability,
• increase reuse and refill systems,
• reduce the use of virgin raw materials,
• strengthen the circular economy, and
• harmonise packaging requirements throughout the EU.

Unlike the previous Directive, these objectives are supported by detailed legal obligations that directly affect packaging design, manufacturing, documentation, and market placement.

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Why is 12 August 2026 important?

One of the most common misconceptions is that the PPWR is "new" simply because businesses are only now hearing about it.

In reality, the Regulation has already entered into force. What changes on 12 August 2026 is that most of its provisions become generally applicable. 

PPWR Timeline

Date	Milestone
11 February 2025	Regulation (EU) 2025/40 entered into force.
12 August 2026	Most provisions become generally applicable.
2028 to 2040	Additional phased obligations gradually apply.

 

The EU deliberately introduced an 18-month transition period to allow manufacturers, importers, brand owners, retailers, and packaging suppliers sufficient time to review existing packaging, redesign products where necessary, update supplier agreements, and prepare internal compliance processes.

For many businesses, this transition period is rapidly coming to an end.

In the next part of this guide, we'll look at who the PPWR applies to, what qualifies as packaging under the Regulation, and why many companies mistakenly believe that EPR registration alone is sufficient for compliance.

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Does the PPWR apply to my company?

For most businesses that place products on the European market, the answer is yes.

The PPWR has an intentionally broad scope. Under Article 2, it applies to all packaging placed on the EU market, regardless of:

• the material used,
• whether the packaging is empty or filled,
• the country where it was manufactured, or
• the type of product contained inside.

This means the Regulation applies equally to packaging manufactured inside the European Union and packaging imported from third countries.

(Regulation (EU) 2025/40, Article 2)

The PPWR affects businesses including:

• EU manufacturers
• Non-EU manufacturers exporting into Europe
• Importers
• Private-label brands
• Brand owners
• Distributors
• E-commerce businesses
• Amazon, Shopify and marketplace sellers
• Packaging manufacturers and suppliers

The European Commission has also confirmed that the Regulation applies equally to European and non-European companies placing packaged products on the EU market.

(European Commission Answer to Parliamentary Question E-003267/2025)

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What counts as "packaging"?

Many businesses are surprised by how broadly the PPWR defines packaging.

Article 3 defines packaging as any item intended for the containment, protection, handling, delivery or presentation of products throughout the supply chain.

(Regulation (EU) 2025/40, Article 3)

Primary Packaging

Primary packaging is the packaging that comes into direct contact with the product.

Examples include:

• Cosmetic bottles
• Toy boxes
• Food containers
• Electronic retail boxes
• Glass jars

Secondary Packaging

Secondary packaging groups several products together for retail sale.

Examples include:

• Multipacks
• Display cartons
• Promotional bundles

Transport Packaging

Transport packaging protects products during storage and shipment.

Examples include:

• Shipping cartons
• Pallet wrap
• Protective inserts
• Stretch film
• Cushioning materials

E-commerce Packaging

The PPWR pays particular attention to packaging used in online sales.

As e-commerce continues to grow, oversized shipping cartons and excessive void fill have become a significant source of unnecessary waste across Europe.

The Regulation therefore introduces specific requirements for e-commerce packaging, including future rules aimed at reducing empty space and unnecessary packaging material.

Many of these provisions apply in later implementation phases, but businesses should already begin reviewing their fulfilment packaging strategies.

(European Circular Economy Stakeholder Platform)

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The PPWR is not just about recycling

One of the biggest misconceptions is that the PPWR is simply another recycling regulation.

It is much broader than that.

The Regulation governs the entire lifecycle of packaging, from its initial design through manufacturing, placing on the market, use, collection and eventual recycling or disposal.

Among other things, the PPWR introduces rules covering:

• Packaging design
• Material composition
• Hazardous substances
• Packaging minimisation
• Recyclability
• Reuse systems
• Refill systems
• Technical documentation
• Declarations of Conformity
• Labelling
• Waste prevention
• Producer obligations

For many manufacturers, packaging will become another regulated product component requiring documented conformity, similar to CE-marked products or products subject to the General Product Safety Regulation (GPSR).

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PPWR versus EPR: They are not the same

This is one of the most common misunderstandings we encounter.

"We already have EPR registration numbers, so we're PPWR compliant."

Unfortunately, that is not correct.

Although the two systems are closely related, they serve very different purposes.

PPWR	EPR
EU Regulation	National producer responsibility schemes
Regulates packaging design and sustainability requirements	Finances collection, sorting and recycling systems
Harmonised across the EU	Different rules in each Member State
Applies before packaging is placed on the market	Applies once packaging is placed on the market
Focuses on product compliance	Focuses on waste management financing

The PPWR does not replace national Extended Producer Responsibility schemes.

Instead, it establishes harmonised technical requirements for packaging itself, while EPR continues to govern producer registration, reporting and financial contributions within each Member State.

(European Commission clarification)

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Why businesses should prepare now

Although many technical requirements will be phased in over the coming years, companies should not wait until enforcement begins before reviewing their packaging.

Packaging development cycles are often lengthy. Many businesses:

• order packaging months in advance,
• print large inventories,
• approve artwork long before production,
• source packaging globally, and
• operate under long-term supplier contracts.

Changing packaging after production has started can become expensive and disruptive.

The European Commission deliberately introduced an 18-month transition period to allow businesses sufficient time to redesign packaging, update documentation, review supplier specifications and establish compliance procedures before the Regulation becomes generally applicable.

Companies that delay preparation may find themselves replacing packaging inventories, redesigning labels or renegotiating supplier agreements under significant commercial pressure.

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Sustainability Requirements for Packaging Design

In Part 1, we looked at the scope of the Packaging and Packaging Waste Regulation (PPWR), why it replaces the previous Packaging Directive, and why 12 August 2026 is such an important milestone for manufacturers and importers.

In this part, we'll examine the first set of technical requirements that businesses need to understand. Unlike previous EU packaging legislation, the PPWR does not simply regulate waste management. It establishes legally binding design requirements for packaging before it can be placed on the European market.

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Packaging Minimisation

One of the core principles of the PPWR is that packaging should contain only the amount of material that is genuinely necessary to perform its intended function.

Article 10 requires manufacturers to minimise the weight and volume of packaging while ensuring that it continues to adequately protect the product throughout storage, transport, sale and normal use.

This means companies can no longer justify oversized packaging simply for marketing purposes or visual impact.

(Regulation (EU) 2025/40)

What does "minimum necessary" actually mean?

The Regulation recognises that packaging performs many important functions besides containing a product. These include:

• protecting products during transport,
• preventing contamination,
• preserving shelf life,
• ensuring safe handling,
• providing legally required information,
• preventing counterfeiting and tampering, and
• allowing efficient manufacturing and logistics.

Manufacturers must therefore balance sustainability with functionality.

Annex IV establishes an assessment methodology that requires businesses to evaluate packaging against specific performance criteria before determining the minimum acceptable weight and volume.

Examples of unnecessary packaging

• Large decorative boxes containing very small products
• Excessive plastic inserts used only for presentation
• Multiple unnecessary packaging layers
• Overly thick packaging without additional protective value
• Luxury packaging that substantially exceeds functional requirements

Conversely, additional material may still be justified where necessary for product protection, food safety, legal requirements or transport performance.

The Regulation therefore does not prohibit premium packaging. Instead, it requires manufacturers to be able to justify why additional material is necessary.

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Packaging Design Must Be Evidence-Based

The PPWR introduces an important change in regulatory philosophy.

Rather than assuming packaging is appropriate because it has always been used that way, manufacturers must now be able to demonstrate that their design choices are justified.

The assessment methodology in Annex IV considers factors including:

• product protection,
• manufacturing processes,
• transport and logistics,
• consumer safety,
• legal requirements,
• recyclability,
• reuse, and
• the use of recycled content.

Existing harmonised standards such as EN 13428 may continue to support packaging minimisation assessments until updated standards are published.

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Requirements for Substances in Packaging

The PPWR also strengthens chemical safety requirements.

Article 5 requires packaging to be manufactured so that the presence of substances of concern is minimised throughout the packaging's lifecycle.

This obligation extends beyond the finished packaging itself. Manufacturers must also consider emissions, recycling processes and secondary raw materials generated after disposal.

(Article 5, Regulation (EU) 2025/40)

Heavy metal restrictions remain

The existing limit for the combined concentration of:

• Lead
• Cadmium
• Mercury
• Hexavalent Chromium

continues to apply.

Together, these substances may not exceed 100 mg/kg within packaging or packaging components.

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PFAS Restrictions for Food Contact Packaging

One of the most widely discussed provisions of the PPWR concerns per- and polyfluoroalkyl substances (PFAS), often referred to as "forever chemicals."

These substances have been widely used because of their resistance to water, grease and heat.

However, their extreme persistence in the environment has raised increasing concerns across Europe.

Beginning on 12 August 2026, food-contact packaging may not be placed on the EU market if PFAS exceed the concentration limits established by Article 5.

The Regulation establishes thresholds including:

• 25 ppb for individual PFAS (targeted analysis)
• 250 ppb for the sum of targeted PFAS
• 50 ppm for total organic fluorine (where applicable)

These restrictions primarily affect manufacturers of:

• food packaging,
• fast-food containers,
• paper food wraps,
• grease-resistant packaging,
• bakery packaging, and
• take-away food containers.

Companies sourcing coated paper or specialty barrier materials should already be requesting declarations from suppliers confirming compliance.

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Recyclability Becomes a Legal Requirement

Perhaps the biggest long-term change introduced by the PPWR is that packaging must be designed for recycling.

Historically, many types of packaging could technically be recycled but rarely were, because they contained incompatible materials, complex laminates or components that could not be separated economically.

The PPWR aims to change this.

According to the European Commission, all packaging placed on the EU market should ultimately be recyclable in an economically viable manner.

(European Commission PPWR Overview)

Design for Recycling

Packaging must be designed so that, once it becomes waste, it can:

• be separately collected,
• be effectively sorted,
• enter established recycling streams,
• produce secondary raw materials of sufficient quality, and
• avoid contaminating other recyclable materials.

From 2030 onwards, recyclability will be assessed using harmonised EU "Design for Recycling" criteria.

From 2035, packaging must additionally demonstrate that it is recycled at scale across the European Union.

Packaging will ultimately receive recyclability performance grades (A, B or C). Packaging performing below Grade C will generally no longer be permitted on the EU market.

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Practical Design Implications

Although many grading requirements apply after 2030, manufacturers should already begin reviewing their packaging designs.

Common improvements include:

• moving from multi-material laminates to mono-material packaging,
• reducing unnecessary coatings,
• using removable labels where appropriate,
• avoiding incompatible adhesives,
• improving material identification, and
• working closely with packaging suppliers during product development.

Packaging redesign often requires long lead times. Businesses that delay these discussions may face costly redesigns as future compliance deadlines approach.

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Technical Documentation, Declaration of Conformity and Manufacturer Obligations

Designing compliant packaging is only one part of the Packaging and Packaging Waste Regulation (PPWR). Manufacturers must also be able to demonstrate compliance through documented evidence.

For the first time, the PPWR introduces a harmonised EU conformity assessment procedure, mandatory technical documentation and an EU Declaration of Conformity for packaging. These requirements resemble the conformity assessment process already familiar from CE-marked products such as machinery, toys and electrical equipment.

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Reusable Packaging

Although much public attention has focused on recyclability, the PPWR places even greater emphasis on reuse.

The Regulation establishes detailed requirements defining when packaging may be considered reusable. Simply describing packaging as "reusable" for marketing purposes is no longer sufficient.

To qualify as reusable, packaging must be designed to complete multiple rotations while maintaining its functionality, safety and integrity. It must also be suitable for collection, reuse and reconditioning systems.

(Regulation (EU) 2025/40, Article 11)

Reusable packaging must be designed to:

• be emptied and refilled multiple times,
• remain safe throughout repeated use,
• maintain product protection during repeated transport,
• allow cleaning where necessary,
• permit repair or refurbishment where appropriate, and
• ultimately be recyclable when it reaches the end of its useful life.

Future delegated acts will establish more detailed technical criteria and performance requirements for reusable packaging systems.

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Compostable Packaging

The PPWR also introduces specific rules for compostable packaging.

However, contrary to popular belief, the Regulation does not require all packaging to become compostable.

Instead, only certain categories of packaging will be required to be compostable under future implementing measures. These include specific applications where compostability provides a clear environmental benefit.

Examples include certain tea bags, coffee pods, sticky labels attached to fruit and vegetables, and other packaging categories identified by the European Commission.

All food-contact packaging must also continue to comply with the requirements of the EU Food Contact Materials Regulation (EC) No 1935/2004.

(Recitals 58 and 59, Regulation (EU) 2025/40)

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Technical Documentation

Perhaps the most significant compliance obligation introduced by the PPWR is the requirement to prepare technical documentation for each packaging type.

Annex VII establishes the minimum content of the technical file.

The documentation must allow market surveillance authorities to assess whether the packaging complies with all applicable provisions of Articles 5 to 12.

(Annex VII, Regulation (EU) 2025/40)

The technical documentation should include, where applicable:

• General description of the packaging
• Intended use
• Design drawings
• Manufacturing specifications
• Material composition
• Assessment of applicable PPWR requirements
• Risk analysis relating to non-conformity
• Applied harmonised standards
• Common specifications
• Alternative technical specifications where standards are not used
• Packaging minimisation assessment
• Recyclability assessment
• Reuse assessment (where applicable)
• Test reports
• Supporting calculations
• Supplier documentation

This represents a substantial increase in documentation compared with previous packaging legislation.

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Internal Production Control (Module A)

Unlike many CE regulations that require notified bodies for higher-risk products, the PPWR primarily uses Module A (Internal Production Control) as its conformity assessment procedure.

Under Module A, the manufacturer is responsible for assessing compliance and preparing all required documentation.

This means the manufacturer must:

• assess conformity with Articles 5 to 12,
• prepare technical documentation,
• implement manufacturing controls, and
• issue the EU Declaration of Conformity.

The manufacturer assumes full legal responsibility for these activities.

(Annex VII, Module A) 

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EU Declaration of Conformity

Once compliance has been demonstrated, the manufacturer must prepare an EU Declaration of Conformity (DoC).

This declaration confirms that the packaging satisfies the applicable requirements of Regulation (EU) 2025/40.

The declaration must follow the model structure contained in Annex VIII and remain up to date whenever relevant changes occur.

(Article 39 and Annex VIII) 

The Declaration of Conformity should identify:

• the packaging type,
• the manufacturer,
• the applicable Regulation,
• the conformity assessment procedure used,
• the applicable harmonised standards (where relevant),
• the responsible signatory, and
• the date of issue.

Where packaging is also subject to other EU legislation requiring a Declaration of Conformity, a combined declaration may be prepared where appropriate.

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Document Retention Periods

The PPWR also specifies how long manufacturers must retain compliance documentation.

Packaging Type	Retention Period
Single-use packaging	5 years after being placed on the market
Reusable packaging	10 years after being placed on the market

These retention periods apply to both the technical documentation and the EU Declaration of Conformity.

Authorised Representatives may retain these documents on behalf of manufacturers where this responsibility is included within their written mandate.

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Manufacturer Obligations

Article 15 establishes the general obligations of manufacturers.

Before placing packaging on the EU market, manufacturers must:

• ensure packaging complies with Articles 5 to 12,
• carry out the conformity assessment procedure,
• prepare technical documentation,
• issue the EU Declaration of Conformity,
• maintain production controls, and
• retain documentation for the required period.

If non-compliant packaging is discovered after being placed on the market, manufacturers must immediately take appropriate corrective measures, including withdrawal or recall where necessary.

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Importer Responsibilities

Importers also have independent legal obligations under the PPWR.

Before placing packaging originating from outside the European Union on the market, importers must verify that the manufacturer has fulfilled the applicable conformity assessment requirements.

Importers must also ensure that:

• technical documentation can be provided upon request,
• a Declaration of Conformity exists,
• storage and transport conditions do not compromise compliance, and
• appropriate corrective action is taken where non-compliance is identified.

Importers cannot assume that compliance rests solely with overseas suppliers.

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Practical Compliance Roadmap

Although some future PPWR obligations will only apply from 2030 onwards, businesses should already begin preparing.

Recommended next steps include:

1. Create an inventory of all packaging types.
2. Identify packaging suppliers for each format.
3. Request detailed material specifications.
4. Review packaging against minimisation requirements.
5. Assess recyclability.
6. Review PFAS and substance declarations where applicable.
7. Prepare technical documentation.
8. Draft EU Declarations of Conformity.
9. Update supplier contracts to require ongoing compliance documentation.
10. Establish an internal document retention process.

Businesses that complete these steps before enforcement begins will generally be much better prepared for future market surveillance activities.

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Future Compliance Milestones, Labelling Requirements and Enforcement

Although the Packaging and Packaging Waste Regulation (PPWR) becomes generally applicable on 12 August 2026, this is only the beginning of a much broader transformation. Many of the Regulation's most significant requirements will be introduced gradually over the next fifteen years through delegated acts, implementing acts and phased compliance deadlines.

Businesses that understand this roadmap today will be better positioned to make long-term investments in packaging design, supplier management and compliance systems.

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The PPWR Timeline Through 2040

Unlike many EU Regulations that become fully applicable on a single date, the PPWR introduces a staged implementation schedule. This gives industry time to adapt while allowing the European Commission to develop detailed technical rules through delegated and implementing acts.

• 11 February 2025 – Regulation (EU) 2025/40 entered into force.
• 12 August 2026 – Most provisions of the PPWR become applicable across the European Union.
• 12 February 2027 – EU Member States must establish national penalties for non-compliance. The European Commission must also adopt delegated acts defining the minimum number of rotations for reusable packaging.
• 12 August 2028 – Harmonised EU packaging labels generally begin to apply, subject to the adoption of the necessary implementing acts.
• 12 February 2029 – Reusable packaging must include reuse information and digital data carriers (such as QR codes), where required.
• 1 January 2030 – Restrictions on certain packaging formats take effect, including requirements relating to empty space and recyclability. Additional implementing acts and recyclability assessment methodologies also become applicable.
• 2035 – Packaging must generally be recyclable at scale across the European Union.
• 2040 – Additional recycled content targets and long-term sustainability requirements become applicable for certain packaging categories.

The exact implementation dates for some obligations depend on when the European Commission adopts the relevant delegated or implementing acts.

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Harmonised Packaging Labelling

One of the most visible changes introduced by the PPWR is the creation of harmonised packaging labels throughout the European Union.

Today, consumers encounter a wide variety of national recycling symbols that often differ between Member States. This creates confusion regarding proper waste sorting.

The PPWR seeks to replace this fragmented approach with a harmonised EU-wide labelling system.

From 12 August 2028, or 24 months after the relevant implementing acts enter into force (whichever is later), most packaging placed on the EU market must display a harmonised label identifying its material composition.

These labels will use standardised pictograms intended to improve consumer understanding and facilitate separate collection.

The labels are expected to communicate:

• material composition,
• sorting instructions,
• compostability (where applicable),
• recycled content (where applicable), and
• deposit-return information where relevant.

The exact graphical design will be established by implementing acts adopted by the European Commission.

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Digital Data Carriers

The PPWR recognises that modern packaging can provide significantly more information than can reasonably fit on a physical label.

For this reason, the Regulation permits and, in some cases, requires the use of standardised digital data carriers, such as QR codes.

These digital tools may provide additional compliance information including:

• material composition,
• reuse instructions,
• collection points,
• sorting guidance,
• recycled content information, and
• other sustainability-related information.

Reusable packaging placed on the market from February 2029 will generally be required to include a digital data carrier providing information on reuse systems and, where feasible, the number of rotations completed by the packaging.

The Regulation also encourages the use of digital marking technologies to identify substances of concern within packaging materials in future implementation phases.

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Misleading Environmental Claims Are Prohibited

The PPWR is not only a technical regulation. It also seeks to improve transparency for consumers.

Economic operators may not display labels, symbols or environmental claims that could mislead consumers regarding the sustainability or recyclability of packaging where harmonised labelling requirements exist.

This complements other EU legislation aimed at reducing greenwashing, including the Empowering Consumers for the Green Transition Directive.

Manufacturers should therefore carefully review existing packaging claims such as:

• "eco-friendly",
• "green packaging",
• "100% sustainable",
• "fully recyclable", and
• "environmentally safe".

Such claims should always be supported by objective evidence and must not conflict with harmonised EU labelling requirements.

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Market Surveillance and Enforcement

Like other EU product legislation, the PPWR relies on national market surveillance authorities for enforcement.

Authorities may request compliance documentation from manufacturers, importers and other economic operators.

This may include:

• technical documentation,
• Declarations of Conformity,
• test reports,
• supplier documentation,
• material specifications, and
• records demonstrating compliance with the Regulation.

Where authorities identify non-compliance, they may require corrective measures, restrict market access, order product withdrawals or require recalls where appropriate.

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National Penalties

Although the PPWR is directly applicable throughout the European Union, penalties remain the responsibility of individual Member States.

By 12 February 2027, every Member State must establish effective, proportionate and dissuasive penalties for infringements of the Regulation.

The Regulation specifically provides that administrative fines may be imposed where national legal systems permit.

Businesses should therefore expect enforcement approaches to differ between Member States while remaining based on the same underlying Regulation.

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What Should Businesses Do Now?

Even if many future obligations only become mandatory after 2028 or 2030, manufacturers should begin preparing immediately.

Recommended actions include:

1. Review all existing packaging designs.
2. Identify packaging formats that may require redesign.
3. Engage with packaging suppliers regarding recyclability and material composition.
4. Begin collecting supplier declarations and technical specifications.
5. Prepare technical documentation for each packaging type.
6. Develop EU Declarations of Conformity.
7. Monitor future delegated and implementing acts published by the European Commission.
8. Train internal product development and purchasing teams.
9. Integrate PPWR compliance into new product development processes.
10. Review existing environmental marketing claims for potential greenwashing risks.

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Final Thoughts

The Packaging and Packaging Waste Regulation represents the most significant reform of EU packaging legislation in more than three decades.

Rather than focusing solely on waste management, the PPWR regulates the complete lifecycle of packaging, from design and material selection through conformity assessment, documentation, labelling and end-of-life management.

For manufacturers, importers and online sellers, packaging compliance is no longer simply an environmental issue. It has become a core product compliance obligation that should be integrated into product development, supplier management and quality systems.

Companies that begin preparing now will generally face a smoother transition than those waiting until enforcement actions begin.

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Common Compliance Mistakes

Based on our experience supporting manufacturers worldwide, these are some of the most common issues businesses encounter when preparing for the PPWR.

1. Assuming EPR Registration Equals PPWR Compliance

Registering with national EPR schemes does not demonstrate that packaging itself complies with the Regulation.

The PPWR introduces entirely separate technical requirements.

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2. Not Knowing What Materials Are Used

Many businesses purchase finished packaging without obtaining detailed material specifications from suppliers.

Under the PPWR, manufacturers should understand:

• material composition,
• coatings,
• inks,
• adhesives,
• barrier layers, and
• any substances of concern.

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3. Relying Solely on Supplier Statements

Supplier declarations are valuable but may not, on their own, demonstrate compliance.

Manufacturers remain responsible for carrying out the conformity assessment procedure and preparing technical documentation.

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4. Waiting Until Enforcement Begins

Packaging redesign projects often require:

• new tooling,
• supplier qualification,
• artwork revisions,
• testing,
• inventory planning, and
• customer approval.

These activities frequently take many months to complete.

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5. Ignoring Future Requirements

Although some obligations only become applicable after 2028 or 2030, businesses developing new packaging today should already consider future recyclability, labelling and reuse requirements.

Redesigning packaging twice is considerably more expensive than planning for future requirements now.

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PPWR Compliance Checklist

The following checklist provides a practical starting point for businesses preparing for the Regulation.

Task	Status
Create an inventory of all packaging formats	☐
Identify packaging suppliers	☐
Obtain detailed material specifications	☐
Review packaging against minimisation requirements	☐
Assess recyclability	☐
Review substances of concern	☐
Request PFAS declarations where applicable	☐
Prepare technical documentation	☐
Prepare EU Declarations of Conformity	☐
Implement document retention procedures	☐
Monitor future delegated and implementing acts	☐
Train procurement and product development teams	☐

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How EaseCert Can Help

Preparing for the PPWR requires much more than updating packaging artwork. Businesses must understand evolving legal requirements, assess packaging designs, prepare technical documentation and establish robust compliance procedures.

EaseCert supports manufacturers, importers and online sellers by helping them:

• review packaging against PPWR requirements,
• prepare technical documentation,
• draft EU Declarations of Conformity,
• evaluate supplier documentation,
• identify compliance gaps, and
• develop practical implementation roadmaps.

Whether you manufacture products in Europe or export to the EU from abroad, early preparation can significantly reduce future compliance risks and minimise costly redesigns.

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Final Thoughts

The PPWR represents a fundamental shift in how packaging is regulated within the European Union.

For the first time, packaging becomes subject to a harmonised conformity assessment framework supported by technical documentation, declarations of conformity and lifecycle sustainability requirements.

Although implementation will continue through 2040, businesses should not view the PPWR as a future issue. The decisions made today regarding packaging design, supplier selection and documentation will determine how smoothly companies adapt to the new regulatory landscape.

Manufacturers that begin preparing now will not only reduce compliance risks but will also be better positioned to meet increasing customer expectations for sustainable packaging throughout the European market.

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Official References

• Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on Packaging and Packaging Waste (PPWR)
• European Commission, Packaging and Packaging Waste
• European Commission Notice (C/2026/3084): Guidance Document for Regulation (EU) 2025/40 on Packaging and Packaging Waste
• European Commission, FAQ on the Packaging and Packaging Waste Regulation (PPWR)
• Publications Office of the European Union, Packaging and Packaging Waste Regulation (PPWR): Frequently Asked Questions
• European Commission Communication Approving the Guidance Document for Regulation (EU) 2025/40
• European Chemicals Agency (ECHA), Packaging and Packaging Waste Regulation (PPWR)
• European Commission, Circular Economy Action Plan
• Directive (EU) 2024/825 on Empowering Consumers for the Green Transition through Better Protection against Unfair Practices and Better Information
• Regulation (EU) 2019/1020 on Market Surveillance and Compliance of Products
• Regulation (EC) No 1935/2004 on Materials and Articles Intended to Come into Contact with Food
• Directive 94/62/EC on Packaging and Packaging Waste (Repealed by Regulation (EU) 2025/40)

 

Disclaimer: This article is intended for general informational purposes only and does not constitute legal advice. While every effort has been made to ensure accuracy, businesses should review the applicable legislation and seek professional advice for their specific products and packaging. The PPWR will continue to be supplemented by delegated acts, implementing acts and official guidance published by the European Commission.