PPWR in Practice: What Businesses Need to Do Now

The Packaging and Packaging Waste Regulation is now applicable. The immediate challenge is not to redesign every package overnight. It is to establish who is responsible, identify every packaging component and assemble the evidence needed to demonstrate compliance.

From 12 August 2026, Regulation (EU) 2025/40—the PPWR—generally applies across the European Union. It covers packaging made from any material, whether empty or filled, manufactured in the EU or imported from a third country.

But the date can be misleading.

Not every PPWR target applies immediately. Many of the more demanding design, recyclability, recycled-content, minimisation and reuse requirements arrive between 2028 and 2038.

What changes now is the compliance architecture.

One product may involve several packaging files

A company should not begin its PPWR assessment with the finished product. It should begin by mapping the packaging around it.

The Regulation distinguishes between:

• Sales packaging, which forms the unit sold to the end user.
• Grouped packaging, which combines several sales units.
• Transport packaging, which protects and facilitates handling during transport.
• E-commerce packaging, a specific form of transport packaging used for distance sales.

A single shipment may therefore involve cartons, liners, labels, pallets, stretch wrap, straps, tape, corner boards and slip sheets. These are not necessarily one regulatory object.

The Commission’s August 2026 FAQ makes the consequence particularly clear for transport packaging: pallets, pallet collars, wrappings and straps may require separate conformity assessments and separate declarations of conformity.

By contrast, a sales-packaging unit composed of a bottle, closure and label can generally be assessed as a whole. One declaration may cover the complete unit, provided the supporting documentation contains the relevant information for each component.

The practical lesson is simple: a shipment-wide statement saying that “the packaging is PPWR-compliant” will often be too broad. The evidence must follow the actual packaging types and units.

First determine who the “manufacturer” is

The PPWR meaning of manufacturer does not always correspond to the company that physically makes the packaging.

Where packaging carries a company’s name or trademark, that company will generally be treated as the manufacturer—even if another business produced the packaging.

For generic, unbranded packaging, the physical packaging manufacturer will normally retain that role. With custom-made packaging, responsibility may instead follow the company that commissioned the packaging and determined its design specifications.

Transport packaging makes this assessment more complex. A pallet, carton and roll of stretch wrap can each reach their final form separately, come from different suppliers and have different manufacturers. Using them together for one shipment does not automatically transfer manufacturer status to the company assembling the load.

Importers have an additional responsibility. When packaging or packaged products come from outside the EU, the importer must verify that the third-country manufacturer has performed the applicable conformity assessment, prepared the EU Declaration of Conformity and supplied the required documentation.

There is another distinction worth preserving: manufacturer and producer are not interchangeable terms under the PPWR. “Producer” is used principally in relation to extended producer responsibility. The responsible company may change depending on the packaging, transaction and Member State concerned.

Supplier evidence is not a Declaration of Conformity

This is one of the most important practical distinctions in the new system.

Under Article 16, packaging suppliers must provide the manufacturer with the technical information and documentation necessary to demonstrate compliance. This may include information on materials, composition, design, substances, food-contact status, recycled content and recyclability.

That information is the evidence base. It is not the formal compliance declaration.

The EU Declaration of Conformity is drawn up under Article 39 by the manufacturer—or on its behalf by an authorised representative. A laboratory or certification scheme may perform parts of the conformity assessment. An authorised representative may assist with defined tasks.

But legal responsibility remains with the manufacturer. It cannot be transferred to a supplier, laboratory or consultant simply through contractual language.

This distinction should now be reflected in supply agreements. Contracts should specify:

• What information each supplier must provide.
• At what level—material, component, packaging type or production batch.
• How frequently the information must be updated.
• How changes in materials, formulations or design will be communicated.
• What happens when evidence is incomplete or no longer current.

Build a packaging file that can answer an authority’s questions

The objective is not to collect documents indiscriminately. It is to create a traceable line from the packaging placed on the market to the evidence supporting its compliance.

For each packaging type or sufficiently consistent family, the file should normally contain:

• A type, batch, serial number or equivalent identifier linking the packaging to its documentation.
• A bill of materials covering the packaging unit and its components.
• Material specifications, dimensions and weights.
• Supplier identities and declarations.
• Relevant design and manufacturing information.
• Food-contact documentation, where applicable.
• Evidence concerning substances of concern.
• Recyclability and recycled-content evidence as the corresponding requirements become applicable.
• Support for any claim concerning recyclability, compostability, recycled content, reusability or packaging minimisation.
• The conformity assessment and EU Declaration of Conformity.
• A record of design, supplier and material changes.

The PPWR does not require every individual item to carry its own serial number. Identification at packaging-type or production-batch level may be sufficient where it allows the packaging to be connected reliably to the correct technical file.

Manufacturers and importers must retain the technical documentation for five years for single-use packaging and ten years for reusable packaging.

The Declaration of Conformity must also be available in the language or languages required by the Member State where the packaging is placed or made available on the market.

What applies now—and what comes later?

The PPWR is not a single deadline. It is a sequence.

From 12 August 2026

The general manufacturer, importer, traceability and conformity framework applies in relation to the substantive requirements already in force.

Food-contact packaging is subject to the new PFAS limits: 25 ppb for an individual PFAS and 250 ppb for the sum of targeted PFAS. Where total fluorine exceeds 50 mg/kg, additional evidence may be needed to distinguish PFAS from non-PFAS fluorine.

All packaging remains subject to the combined 100 mg/kg limit for lead, cadmium, mercury and hexavalent chromium. Compliance with these substance requirements must be demonstrated in the technical documentation.

Packaging must also carry—or, where permitted, be accompanied by—the required identification and manufacturer information.

From 2028 or later

Harmonised sorting labels are expected to apply from 12 August 2028 or after the relevant implementing measures have entered into force, whichever is later. Businesses should therefore prepare their packaging systems for change without treating unfinished labelling rules as final.

From 2030

The main design transition begins. This includes recyclability performance requirements, minimum recycled content for plastic packaging, packaging minimisation, empty-space limits, certain single-use packaging restrictions and reuse targets.

Several dates remain linked to delegated or implementing acts. Companies should consequently track both the headline year and the measures needed to make the obligation operational.

From 2035 and 2038

From 2035, recyclability will increasingly depend on whether packaging is recycled at scale. From 2038, only packaging meeting recyclability grades A or B may remain marketable, subject to the Regulation’s applicable qualifications and exemptions.

The 2030 obligations are later obligations, but they require decisions now. Packaging formats, supplier contracts and production equipment cannot always be changed within one purchasing cycle.

Existing stock does not have to be destroyed

The Commission FAQ provides useful clarification for packaging produced before 12 August 2026 but not yet placed on the market.

It does not have to be destroyed, remanufactured or automatically relabelled. The required identifier and manufacturer information may be supplied through an accompanying document.

Packaging already placed on the EU market before 12 August 2026 may remain there even where it does not comply with the new PPWR requirements.

For packaging manufactured after that date, however, accompanying documentation should be used for identification and manufacturer information only where the nature or size of the packaging makes direct marking impracticable.

This is a transition measure, not a general alternative to traceability.

Enforcement offers a landing period—not an exemption

The Commission has stated that enforcement immediately after 12 August 2026 should not disrupt trade flows, supply chains or consumer access to goods.

Where an authority identifies non-compliance, the economic operator should first be asked to correct it. Market-surveillance authorities are encouraged to use information requests, awareness-raising and reasonable adaptation periods rather than beginning with sanctions.

But this is not immunity.

If non-compliance persists, authorities may prohibit, withdraw or recall the packaging. A company that can demonstrate that it has mapped its packaging, assigned responsibilities, requested supplier evidence and established a corrective-action plan will be in a materially stronger position than one relying on a generic supplier assurance.

Five actions to take now

1. Map every packaging component.

Include sales, grouped, transport and e-commerce packaging—not only the package seen by the consumer.

2. Assign the regulatory roles.

Determine the manufacturer, importer, distributor and EPR producer for each relevant flow. Do not assume that one company occupies every role.

3. Send structured Article 16 requests to suppliers.

Ask for component-level evidence and establish an update process for changes in materials or design.

4. Create packaging-type files.

Link each type or batch to its specifications, supporting evidence, conformity assessment and declaration.

5. Separate immediate compliance from redesign planning.

Close the 2026 documentation and substance gaps first, while beginning the longer transition towards the 2030–2038 performance requirements.

Where to find the official guidance

The European Commission’s Packaging and Packaging Waste Regulation FAQ was updated in August 2026 and addresses many operational questions concerning roles, existing stock, transport packaging, conformity assessment and early enforcement.

It should be read together with the Commission’s more detailed PPWR Guidance Document and the legally binding text of Regulation (EU) 2025/40.

The FAQ is a practical interpretative aid. It does not replace the Regulation, the delegated and implementing acts still to come, or an assessment of the particular packaging and supply chain involved.

Do you want to learn more? Contact Nexum EU Strategies