Food-contact packaging
PFAS restricted since 12/08/2026: limits of 25, 250 ppb and 50 mg/kg (art. 5.5).
The Packaging Regulation (PPWR) is already in force. Do you know which obligations apply to you?
Regulation (EU) 2025/40 (PPWR) is enforceable from 12 August 2026 for anyone who manufactures, commissions, fills, imports, distributes, transports or sells packaging in the EU.
21 possible roles, 34 packaging typologies, 100 different obligations. Discover yours in three minutes.
The problem
It depends on who you are,
It depends on who you are,
where you sell and what you package
These three factors change your obligations under the PPWR,
not your sector or the size of your company.
Who you are
Manufacturer or supplier?
If you decide the design or sell under your own brand, you are a manufacturer. If you sell under the customer's brand, you are a supplier. This difference changes the entire technical file.
A distributor can become a manufacturer
If you place the packaging on the market under your own brand, or modify it in a way that affects its conformity, the law treats you as a manufacturer, with all the corresponding obligations (art. 21).
Where you sell
Producer per Member State
Extended producer responsibility (EPR) registration is determined packaging by packaging and country by country, not once for the whole EU.
A different representative for each country
If you sell directly to end users in a Member State where you are not established, you need an authorised representative there for EPR purposes (art. 45.3).
What you package
One package, several typologies at once
The same packaging can be sales packaging, rigid plastic and food-contact all at once, each dimension with its own obligations. Without cataloguing it properly, it's easy to miss one.
Reusable requires nine criteria at once
For packaging to count as reusable, it must meet all nine criteria of art. 11 at once: design, rotations, hygiene, reconditioning and more. If it fails one, it doesn't count.
Already enforceable
Three things you should already have ready
12 August 2026 is not a future date: it has already passed. This is what the Regulation has required since that day.
Technical file and DoC
Technical documentation and EU Declaration of Conformity for each type of packaging (arts. 15 and 39).
EPR registration
Extended producer responsibility, mandatory before placing on the market (art. 44).
PPWR Compliance
A compliance hub built to your measure, not a generic checklist
You answer the questionnaire once. The engine detects your roles and typologies, filters the obligations that genuinely apply to you and activates only the modules you need. No managing 100 obligations when most don't apply to you.
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auto_awesome
Automatic detection
The engine cross-references your answers with the Regulation's 100 obligations and discards the ones that don't apply to you, without you having to read the legal text.
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tune
Only what applies to you
Only the modules and obligations that apply to your case are activated, with tasks and deadlines already created.
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fact_check
Evidence always ready
Each obligation comes with its deadline and the evidence you'll be asked for in an inspection, not just a list of pending tasks.
PPWR Compliance
What PPWR Compliance includes
Complete the full questionnaire, get every obligation with its evidence and date, and manage files, declarations and suppliers in one place.
Dashboard
Compliance status, alerts and upcoming milestones.
Profile and roles
Activity questionnaire, your PPWR roles, typologies and the Member States where you operate.
Packaging catalogue
Packaging references with function, material, regime and gravimetric composition.
Design requirements
Assessment by reference: substances, recyclability, recycled content, compostability, minimisation, reuse and empty space.
Technical file
Technical documentation for each type of packaging, kept for 5 or 10 years depending on the case.
EU Declaration of Conformity
Generation and filing of the DoC for each type of packaging.
Suppliers and operators
Supplier information, fluorine testing and identification of who comes before and after you in the chain.
Batches and traceability
Batch or series records linked to each reference, its DoC, destination and customer.
Labelling and claims
Harmonised label, reuse QR code, recycled content, digital EPR symbol and claims.
Reuse and empty space
Empty space ratio, reuse targets, refill systems and HORECA.
EPR and producer registration
Registration per Member State, annual reporting, contributions and authorised EPR representative.
Calendar and tasks
Tasks generated per obligation, 2026-2040 milestones and corrective actions.
Calendar
It's not one deadline, it's several
In force
12/08/2026
General application: design, PFAS, EPR, technical file and DoC.
Pending
12/02/2027
HORECA: consumer's own container. Digital EPR symbol.
Pending
12/02/2028
Compostable packaging mandatory in certain formats. Minimum empty space in sales packaging.
Pending
01/01/2029
Deposit-return system with 90% collection.
Pending
01/01/2030
Recyclability grades, minimum recycled content, 50% empty space, reuse targets.
Pending
01/01/2035
Large-scale recycling enforceable; review of the exemptions in art. 6.
Pending
01/01/2038
Only packaging with recyclability grade A or B is allowed.
Pending
01/01/2040
Minimum recycled content of 50-65% depending on material; reuse targets of 70%, 25% and 40%.
Frequently asked questions
What you ask us most about the PPWR
What is the PPWR?expand_more
It is Regulation (EU) 2025/40 on packaging and packaging waste. It replaces the old Directive 94/62/EC and, being a regulation (not a directive), it applies directly in all 27 Member States without each country needing to transpose it into its own legislation.
What types of packaging does the PPWR apply to?expand_more
To all of them: the Regulation applies to all packaging, regardless of the material it is made from, and to all its waste, whether from industry, retail or wholesale trade, offices, services or households (art. 2). No packaging or sector is excluded by default.
When does it come into force?expand_more
It entered into force on 11 February 2025. Most obligations (conformity assessment, PFAS, technical file, DoC, EPR registration) are enforceable from 12 August 2026. The rest are phased in through 2040, with milestones in 2027, 2028, 2029, 2030, 2035 and 2038.
Who does it affect?expand_more
El Reglamento define legalmente 7 categorías de "operador económico": fabricante, proveedor, importador, distribuidor, representante autorizado, distribuidor final y prestador de servicios logísticos (art. 3.12). En la práctica, según lo que hagas con cada envase, puedes encajar en hasta 21 roles distintos con obligaciones propias (productor, usuario final, operador de reutilización, etc.).
What happens if I don't comply? Are there fines?expand_more
Sí. Cada Estado miembro debe tener su propio régimen sancionador en vigor antes del 12 de febrero de 2027, con sanciones "efectivas, proporcionadas y disuasorias" (art. 68). Para los artículos 24 a 29 (reutilización y espacio vacío) la ley exige específicamente multas administrativas. El Reglamento no fija importes concretos: eso lo decide cada país.
Are there exemptions for SMEs or microenterprises?expand_more
Sí, hay varias reglas especiales. La más relevante: si encargas el diseño o fabricación de un envase con tu marca a un proveedor que es microempresa y está en tu mismo Estado miembro, la ley considera "fabricante" al proveedor, no a ti (art. 3.13). También hay matices de microempresa en varias obligaciones de reutilización y RAP.
Does Compliance PPWR replace Ecoembes or my PRO?expand_more
No. The PPWR coexists with extended producer responsibility (EPR), which in Spain is managed by collective schemes such as Ecoembes. Registration, annual reporting and the payment of contributions follow their usual national channel. PPWR Compliance organises the documentation and evidence the Regulation itself requires (technical file, DoC, labelling, obligations calendar): it does not replace registration or payment with your PRO, it just keeps everything organised so nothing slips through.
What happens to packaging already manufactured before August 2026?expand_more
The Regulation repeals the old Directive 94/62/EC as of 12 August 2026, but with a transitional regime: several of its articles remain applicable until specific dates (31/12/2028 and 31/12/2029, depending on the requirement) while the delegated and implementing acts that replace them are adopted (art. 70). Not everything changes overnight on the same day.
Does it affect me if my company is outside the EU?expand_more
Sí, si vendes envases o productos envasados dentro de la UE. La figura del "importador" (art. 3.17) es siempre una persona o empresa establecida en la Unión que introduce el envase desde un tercer país, así que si tu empresa está fuera, necesitas un importador o un representante autorizado establecido en la UE que asuma esas obligaciones en tu nombre.
How does the PPWR differ from the EUDR?expand_more
They are two different European regulations, and both can apply to you at once. The EUDR regulates deforestation in the supply chain of certain raw materials (wood, cocoa, coffee, soy, among others) before they reach the EU. The PPWR regulates the packaging itself: its design, materials, labelling and end of life, regardless of what it contains. If you export or import packaged products made with raw materials covered by the EUDR, it's common to need to comply with both regulations in parallel.
How do I know exactly which obligations apply to me?expand_more
It depends on your role and the typology of your packaging, not your sector. The self-assessment questionnaire (16 yes-or-no questions) detects your real roles and typologies and filters, out of the Regulation's 100 obligations, the ones that genuinely affect you.
Already know your role? Let's talk about how to manage it
PPWR Compliance is in development. Tell us about your case and the packaging you work with, and we'll tell you the next steps.