PPWR 2026: What the Packaging Regulation Requires from 12 August

The European Union generates more than 80 million tonnes of packaging waste every year, and that volume has been growing faster than GDP for a decade. The Regulation (EU) 2025/40, known as the PPWR (Packaging and Packaging Waste Regulation), is the response: it replaces Directive 94/62/EC and, unlike it, needs no national transposition. The same text, with the same obligations, has applied in Madrid, Berlin and Paris from day one.

12 August 2026 is now fixed in the calendar of any company that manufactures, imports or distributes packaging in the EU, but one thing needs to be clear from the start: that date is not the end of the process, it's the first stop on a timeline that runs to 2038. And not everything circulating about the Packaging and Packaging Waste Regulation has a firm date yet, nor are all the figures being repeated the ones that actually made it into the final text. The A, B and C recyclability grades, for example, depend on a delegated act the Commission has not yet adopted. Separating what is already enforceable from what is still pending technical development, and correcting a figure that keeps circulating incorrectly, is exactly the purpose of this article.

1. Regulation, not a directive: what changes for your company

The PPWR entered into force on 11 February 2025, twenty days after its publication in the Official Journal of the European Union, and has applied in full since 12 August 2026, after an eighteen-month transitional period. The difference with the old directive isn't just about dates: being a regulation, it applies directly and uniformly across all 27 Member States, with no room for each country to interpret or adapt it in its own way. If your company sells the same packaging in Spain, France and Germany, the obligations the Packaging and Packaging Waste Regulation imposes on it are identical in all three markets.

The regulation covers every type of packaging, regardless of material, and whether it is full or empty: sales packaging, grouped packaging, transport packaging, service packaging (such as a takeaway coffee cup) and composite packaging. It also covers labels attached to loose fruit, seals, hangers sold with garments and coffee capsules, among many other items that previously sat in a grey area. According to European Commission figures, packaging accounts for 40% of all plastic and 50% of all paper consumed in the EU, and equals 36% of the municipal solid waste generated.

2. SMEs and exporters outside the EU: no one is exempt

The PPWR does not set out a general exemption for small businesses. Micro-enterprises do have some lighter obligations regarding labelling and formats, but remain subject to the regulation's core obligations: Declaration of Conformity, substance restrictions and EPR registration.

If your company is based outside the EU and exports packaged product to the European market, you normally cannot act as the importer yourself for PPWR purposes unless you have an entity established in the Union. Typically you will need an authorised representative to handle registration and Extended Producer Responsibility compliance in the destination country, similar to the representative figure already familiar to exporting companies from other EU product regulations.

The consequence of not having this sorted out isn't just an administrative penalty: non-compliant packaging can be held directly at European customs, even before the recipient receives it.

3. What the PPWR requires from 12 August 2026

These are the obligations that already have a firm date and do not depend on any further technical development:

• EU Declaration of Conformity (DoC). No packaging may be placed on the market without it. It certifies that a specific type of packaging complies with the regulation in terms of recyclability, recycled content, reuse, labelling and substance restrictions. The supporting technical documentation must be kept for 5 years for single-use packaging and 10 years for reusable packaging. Conformity assessment is based on internal production control, i.e. a self-declaration by the manufacturer: the PPWR does not require a notified body to certify the packaging. Only if you voluntarily choose to use tests, measurements or calculations carried out by an accredited conformity assessment body do you gain the so-called presumption of conformity, extra backing in the event of an inspection, but not a mandatory step.
• Heavy metal restriction (Article 5(4)). The sum of lead, cadmium, mercury and hexavalent chromium may not exceed 100 mg/kg (0.01%) in any packaging.
• PFAS restriction in food-contact packaging (Article 5(5)). Packaging intended to come into contact with food may not exceed 25 ppb for any individual PFAS, nor 250 ppb for the sum of all of them. There is also a third, broader threshold of 50 ppm for total PFAS including polymeric PFAS, which are excluded from the two limits above. In practice, if the packaging's total fluorine content is below 50 mg/kg, it is considered compliant with no further testing needed; above that threshold, the manufacturer or importer must be able to show, on request, what proportion of the fluorine corresponds to PFAS and what does not. This directly affects fluorinated-coated paper cups, pizza boxes or grease-barrier takeaway food packaging.
• Ban on deceptive design. From 12 August 2026, packaging cannot be manufactured with double walls, false bottoms or other features whose sole purpose is to increase the perceived volume of the product.
• Registration in the national register of each Member State where you place packaging on the market, together with the applicable Extended Producer Responsibility (EPR).

All of these obligations already exist, with no pending technical conditions. They don't depend on the Commission publishing anything further: they are required because the regulation's own text sets them out in that level of detail.

One important clarification, because this is the figure most often repeated incorrectly: the numerical limit on empty space in grouped, transport and e-commerce packaging is not 40%, nor does it take effect in August 2026. That figure comes from a 2022 legislative proposal that did not make it into the final text. The approved regulation sets a cap of 50%, applicable from 1 January 2030, or three years after the implementing act defining the calculation methodology enters into force, whichever is later. What does already apply, from August 2026, is the general principle of minimising packaging to the functional minimum and the ban on deceptive design covered above; the numerical cap comes later.

4. PPWR recyclability grades (A, B, C): dates not yet final

This is where more care is needed, because 1 January 2030 is often cited as if it were a fixed date, and the system is also often described with grades from A to E. Neither of those is entirely accurate. The final regulation defines only three recyclability grades (A, at least 95% recyclability by weight; B, at least 80%; and C, at least 70%), not five: any packaging below the C threshold simply falls outside the market, with no formal grade D or E, even though some older sources still mention them.

The design-for-recyclability principle (Article 6(1)) is already enforceable from 12 August 2026. What doesn't have a firm date is the exact bar: Article 6(2)(a) requires that from that date only grade C or higher packaging be placed on the market, but that obligation takes effect on 1 January 2030 or twenty-four months after the Commission adopts the delegated act setting the assessment methodology, whichever is later. That delegated act, provided for in Article 6(4), has a legal deadline of 1 January 2028, and until then there is no harmonised criterion for assigning a grade to a given piece of packaging.

The same applies to the recycled content targets for plastic: under the text itself, they apply from 1 January 2030, or three years after the implementing act under Article 7(8) enters into force, whichever is later. This is a caveat many sources leave out, and it can push back the real timeline if the Commission is slow to approve the methodology.

There is, however, an early clue as to the direction that methodology will take. On 30 June 2026 the Commission adopted the Implementing Decision (EU) 2026/1425, which sets out how to calculate, verify and report recycled content in single-use plastic beverage bottles. It doesn't stem from the PPWR but from Directive (EU) 2019/904 on single-use plastics, but it signals the approach to come: it recognises mass balance for chemical recycling and restricts counting plastic recycled outside the EU until 21 November 2027, with exceptions for certain third countries. It's the most concrete sign to date of how the Commission plans to resolve this type of methodology, even though the specific act under Article 7(8) of the PPWR has still not been published.

5. The full timeline, from 2025 to 2038

*For recyclability grades, recycled content and the empty-space cap, subject to the prior adoption of the corresponding delegated and implementing acts.

6. Mandatory recycled content in plastic packaging

Once the methodology is settled, these are the minimum percentages of post-consumer recycled plastic set by the regulation, calculated as an annual average per manufacturing plant and per packaging type, not as a company-wide average:

For chemical recycling, where the recycled molecule is indistinguishable from virgin material and cannot be physically segregated, the regulation provides for a mass balance system: a percentage of recycled content can be claimed through accounting allocation, provided it is certified by an audited chain-of-custody system and there is no double counting. The exact calculation and verification methodology also depends on the implementing act under Article 7(8).

7. Reuse and B2B packaging

Here it's worth distinguishing two types of obligation, since they don't arrive at the same time. If your company already uses reusable packaging, taking part in a formal reuse system (with organised collection, cleaning and redistribution) is enforceable from August 2026. What doesn't arrive until 2030 are the mandatory percentages: at least 40% of transport packaging will have to be reusable within a system, and packaging used to send goods between sites of the same company or to another company within the same Member State will have to be 100% reusable. The HORECA sector and takeaway food and drink packaging have their own reuse-target timeline. Cardboard packaging is excluded from these targets.

The 2030 timeline itself has already shifted once: on 25 February 2026 the Commission adopted a delegated decision exempting pallet wrap and strapping from the 100% intra-company reuse target, because of the disproportionate costs it posed for logistics. They still count towards the general 40% target, only exempted from that stricter 100%. It's another example of the PPWR's technical framework still shifting even after the general timeline has been set.

8. Who is responsible: manufacturer, importer and distributor

The PPWR distinguishes roles with different obligations, and confusing them is a common mistake:

• Manufacturer, the party that places the packaging on the market under its own brand, even if it does not physically produce it. If you buy plain boxes from a supplier and put your logo on them, you are the manufacturer for PPWR purposes, and the technical documentation and Declaration of Conformity are your responsibility.
• Importer, the entity established in the EU that verifies that the manufacturer outside the Union has met its obligations before the packaging enters the European market.
• Distributor, the party that markets packaging already placed on the market by another operator, without altering it.

The same company can take on several of these roles at once depending on the product, which multiplies the points where documentation can be missing if there is no centralised process controlling it.

9. How to manage PPWR compliance step by step

The real problem behind the PPWR isn't just knowing what each date requires, but that this information tends to be scattered: packaging composition in an email with a supplier, EPR registration on a separate portal, the Declaration of Conformity in a shared folder, and the 2030 timeline living in one person's head. Retexcycle PPWR brings all of that together in a single system:

Step 1. Centralised diagnosis. The PPWR self-assessment brings your entire packaging portfolio and current situation together in a single 16-question survey, and returns one PDF report with your compliance status and the gaps found, instead of having to cross-check several sources to know where you stand.

Step 2. One record per packaging format. Each format is recorded together with the role you play in it (manufacturer, importer or distributor) and its material composition, without needing to ask procurement, sustainability and the supplier separately.

Step 3. Consolidated documentation. The Declaration of Conformity and its supporting technical documentation sit alongside the rest of the packaging information, with the correct retention periods (5 or 10 years depending on the type), instead of being scattered across emails and loose folders.

Step 4. One single version of the legal timeline. As this article explains, a large part of the 2030 timeline still depends on delegated acts that haven't been adopted. Retexcycle PPWR keeps track of what is already enforceable versus what remains pending, so the whole company works from a single version of the timeline instead of differing interpretations.

The result: when an inspection comes, or a customer asks for evidence on a specific packaging item, everything needed (composition, Declaration of Conformity, technical documentation and the responsible party) is at hand, without having to reconstruct it across several teams and tools.

What to do this week

• Make an inventory of every packaging format you place on the market, including those not facing the end consumer.
• Identify which role you play (manufacturer, importer, distributor) for each of those formats.
• Start asking your packaging suppliers for material composition and information on PFAS and heavy metals, even though the formal deadline is August 2026.
• Confirm your registration in the national register of each Member State where you place packaged product on the market.
• Don't treat the 2030 timeline as final: check periodically whether the Commission has already published the delegated acts on recyclability grades.

If you'd rather see it applied directly to your own packaging portfolio, you can request a demo with your own data.