PPWR is live: what EU packaging rules mean for your products right now

The EU Packaging and Packaging Waste Regulation — Regulation (EU) 2025/40, the PPWR — is no longer something to prepare for. Its main body of obligations became applicable on 12 August 2026. If you sell packaged products into the European Union today, you are selling under it. There is no transition window for stock already in a warehouse, and there is no national grace period, because a regulation applies directly in all 27 Member States without transposition.

That is the uncomfortable framing of this article: if you have not looked at packaging yet, you are already late. The good news is that most of what is binding right now is documentation and design hygiene rather than expensive redesign. The expensive parts — recyclability grades, recycled content minimums, harmonised labels — arrive between 2028 and 2030, and you still have time to plan for them.

Why this one is different from the old packaging directive

Packaging rules in Europe are not new. Directive 94/62/EC governed them for three decades. But a directive is an instruction to Member States, each of which wrote its own national law. That is why packaging compliance historically meant 27 separate legal problems, 27 sets of definitions and 27 sets of paperwork.

The PPWR replaces that with one binding text. Design requirements, conformity documentation, substance limits and ecommerce parcel rules are now the same in Dublin, Warsaw and Lisbon. What remains national is money: Extended Producer Responsibility registration and fees are still paid scheme by scheme, country by country. Harmonised rules, national invoices.

Who carries the obligations

The regulation attaches duties to roles, not to company size. You are in scope if you manufacture packaging, fill it, import packaged goods, distribute them, or sell them to EU customers. In practice that covers:

• brands manufacturing their own products;
• importers bringing packaged goods into the EU;
• private-label and white-label sellers;
• online sellers on their own storefront or on marketplaces;
• fulfilment providers handling packaged goods;
• marketplaces themselves, where they handle packaging or logistics for third-party sellers.

Two traps catch ecommerce sellers repeatedly. First, "packaging" is not only the retail box: shipping cartons, mailer bags, void-fill, tape, inserts and protective sleeves all count. Second, if you are established outside the EU, you generally carry the producer obligations directly and need EU-based representation — which is a separate appointment from the GPSR EU Responsible Person you may already have.

What is binding right now

Conformity documentation

Every packaging format placed on the EU market since 12 August 2026 must be covered by a Declaration of Conformity supported by technical documentation. This is the single most common gap we see. It is a manufacturer duty, so if you buy packaging from a supplier, the practical action is to request their declaration and keep it on file with your own product records. If you specify bespoke packaging, the declaration may be yours to issue.

Substance limits

Two limits matter immediately. The sum of lead, cadmium, mercury and hexavalent chromium in packaging must stay within 100 ppm, continuing the limit sellers already knew from the old directive. Newer, and much more likely to be missed, is the limit on per- and polyfluoroalkyl substances (PFAS) in food-contact packaging under Article 5. Grease-resistant wrappers, coated board, moulded fibre trays and similar formats are the usual suspects. Ask your supplier for a written declaration or test evidence; do not assume "paper" means "PFAS-free".

Empty space in ecommerce parcels

The regulation caps empty space in ecommerce, transport and grouped packaging at 40%. This is measurable, easy for an enforcement authority to photograph, and easy for you to fix. Take your five highest-volume shipment configurations, calculate the ratio of product volume to parcel volume, and where you are over the line either drop a box size or reduce fill.

Recycled content declarations

Where you make claims about recycled content in packaging, they must be substantiated on the same evidentiary footing the regulation expects. The binding minimum percentages arrive in 2030, but an unsupported claim today is a problem today — not least because unsupported environmental claims also fall under the EmpCo Directive.

Labelling under Article 12

Article 12 sets the framework for harmonised material and sorting information on packaging, with the detailed harmonised formats following through implementing acts. The practical near-term step is to inventory what your packaging currently says. Country-specific sorting logos and legacy claims will need to be reconciled with the harmonised scheme when it lands, and the businesses that already know what is printed on every format will have a far cheaper transition.

EPR for packaging

The PPWR harmonises the framework around Extended Producer Responsibility, but registration and fees stay national. If you place packaging on the market in Germany, France, Spain, Italy or the Netherlands, you register with each scheme, report the tonnage you place, and pay. Selling on a marketplace does not remove this obligation, and marketplaces are now expected to check that traders using them are registered — which means non-registration increasingly shows up as a listing problem before it shows up as a fine.

What comes later

Treat this table as a planning horizon, not a reason to wait. Recyclability grades in 2028 are decided by design choices you make in 2027, and packaging tooling has long lead times.

A realistic 30-day plan

Week 1 — inventory. One row per packaging component you place on the EU market. Material, weight, supplier, food contact yes or no, market countries. Nothing about the PPWR can be answered without this list, and most companies do not have it.

Week 2 — documents. Request Declarations of Conformity and PFAS evidence from each packaging supplier. Chase in writing so the request itself becomes part of your due-diligence record.

Week 3 — measurement. Calculate empty-space ratios on your top shipment configurations. Fix anything above 40%.

Week 4 — registrations. Confirm you hold an active EPR registration in every country you ship to, and that reported tonnages match what you actually shipped last year. Where you are non-EU, confirm your authorised representation is in place.

Where the mistakes cluster

The failures we see are rarely exotic. They are: no declaration on file for the shipping carton because nobody thought a carton counted; a food-contact liner bought before anyone asked about PFAS; EPR registered in Germany only, because Germany was the first market and nobody revisited it after expansion; and marketing copy calling packaging "eco-friendly" with nothing behind it, which turns a packaging problem into a green-claims problem.

What to do with this today

Packaging compliance is a data problem before it is a legal problem. Once you know what your packaging is made of, who supplied it, which countries it reaches and what your parcels actually look like, most PPWR questions answer themselves. Start the inventory this week, even if it is a spreadsheet, and let the documentation requests run in parallel.

Educational information only, not legal advice. National registration and representation requirements still vary by Member State — confirm scope for your markets with a qualified advisor.