EU Packaging Regulation (PPWR): what applies from 12 August 2026
The Packaging and Packaging Waste Regulation (EU) 2025/40 replaced the 1994 packaging directive and applies from 12 August 2026 (Article 71). As a regulation it applies directly in every Member State. A few duties start now; most design rules follow from 2028 to 2035, often counted from implementing acts not yet adopted.
Checked against the sources on 6 October 2026
Who has duties
- Manufacturer: makes packaging or a packaged product, or has it designed or made under its own name or trademark (Article 3). It may place only conforming packaging on the market, carries out the conformity assessment, draws up the technical documentation and an EU declaration of conformity, keeps them for 5 years (10 for reusable packaging), and shows its name, postal address and electronic contact on the packaging or through a QR code (Articles 15, 38 and 39).
- Importer: established in the EU and places packaging from a third country on the market. It also shows its own name and address (Article 18).
- Producer, for extended producer responsibility (EPR): whoever first makes packaging or packaged products available in a Member State, including a seller outside the EU that sells directly to end users there (Article 3(1), point 15).
Selling directly to EU consumers from outside the EU
A seller in a third country that makes packaged products available directly to end users in a Member State is a producer there. It must appoint, by written mandate, an authorised representative for extended producer responsibility in each such Member State (Article 45(3)). Producers must be registered in each Member State before they sell there (Article 44(4)), and online marketplaces must collect the registration number and a self-certification before letting a producer sell to EU consumers (Article 45(4)).
The PPWR registers come later: each Member State has 18 months from the first implementing act to set one up (Article 44(1)). Many countries already run packaging registers under national law, so check each country you sell to.
Key dates
| Date | What applies | Article |
|---|---|---|
| 12 August 2026 | The regulation applies: conformity assessment, technical documentation, EU declaration of conformity, name and address on the packaging | 15, 38, 39, 71 |
| 12 August 2026 | Food-contact packaging may not contain PFAS above the limit values (for example 25 ppb for any single PFAS) | 5(5) |
| 12 August 2028, or 24 months after the implementing acts, if later | Harmonised label showing the material composition, for sorting | 12(1) |
| 1 January 2030 | Weight and volume of packaging reduced to the minimum; no double walls, false bottoms or unnecessary layers | 10 |
| 1 January 2030, or 3 years after the methodology act, if later | Grouped, transport and e-commerce packaging: empty space ratio of at most 50 % | 24 |
| 1 January 2030 | Packaging formats listed in Annex V may no longer be placed on the market | 25 |
| 1 January 2030, or 24 months after the delegated acts, if later | All packaging designed for recycling | 6(2)(a) |
| 1 January 2030, or 3 years after the implementing act, if later | Minimum recycled content in plastic packaging: 10 % to 35 % depending on the type | 7(1) |
| 1 January 2035 | Packaging recycled at scale | 6(2)(b) |
What to do now
- Work out your role in each market: manufacturer, importer, distributor or producer.
- If you sell directly to consumers in EU countries, appoint an authorised representative for EPR in each of them and register before you sell.
- Prepare the technical documentation and the EU declaration of conformity for your packaging (Annex VII).
- Show your name, postal address and contact on the packaging or through a QR code.
- For food-contact packaging, ask your suppliers for PFAS test results.
The 50 % empty-space rule applies from 2030, not 2026. Not sure which other EU rules apply to you? Use the EU rules finder.