Less than a week remains before the EU Packaging and Packaging Waste Regulation (PPWR) applies. From 12 August 2026, packaging that does not meet the new requirements may not be placed on the EU market. Note in particular that even where the product itself carries CE marking, goods may still be refused at an EU border if the packaging fails PPWR requirements. This is not only a major upgrade of the EU packaging regime, it is a green threshold every exporter has to cross.

What is PPWR?

PPWR (Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40) is a newly adopted EU packaging framework. It entered into force on 11 February 2025 and its core provisions apply from 12 August 2026, replacing the Packaging and Packaging Waste Directive (94/62/EC) that has been in place for almost 30 years.

The key difference from the old directive is that, as a regulation, PPWR applies directly at EU level. It does not need to be transposed into national law and applies uniformly across all 27 Member States.

Who needs to pay attention?

PPWR covers packaging and packaging waste of all materials (plastic, paper, metal, glass, composites and so on) and all applications (industrial, commercial, consumer and transport packaging). Anyone placing packaging, or products with packaging, on the EU market — through offline distributors, third-party cross-border e-commerce platforms or standalone online stores — has compliance obligations:

Export manufacturers: as the party primarily responsible for packaging compliance, they must prepare technical documentation and a declaration of conformity (DoC) for each packaging type in the capacity of manufacturer, otherwise products cannot enter the EU market.

Cross-border e-commerce sellers: Amazon, Temu, AliExpress and other platforms already require sellers to complete packaging EPR registration in each country and upload an ERN number before 12 August. Late sellers risk delisting.

Packaging material suppliers: they must provide material composition reports and declarations of conformity to support downstream customers in drawing up DoCs and technical files.

Core requirements: what must companies do?

With 12 August as the first critical milestone, four core actions should start immediately.

1. Control hazardous substances (no stock transition period)

Heavy metals: the combined content of lead, cadmium, mercury and hexavalent chromium in any packaging must not exceed 100 mg/kg.

PFAS: in food-contact packaging, a single PFAS substance (other than polymers) must be 25 ppb or less, the sum of all PFAS substances (other than polymers) 250 ppb or less, and total fluorine 50 ppm or less.

2. Meet EPR obligations

Companies must register for extended producer responsibility in every destination country, obtain the national registration number (ERN), declare packaging volumes periodically and pay environmental fees. Non-EU companies must appoint an authorised representative established in the EU. Several cross-border platforms already require a valid ERN before 12 August, with delisting as the sanction.

3. Prepare the full documentation set

Manufacturers and importers must compile technical documentation for each packaging type and issue an EU declaration of conformity. This file is the first item customs and market surveillance authorities check during inspections; if it is missing, the packaging is treated as non-compliant. Documents must be kept for at least five years from the date the packaging is placed on the market (ten years for reusable packaging).

Note: a PPWR declaration of conformity is not a CE certificate, and PPWR does not require CE marking on packaging.

4. Apply economic operator identification rules

Packaging should clearly show traceability information such as the model, batch or serial number. Where this cannot be marked directly on the packaging, it may be provided in accompanying documents.

The manufacturer's name, registered trade name or trade mark and postal address must also be indicated, together with electronic contact details where available. If this cannot be marked on the packaging surface, a QR code or other standardised data carrier may be used instead.

What rules come next?

PPWR is not a one-off policy but a phased long-term framework. After completing the baseline work for August 2026, companies should watch the following milestones:

By 12 February 2027: the European Commission will adopt delegated acts setting minimum reuse cycles for reusable packaging. Companies should follow the drafting closely and prepare reusable packaging design and supply chains in advance.

August 2028: harmonised recycling labels, QR code labels and digital identification become fully applicable. All packaging placed on the EU market must carry clear recycling instructions and link to detailed environmental information through a digital carrier such as a QR code.

January 2030: recycled content targets and recyclability thresholds apply. Plastic packaging must meet minimum post-consumer recycled (PCR) content ratios (for example 30% for single-use beverage bottles), and packaging must reach recyclability class C or better (recycling rate of at least 70%). In addition, empty space in e-commerce, grouped and transport packaging must not exceed 50%.

January 2038: recyclability criteria tighten further, with only class A or B packaging admitted to the EU market.

2040: packaging waste reduction and recycled content targets are fully met. Measured against a 2018 baseline, packaging waste generated per capita must fall by at least 15%, and recycled content ratios rise further (for example 65% for single-use beverage bottles and 65% for other plastic packaging).

With less than a week to go before PPWR applies, the window is closing. Companies are advised to benchmark against the four core requirements now, screen for blind spots and avoid losing EU market access over packaging detail.