EU Packaging Regulation (PPWR): what changed on August 12 and what sellers must do now
On 12 August 2026, the EU Packaging and Packaging Waste Regulation — Regulation (EU) 2025/40, known as the PPWR — became directly applicable across all 27 EU Member States. It replaced the 1994 Packaging and Packaging Waste Directive that had governed packaging rules for three decades. If you sell packaged products into the EU, the rules have changed. There is no grace period for existing stock.
On 12 August 2026, the EU Packaging and Packaging Waste Regulation — Regulation (EU) 2025/40, known as the PPWR — became directly applicable across all 27 EU Member States. It replaced the 1994 Packaging and Packaging Waste Directive that had governed packaging rules for three decades. If you sell packaged products into the EU, the rules have changed. There is no grace period for existing stock.
This guide explains what the PPWR is, what actually changed on August 12, what obligations apply now versus later, and what action to take this quarter.
What the PPWR is
The PPWR is the EU's single, directly binding rulebook for how packaging is designed, documented, sold, and managed at end of life. The key structural change is legal form: the old regime was a directive, meaning each Member State transposed it into national law differently. The PPWR is a regulation, meaning it applies identically in every EU country from the day it takes effect.
For sellers, this means "EU packaging compliance" is no longer 27 separate legal problems. The design and documentation rules are now harmonised. However, registration and fees — your Extended Producer Responsibility (EPR) obligations — remain national. You still register with and pay into each country's scheme individually.
The PPWR entered into force on 11 February 2025. Most obligations apply from 12 August 2026 under Article 71.
Who is in scope
The PPWR applies to any business that manufactures, imports, fills, distributes, or sells packaged products in the EU. That includes:
- brands that manufacture their own products;
- importers that bring packaged goods from outside the EU;
- private-label sellers;
- fulfilment companies handling packaged products;
- online sellers using Amazon FBA, Shopify, or any other channel;
- online marketplaces when they handle packaging or logistics on behalf of third-party sellers.
If you are a non-EU manufacturer whose products reach the EU in any packaging, you almost certainly carry PPWR obligations directly — both as the manufacturer (packaging design requirements and a Declaration of Conformity) and as the producer (national EPR registration and, in most cases, an EU-based Authorised Representative).
For ecommerce businesses, the scope extends beyond the product's retail box. Shipping cartons, mailing bags, protective inserts, tape, and void-fill can all be relevant.
What actually changed on August 12, 2026
Not every PPWR obligation started on August 12. Many headline requirements — recyclability grades, minimum recycled content, harmonised labelling, reuse targets — are phased in between 2027 and 2040. Here is what is binding now versus what comes later.
Binding from August 12, 2026
PFAS limits in food-contact packaging. Article 5 introduces concentration limits on per- and polyfluoroalkyl substances (commonly called "forever chemicals") in food-contact packaging. If any part of your packaging range touches food directly — grease-resistant wrappers, coated cardboard, certain moulded fibre trays — this requirement applies now.
Declaration of Conformity. Every packaging format placed on the EU market from 12 August 2026 must be accompanied by a Declaration of Conformity and supporting technical documentation. This is the manufacturer's declaration that the packaging meets the essential requirements of the regulation.
Heavy metal concentration limits. Packaging must respect the limit on the sum of lead, cadmium, mercury, and hexavalent chromium (100 ppm). This continues the existing Directive 94/62/EC limit but is now part of the PPWR framework.
Empty-space limits for ecommerce packaging. The PPWR caps empty space in ecommerce parcels at 40%. If you ship products in oversized boxes with excessive void-fill, this provision applies.
Authorised Representative requirement. PPWR Article 45 introduces its own EU-wide representative requirement for non-EU producers. This is separate from the GPSR EU Responsible Person and from any existing national requirements. Without an authorised representative in each relevant Member State, packaging cannot lawfully be placed on that market.
Marketplace verification. Online marketplaces are required to verify that traders using them are properly registered. Article 45(4) makes this explicit.
Coming later (not yet binding)
| Requirement | Expected date |
|---|---|
| Recyclability performance grades (A/B/C) | 2028 |
| Minimum recycled content targets (plastics) | 2030 |
| Harmonised packaging labelling (material identification + sorting) | 2028 |
| Reuse targets (specific sectors) | 2030–2040 |
| Ban on certain single-use plastic formats (Annex V) | 2030 |
| Deposit-return systems harmonisation | 2029 |
What sellers must do now
1. Audit your packaging inventory
List every packaging component you place on the EU market: retail packaging, shipping packaging, protective packaging, labels, inserts, tape. For each component, record: material, weight, supplier, whether it contacts food, and whether it contains or may contain PFAS.
2. Prepare your Declaration of Conformity
For each packaging format, you need a Declaration of Conformity stating that it meets the PPWR essential requirements. This is the manufacturer's responsibility. If you source packaging from a supplier, request their declaration or supporting documentation.
3. Check PFAS exposure
If any of your packaging contacts food, confirm with your supplier that PFAS concentrations comply with the Article 5 limits. Request a supplier declaration or test certificate. This is the most immediately enforceable obligation.
4. Review ecommerce empty-space ratios
Measure the void-fill ratio in your standard shipment configurations. If more than 40% of your parcel volume is empty, adjust your packaging sizes or reduce fill materials.
5. Confirm your EPR registrations
The PPWR harmonises EPR rules but does not centralise registration. You still need to register with each national scheme in every country where you place packaging on the market. If you are not already registered in all relevant countries, this is now non-optional.
6. Appoint an Authorised Representative where required
If you are a non-EU producer, Article 45 requires you to appoint an authorised representative in the EU. This is a per-country requirement — the harmonised registration format the Commission was expected to publish has been delayed, which means national registration processes still vary.
PPWR vs EPR: what is the difference?
This is a common point of confusion. The PPWR sets the EU-wide design and documentation rules for packaging and harmonises the framework for EPR. EPR itself — Extended Producer Responsibility — is the system by which producers register, report, and pay into national waste management schemes. The PPWR does not replace EPR registration. It harmonises the rules around it.
You need both: PPWR compliance for the packaging itself, and EPR registration for the financial obligations in each Member State.
How Regonance helps
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Educational information only. Not legal advice. The PPWR's national registration and representative requirements vary by Member State — validate scope with a qualified advisor before acting.
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Compliance guidance based on published EU regulatory texts. Not legal advice. Consult qualified counsel for your specific situation.