New era for packaging under the PPWR, applicable from 12 August 2026
12 August 2026 will mark a turning point for all companies placing packaging or packaged products on the EU market. From this date, several key obligations under the PPWR, the EU's new Packaging and Packaging Waste Regulation, will become fully applicable. As a result, products with non-compliant packaging may no longer be placed on the market.
At the same time, several aspects of the PPWR remain uncertain. Questions persist regarding, among other things, who should be regarded as the actual manufacturer of packaging, as it may be argued that a participant in the supply chain that only markets packaged products could also be considered a manufacturer. Uncertainties also remain concerning the classification of certain specific packaging types. Consequently, companies must not only comply with the new requirements but also review their existing processes, responsibilities, and supplier relationships.
One of the most important requirements that will take effect from 12 August 2026 is the obligation to carry out a conformity assessment for all affected packaging types in accordance with the PPWR. This includes, for example, verifying PFAS concentration limits for food-contact packaging, identifying substances of concern, and assessing reusability. Companies qualifying as manufacturers must prepare technical documentation covering these requirements, which must be available before the packaging is placed on the market. In addition, an EU Declaration of Conformity must be issued for all relevant packaging. These documents must be made available to the authorities within 10 days upon request.
In relation to food packaging, it is also important to highlight an additional requirement that, while not directly linked to the PPWR, may impose further obligations on companies manufacturing food packaging materials. Products (packaging materials) intended to come into contact with food, or used for packaging food, may fall within the scope of the food chain supervision fee. As a result, affected companies may be required not only to ensure packaging compliance but also, where the relevant conditions are met, to fulfil reporting and fee payment obligations.
Based on the above, it can be concluded that companies operating in the EU will face significant and multi-layered administrative challenges as the PPWR enters into force. In practice, the most important immediate task is for companies to map their packaging portfolios, identify which packaging types and obligations fall within the scope of the PPWR, initiate structured supplier data collection processes, establish a robust documentation system, and prioritise the review of higher-risk packaging.
Our experts are happy to assist with the practical interpretation of the Packaging Regulation, the assessment of obligations related to the food chain supervision fee, as well as the review and development of corporate processes, compliance frameworks, and documentation systems.
