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PPWR explained: what the new packaging regulation means for your organization

7–10 minutes

Max van der Wal and Romeo Kaptijn

28 September 2026

Manufacturers requesting PFAS analyses. Customers who want to know whether your packaging will still be compliant by 2030. And an implementation date of August 12, 2026, which has now passed, even though many organizations have not yet completed their preparations. For anyone placing packaging on the European market, the rules of the game have fundamentally changed. This article explains what the requirements are, who is affected, and which steps should be prioritized now.

Table of contents

What is the PPWR?

The Packaging and Packaging Waste Regulation — abbreviated as PPWR — is the new EU regulation on packaging and packaging waste, effective as of August 12, 2026. It replaces the European Packaging Directive, which has been in effect since 1994.

The difference from a directive is fundamental: a regulation takes effect directly in all EU member states, without requiring countries to enact national legislation to implement it. Its provisions apply immediately in Amsterdam, Düsseldorf, and Milan — without any intervention from The Hague.

The goal is to reduce packaging waste and improve environmental performance. The PPWR achieves this through requirements in four key areas:

Recyclability: whether a piece of packaging can actually be recycled.
Reuse: packaging that is refilled and used multiple times, as opposed to single-use packaging.
PFAS: per- and polyfluoroalkyl substances, a group of chemicals commonly found in food packaging that are now subject to limit values.
Extended Producer Responsibility (EPR): the system under which the party that places packaging on the market is jointly responsible for its recycling and contributes financially toward that process.

The PPWR applies to all materials: plastic, glass, paper, metal, composites, and wood. No material is excluded.

In a nutshell

  • What: Binding EU rules for all packaging on the EU market — requirements for PFAS — levels, recyclability, recycled content, reuse, and labeling.
  • Who it applies to: Any organization that places packaging or packaged products on the EU market — manufacturers, importers, distributors, or private-label holders. There is no revenue threshold or employee threshold.
  • When: The main requirements take effect on August 12, 2026. Additional requirements will take effect in 2028, 2030, and 2038.
  • What you can do now: Determine the role you play, take inventory of your packaging, and test for PFAS levels — the limit values for food packaging apply immediately, with no transition period.

Who is covered by the PPWR?

The PPWR applies to anyone who places packaging or packaged products on the EU market. There are no financial thresholds: in principle, both a multinational and an SME are subject to the same rules (though there are certain exceptions for micro-enterprises). The obligations that apply to you depend on your role in the supply chain.

  • Manufacturer: prepares technical documentation, assesses whether its packaging meets the requirements, and records this in an EU declaration of conformity. Retention period: 5 years for single-use packaging, 10 years for reusable packaging.
  • Importer: Verifies, prior to market entry, whether the foreign manufacturer has complied with its documentation requirements.
  • Distributor: verifies whether the required labels are present and whether the manufacturer or importer has fulfilled their obligations.
  • Private label/own brand: Anyone who markets packaging under their own name or makes substantial changes to existing packaging is legally considered a manufacturer — with all the associated obligations.
“Anyone who markets packaging under their own name is legally considered the manufacturer, even if they do not produce the packaging themselves.”

PPWR timeline

  • August 12, 2026: PFAS limit values for food packaging; technical documentation and declaration of conformity for manufacturers; supply chain information requirements.
  • February 12, 2027: Refill systems in the hospitality industry for consumer containers.
  • February 12, 2028: Retailers must offer reusable takeout containers.
  • August 12, 2028: Harmonized labeling of material composition becomes mandatory.
  • January 1, 2030: Ban on packaging with a recyclability rating below Grade C; ban on six types of single-use plastic packaging; reuse targets for transport packaging; minimum percentages of recycled plastic in plastic packaging, established through delegated acts.
  • January 1, 2038: Only packaging with Grade A or B recyclability will be permitted.

The date of August 12, 2026, has arrived. That does not mean the work is complete: PFAS analyses, technical documentation, and UPV registrations are still ongoing at many organizations. The set of 2030 requirements calls for the redesign of packaging and adjustments to the supply chain. This requires preparation even now.

What will change, and what will happen if you do nothing?

The crux of the change: packaging may only be placed on the EU market if it is accompanied by a declaration of conformity, supported by technical documentation. This was not the case previously. Whereas the sector previously operated on the basis of industry agreements and voluntary standards, there is now a requirement to demonstrate compliance that is comparable to the documentation requirements in the electronics or mechanical engineering industries.

There is no transition period for PFAS. As of August 12, 2026, it will no longer be permitted to place food packaging on the market that contains intentionally added PFAS in amounts exceeding the limit values, not even for existing inventory.

The PPWR requires member states to establish penalties. The amounts are not harmonized at the EU level; member states determine the amounts of the fines themselves.

The practical risk is very real: large retailers and companies that report on sustainability are requesting information from suppliers about packaging materials and PFAS levels. Those who cannot provide this information may lose orders; as an importer, you must also verify the documentation provided by foreign suppliers.

What are the requirements set by the PPWR?

PFAS-Free Food Packaging (Effective August 12, 2026)
Packaging that comes into contact with food must not contain PFAS in amounts exceeding the established limits. There is no grace period and no exception for existing inventory. This is the most urgent requirement for everyone in the food chain.
Technical Documentation and Declaration of Conformity (Effective August 12, 2026)
Manufacturers must demonstrate that their packaging complies — through an EU declaration of conformity, supported by technical documentation. Importers must verify that this documentation is available before placing products on the EU market. If it is not available, they are the responsible party.
UPV Registration (effective August 12, 2026)
Anyone who is the first to place packaging on the market in an EU member state must register with that member state’s national producer registry, and this applies separately for each country. Non-European producers who supply directly to EU customers are required to appoint a UPV representative.
Ban on non-recyclable packaging and certain types of plastic (effective January 1, 2030)
Packaging with a recyclability rate that is too low will no longer be allowed on the EU market after 2030. Specific single-use plastic packaging formats will then be completely banned. Anyone who does not review their packaging design now will have too little time to make the necessary changes.
Recycled Plastic in Plastic Packaging (Effective January 1, 2030)
Plastic packaging must contain a minimum percentage of recycled material, which varies depending on the type of packaging. The exact calculation methods will be established through delegated acts of the European Commission.

How does the PPWR relate to other legislation?

The PPWR does not stand alone. Three connections are the most relevant in practice.

PPWR and SUPD

The Single-Use Plastics Directive already established bans on certain product categories. The PPWR expands on this and takes the lead on the six packaging formats listed in Annex V.

PPWR and ESPR

The Ecodesign for Sustainable Products Regulation (ESPR) and the PPWR employ a number of similar principles regarding requirements for products and packaging, respectively. In addition, the ESPR introduces digital product passports with QR codes; the PPWR introduces similar declarations of conformity and digital labeling requirements. Whoever is currently coordinating data collection for both has opportunities for direct harmonization.

PPWR and the “old” PPWD

The Packaging Directive 94/62/EC will expire on August 12, 2026. For organizations that based their compliance policies on that directive — through national implementing laws or industry agreements — the legal framework will change as of that date. The more ambitious goals of the PPWR were not previously included in the directive.

Getting started with the PPWR

  1. Determine the role in which you operate
    Identify which packaging products you place on the EU market and whether you are a manufacturer, importer, distributor, or private-label holder. That determination defines your obligations. An importer who sells products under their own name may be considered a manufacturer and is also subject to the corresponding documentation requirements.
  2. Prepare a packaging dossier
    Start by requesting technical documentation from your suppliers of packaged products and packaging materials. Manufacturers can only prepare their declaration of conformity if their suppliers provide the necessary information. Establish this as a systematic process, not a one-time request.
    Currently, the focus here is on testing PFAS levels in food packaging.
  3. Start looking ahead to 2030
    In addition to the obligations already in place, the PPWR will gradually introduce additional requirements in the coming years. These include stricter conditions for recyclability, restrictions on certain packaging formats, minimum percentages of recycled material, and reuse targets. By identifying now which future requirements are relevant to the packaging portfolio, there will be sufficient time to carefully prepare the necessary adjustments in design, procurement, and collaboration with supply chain partners.

Want to learn more about the PPWR?

Would you like to know what the PPWR specifically means for your packaging portfolio and supply chain position? Contact one of our specialists or click below.
Want to talk more? Get in touch

Sources

Regulation (EU) 2025/40 of the European Parliament and of the Council of December 19, 2024, CELEX:32025R0040, OJ L 2025/40, January 22, 2025.

Commission Guideline C(2026)3702 / OJ C/2026/3084, June 5, 2026 (33 topics, non-binding).

Commission FAQ KH-01-26-006-EN-N, march 30, 2026 (edition 1).

Delegated Decision (EU) 2026/429, OJ L_202600429 (exemption for pallet wrap/strapping).

Written by

Max van der Wal

Max van der Wal

Consultant
In a world of complex (environmental) laws and regulations, I provide clarity and coherence based on my experience in Brussels.