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The PPWR — Regulation (EU) 2025/40 on packaging and packaging waste — replaces the old Packaging Directive 94/62/EC and, for the first time, sets one directly applicable rulebook for packaging across the entire EU. It entered into force on 11 February 2025, but the biggest mistake companies make is treating it as a single block that lands all at once. It does not: the PPWR applies in stages, and confusing the general date with the later phases leads to two costly errors — investing now in requirements that do not yet apply, or arriving late to those that are already binding. This article separates what applies from 12 August 2026 from what only arrives in 2030.
What the PPWR is, and who carries the obligation
The PPWR covers all packaging placed on the EU market, whatever the material — plastic, paper, glass, metal or composites — and whatever product it contains. The point most companies get wrong is who carries the obligation. For PPWR purposes, the “manufacturer” is whoever places the packaging on the market under their own name or brand, not necessarily whoever physically produces it. For private label or imported goods, this means the EU Declaration of Conformity is signed by the brand that markets the product, while the physical manufacturer keeps and supplies the technical file. An importer bringing packaging or packaged goods from a third country therefore takes on the manufacturer’s obligations before the EU authorities.
What actually applies from 12 August 2026
12 August 2026 is the general date of application. From that day, the following obligations are binding, among others:
- Technical documentation and the EU Declaration of Conformity per packaging type (Articles 15 and 39): the file that proves the packaging meets the applicable requirements. Without it, the packaging should not be placed on the market.
- Heavy-metal restriction (Article 5): the sum of lead, cadmium, mercury and hexavalent chromium may not exceed 100 mg/kg. This is not new — it carried over from Directive 94/62/EC — but the PPWR keeps it and folds it into conformity.
- PFAS restriction — food-contact packaging only (Article 5): a constantly misread point. The PPWR PFAS restriction does not apply to cosmetic or general packaging; only to food-contact packaging.
- Minimisation of weight and volume and limits on empty space (Article 10): packaging must be reduced to what its function requires.
- Producer registration and Extended Producer Responsibility (EPR): registration in the producer register and membership of a collective scheme.
What is NOT due in 2026: the 2028 and 2030 requirements
This is where the savings are. The requirements that generate the most noise — and the most alarming investment — are not binding in 2026:
- Recyclability with design-for-recycling grades A/B/C (Article 6): 1 January 2030. Grade C stops being accepted in 2038.
- Minimum recycled content in plastic packaging (Article 7): 1 January 2030.
- Bans on certain single-use formats (Annex V, Article 25): 1 January 2030.
- Harmonised packaging labelling (Article 12): around 2028, pending the implementing act that fixes the format.
The practical advice is to start gathering recyclability and recycled-content data now — because it affects design and cannot be solved in a month — but without declaring it binding in August 2026. On top of that, several delegated and implementing acts (recyclability criteria, recycled-content calculation, the format of the Declaration of Conformity, minimisation limits) are still being adopted: parts of the file cannot be closed until they are published, so always verify against EUR-Lex and the Commission guidance.
EPR membership does not replace product conformity
A frequent misunderstanding is to assume that belonging to a collective EPR scheme equals PPWR compliance. It does not. EPR membership covers the producer’s extended responsibility — the financial contribution, the producer register and eco-modulation tools — but it does not replace the technical file or the EU Declaration of Conformity for each packaging type. They are two complementary planes: “registered” is not the same as “compliant”. This matters especially for food packaging, where conformity also connects with food-contact rules: see our guide on the Declaration of Conformity for food contact materials.
Frequently asked questions
Do I need a recycled-content certificate by August 2026?
No. Minimum recycled content in plastic packaging is a 2030 requirement (Article 7). You should start collecting the data because it drives design decisions, but it is not binding in 2026.
My supplier is outside the EU. Can it sign the Declaration of Conformity?
As the party placing the packaging on the EU market under your brand, you take on the manufacturer’s obligations and issue the EU Declaration yourself. Your supplier’s documentation feeds the technical file, but it does not replace your declaration.
How ASC Services helps
We build your packaging conformity end to end: an inventory of packaging by type and material, the technical file and the EU Declaration of Conformity under the PPWR, and the administrative EPR side — producer registration, scheme membership and periodic reporting. We separate what is binding in 2026 from what arrives in 2030, so you invest where it counts and in the right order. Talk to us through our contact page or explore our consultancy services for regulated products.