The EU Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, entered into force on 11 February 2025 and has applied since 12 August 2026 (Article 71).
Many businesses associate the PPWR with its 2030 targets for recyclability, recycled content and reuse. Several important obligations, however, already apply today: restrictions on substances in packaging, the conformity assessment, technical documentation and EU declaration of conformity, identification of the packaging and its manufacturer, and the duty of packaging suppliers to provide compliance information.
To support implementation, the European Commission published an official guidance document (C/2026/3084) on 10 June 2026, followed by updated Frequently Asked Questions on 3 August 2026.
The message for businesses is clear: PPWR compliance is no longer only about redesigning packaging for future requirements. It is about being able to demonstrate compliance today.
1. Which PPWR requirements already apply?
The PPWR introduces its requirements gradually, and not every obligation became applicable in August 2026. Manufacturers and brands must nevertheless already address the following.
Restrictions on substances of concern
Article 5 sets requirements for substances in packaging:
- Heavy metals: the sum of the concentrations of lead, cadmium, mercury and hexavalent chromium in packaging or packaging components must not exceed 100 mg/kg (Article 5(4)).
- PFAS in food-contact packaging: since 12 August 2026, food-contact packaging may not be placed on the market if it contains per- and polyfluoroalkyl substances at or above 25 ppb for any targeted PFAS, 250 ppb for the sum of targeted PFAS, or 50 ppm for PFAS including polymeric PFAS (Article 5(5)).
Compliance with both limits must be demonstrated in the technical documentation (Article 5(6)). The Commission's guidance adds two practical points. There is no transitional period for selling off existing stock, although food-contact packaging placed on the market before 12 August 2026 may remain on the market. And sales and grouped food-contact packaging are generally considered placed on the market when they are filled.
For manufacturers, this creates an immediate need to understand packaging composition and to obtain reliable evidence from material suppliers: chemical declarations, laboratory reports and, for food-contact packaging, the applicable food-contact documentation.
Packaging recyclability
Article 6(1) states that all packaging placed on the market shall be recyclable. The Commission's guidance confirms that, because no specific deadline is set for it, this general provision applies from 12 August 2026.
The detailed design-for-recycling criteria and the recyclability performance grades A, B and C come later, through delegated and implementing acts. The guidance also states that manufacturers do not need to perform the conformity assessment for recyclability until the delegated acts under Article 6(4) enter into force.
In practice, manufacturers should keep evidence of packaging materials and current recyclability characteristics while preparing for the detailed requirements planned from 2030.
Reusable packaging
Article 11 defines when packaging counts as reusable. It must, among other things, be conceived and designed for as many rotations as possible, be capable of being reconditioned while keeping its function, and be part of a system for re-use.
The Regulation applies these criteria to packaging placed on the market from 11 February 2025. Reusable packaging already on the market before that date does not have to be brought into conformity, withdrawn or recalled (Article 15(9)). Our article on the REDIPACK reusable packaging project shows what a system for re-use looks like in practice.
Practical implication: separate the requirements that already apply from those that become mandatory later. Treating the PPWR as a single 2030 deadline is a mistake.
2. Technical documentation and EU declarations of conformity are required now
The most important immediate change concerns conformity documentation.
Before placing packaging on the market, the manufacturer must carry out the conformity assessment procedure (Article 38) or have it carried out on its behalf, and draw up the technical documentation (Article 15(2)). The procedure is the internal production control set out in Annex VII. It does not require a notified body; the Commission's guidance notes that a laboratory or certification scheme may carry out the assessment for the manufacturer.
The manufacturer is responsible for:
- Assessing the packaging against the requirements of Articles 5 to 12 that apply to it.
- Drawing up the technical documentation.
- Drawing up an EU declaration of conformity once compliance has been demonstrated (Article 39).
- Keeping series production in conformity and reassessing when the packaging design, its characteristics or the referenced standards change (Article 15(4)).
What the technical documentation contains
Annex VII lists the elements, where applicable, including:
- a general description of the packaging and its intended use;
- design and manufacturing drawings, materials and components;
- the harmonised standards, common specifications or other technical specifications applied;
- the assessment methods used and how conformity is demonstrated;
- test reports and supporting evidence;
- an analysis and assessment of the risk of non-conformity.
The EU declaration of conformity follows the model in Annex VIII. It must be kept up to date and be available in the language or languages required by the Member State where the packaging is placed on the market. Where several EU acts require a declaration, a single declaration covering all of them can be drawn up (Article 39(2) and (3)).
The manufacturer keeps the technical documentation and the declaration for (Article 15(3)):
| Packaging type | Retention period |
|---|---|
| Single-use packaging | 5 years from the date it was placed on the market |
| Reusable packaging | 10 years from the date it was placed on the market |
A declaration is not an administrative formality: by drawing it up, the manufacturer assumes responsibility for the compliance of the packaging (Article 39(4)).
Identification and manufacturer information
Two further obligations apply now:
- the packaging must bear a type, batch or serial number or another element allowing its identification, or the information must accompany the packaged product (Article 15(5));
- the manufacturer's name, registered trade name or trademark and postal address must be indicated on the packaging, or through a QR code or another data carrier (Article 15(6)).
3. Packaging suppliers must provide the necessary compliance information
Manufacturers cannot demonstrate conformity without reliable information from their suppliers.
Article 16 requires suppliers to provide the manufacturer with all the information and documentation necessary to demonstrate the conformity of the packaging and packaging materials, including the technical documentation referred to in Annex VII and required under Articles 5 to 11. It must be provided on paper or electronically, in a language the manufacturer can easily understand. For contact-sensitive packaging, such as food-contact packaging, the documentation required under the applicable EU rules is part of that information.
What to request from suppliers
| Information | Typical evidence |
|---|---|
| Packaging specifications | Material composition, component descriptions, drawings, weights |
| Chemical compliance | Restricted-substance declarations and relevant test reports |
| Food-contact packaging | Applicable food-contact documentation and PFAS evidence |
| Recyclability | Material identification and relevant assessments |
| Reusable packaging | Design specifications, durability and re-use system information |
| Document control | Supplier identity, document versions and the packaging specifications concerned |
Not every packaging type needs the same evidence, so tailor each request to the obligations that apply to it.
Importantly, a supplier declaration alone does not automatically demonstrate PPWR compliance. The manufacturer must judge whether the evidence actually supports each requirement. Where documentation is missing, Article 16 gives a clear legal basis for asking the supplier for it.
4. Who is responsible: the packaging supplier or the brand owner?
The PPWR distinguishes the manufacturer, responsible for the conformity of the packaging, from the producer, the role that matters for extended producer responsibility (EPR). These are not necessarily the same company.
The definition of manufacturer in Article 3(13) is explicit: a company that has packaging or a packaged product designed or manufactured under its own name or trademark is the manufacturer, even when another company physically produces the packaging. This is particularly relevant for private-label brands and retailers. There is one exception: when that company is a micro-enterprise and its packaging supplier is located in the same Member State, the supplier is the manufacturer. The Commission's guidance and FAQs explain these rules further.
For companies buying packaging from several suppliers, the practical questions are:
- Who is the manufacturer under the PPWR for each packaging?
- Who performs the conformity assessment?
- Who issues the EU declaration of conformity?
- Which suppliers must provide supporting information?
- Who maintains the documentation when packaging specifications change?
Answering them is the essential first step. The same question arises for products under the Digital Product Passport rules; see who is responsible for the Digital Product Passport.
5. What comes next: 2028, 2029 and 2030
The PPWR already applies, but significant further requirements follow.
| Timeline | Key requirements |
|---|---|
| 12 August 2026 | General application, conformity documentation, identification, supplier information, PFAS limits for food-contact packaging |
| 12 February 2028 | Empty space in sales packaging reduced to the minimum necessary (Article 24(4)) |
| From 12 August 2028 at the earliest | Harmonised labels on material composition (Article 12(1)) |
| From 12 February 2029 at the earliest | Labels on reusable packaging, with further information through a QR code or other data carrier (Article 12(2)) |
| From 2030 | Design-for-recycling requirements, minimum recycled content in plastic packaging, packaging minimisation, a maximum empty space ratio of 50% for grouped, transport and e-commerce packaging, and re-use targets, subject to the conditions and implementing acts set out in the Regulation |
Several dates depend on delegated or implementing acts and may therefore move later.
The PPWR does not require every package to carry a QR code in 2026, nor does it create a universal Digital Product Passport for packaging. Digital information will nonetheless matter more and more: for identification, consumer information, reusable packaging and compliance documentation. Businesses should prepare their packaging data before the next requirements take effect.
6. A practical PPWR compliance checklist
For companies managing many packaging suppliers and product lines, start with six concrete actions.
Step 1: Map your packaging portfolio
Build a structured inventory of packaging types and configurations, with their materials, components, suppliers and the products or SKUs that use each one.
Step 2: Determine legal responsibilities
Identify the manufacturer, supplier, importer and EPR producer for each case. Establish who is accountable for conformity and documentation.
Step 3: Assess the requirements that apply now
Review each packaging configuration against the applicable requirements, starting with substance restrictions, food-contact packaging, identification and manufacturer information, and the reusable-packaging criteria.
Step 4: Collect supplier evidence
Request missing specifications, declarations and test information. Track which suppliers have responded and where evidence is still incomplete.
Step 5: Prepare and maintain conformity documentation
Organise the technical documentation and EU declarations of conformity, link them to the right packaging specifications and versions, and apply the retention periods.
Step 6: Prepare for upcoming requirements
Start collecting material composition, packaging weights and dimensions, recycled content and re-use information that future PPWR obligations will need.
The goal is not to collect every possible document. It is to hold the right evidence for each packaging configuration and each applicable requirement.
7. How GoodsTag helps businesses manage PPWR compliance
For manufacturers and brands with hundreds or thousands of product references, the hard part is rarely a single requirement. It is managing the links between packaging specifications, suppliers, evidence, products and markets.
GoodsTag's Packaging Compliance & Circularity Platform helps businesses:
- centralise packaging specifications and component-level information;
- collect and organise supplier declarations, certificates and test results;
- connect compliance documentation to the packaging configurations and product SKUs concerned;
- keep versioned records and evidence as packaging specifications change;
- manage digital packaging information and extend the same data foundation to circular packaging operations.
A packaging specification used by hundreds of products is managed once, centrally, instead of collecting the same information separately for each product.
GoodsTag supports the management of compliance data and documentation. The conformity assessment and the EU declaration of conformity remain the responsibility of the legally accountable manufacturer.
From compliance documentation to circular packaging management
The same data foundation supports the coming requirements for reusable packaging. With unique identification, Digital Twins and event tracking, companies can monitor packaging rotations, returns, losses and operational performance, and connect regulatory compliance with measurable circularity.
Conclusion: PPWR compliance starts with reliable packaging data
The application of the PPWR on 12 August 2026 marked the move from regulatory preparation to operational compliance.
The immediate priority is to establish which requirements apply, identify the responsible economic operators, collect supplier evidence and keep the necessary conformity documentation. Requirements for recyclability, labelling, recycled content and re-use will add further demands. Companies that structure their packaging data today will manage those obligations more efficiently as the framework develops.
Sources
- Regulation (EU) 2025/40 on packaging and packaging waste (PPWR), Articles 3, 5, 6, 11, 12, 15, 16, 24, 38, 39 and 71, Annexes VII and VIII
- Commission Notice C/2026/3084: Guidance document for Regulation (EU) 2025/40, 10 June 2026
- European Commission: FAQ on the Packaging and Packaging Waste Regulation, 3 August 2026
- European Commission: New EU packaging rules start to apply, including restrictions on PFAS in food-contact packaging, 11 August 2026
Last regulatory review: 14 October 2026. Commission guidance and FAQs set out the Commission's interpretation but do not amend the Regulation. Specific requirements depend on the packaging type, the economic operator and the applicable implementation dates. This article provides general regulatory information and does not replace a packaging-specific legal assessment.
