PPWR questions, answered
From 12 August 2026 the Packaging and Packaging Waste Regulation applies directly in all 27 member states, with obligations staggered through to 2040. These are the questions that decide whether it reaches your packaging, and when. The answers on authorised representatives reflect national law as at 29 September 2026.
What is the PPWR?
The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, is the EU law that replaces the old Packaging and Packaging Waste Directive. Because it is a regulation rather than a directive it applies directly in every member state, without national transposition, so the same rules bite in all 27 countries at once.
When does the PPWR apply?
It was adopted in December 2024 and applies from 12 August 2026. Individual obligations are then staggered through to 2040: bring-your-own-container for take-away food and drink from 12 February 2027, the reusable take-away offer and minimum empty space in sales packaging from 12 February 2028, harmonised labelling from 12 August 2028, the Grade C recyclability floor, recycled-content and reuse targets and the 50% empty-space cap from 1 January 2030, recyclable at scale from 1 January 2035, and higher recycled-content targets from 1 January 2040. Several of these dates move later if the Commission act they depend on is late.
Which duties bite on day one, 12 August 2026?
Seven business duties have applied since 12 August 2026: the PFAS limits for food-contact packaging (Article 5(5)); the heavy-metal limit of 100 mg/kg (Article 5(4)); conformity assessment, technical documentation and the Declaration of Conformity (Article 15); registration in each member state (Article 44); extended producer responsibility (Article 45); the ban on misleading sustainability labels (Article 12(8)); and the re-use system duties for reusable packaging (Articles 26 and 27). The Article 6 design-for-recycling requirement does not apply until 1 January 2030 at the earliest. The next business deadline is 12 February 2027, when take-away food and drink sellers must let customers bring their own container (Article 32).
Does the PPWR apply to small businesses?
Yes. There is no general small-business exemption. The core duties, substance limits, recyclability, recycled content, labelling and registration, apply regardless of company size. A small number of targeted carve-outs exist, such as the micro-enterprise exemption from the reuse targets in Article 29(13), but they are exceptions to specific articles rather than a blanket exemption.
Does the PPWR apply to my business if I am outside the EU?
If you place packaging or packaged goods on the EU market, yes. Who carries the EPR duties depends on who you sell to. If you sell to an EU importer or reseller who passes the goods on unchanged, they are the producer in their market. If you supply end users in a member state directly, you are the producer there, and from 12 August 2026 Article 45(3) requires you to appoint an authorised representative for EPR in each such state. Member states may also require one from non-EU producers more generally, and France and Spain require one from every producer not established there.
What is the Article 21 own-name rule?
If your brand, name or trade mark appears on packaging that a contract packer or co-manufacturer produces for you, Article 21 treats you as the manufacturer of that packaging. The compliance duties, and the paperwork behind them, are yours rather than your packer's. This is the single most commonly missed obligation for brand owners.
What are the empty-space rules?
Article 24 caps empty space at 50% in grouped, transport and e-commerce packaging, and Article 10 requires packaging to be minimised to the smallest weight and volume that still does the job. The 50% cap applies from 1 January 2030, or three years after the Commission implementing act on the calculation method enters into force, whichever is later. The Article 10 minimisation duty also runs from 1 January 2030.
What labelling will the PPWR require?
Article 12 requires harmonised material-composition labelling so consumers can sort packaging correctly. It applies from 12 August 2028, or 24 months after the Commission adopts the relevant implementing act, whichever is later. Reusable-packaging marking follows from 12 February 2029 on the same mechanism. Because both dates depend on an implementing act, the trigger is the mechanism rather than a fixed calendar date.
What are the penalties for non-compliance?
Article 68 leaves penalties to member states, which must lay down their national rules and notify them to the Commission by 12 February 2027. That means the size and shape of a penalty depends on which member state is enforcing, and non-compliant packaging can also simply be refused market access.
Can I keep selling packaging printed under the old rules?
There is a transitional bridge. Article 70 allows packaging that complies with the previous Packaging and Packaging Waste Directive marking rules to continue being placed on the market for a limited period after the PPWR applies. It is a continuity window rather than an indefinite sell-through, so it should be planned around, not relied on.
Is this report legal advice?
No. It is a screening of your answers against the regulation: a fast, cited map of what appears to apply to packaging like yours, with every point referenced to its article so you or your adviser can check it against the text.
Who is the report for?
Producers, importers, brand owners, distributors and non-EU sellers who place packaging on the EU market and need to know what the PPWR requires of them specifically, rather than reading 200 pages of regulation to find out.
Do I get the supplier letters?
Yes. The report includes ready-to-send request letters for the Declaration of Conformity, the PFAS Certificate of Analysis and heavy-metal documentation, pre-filled for your packaging so you can send them to your suppliers as they are.
How current is the report?
It is built on Regulation (EU) 2025/40 as adopted, and it states the date the rules were last checked. Where an obligation depends on a Commission implementing act that has not been adopted yet, the report says so and gives the mechanism instead of inventing a date.
What do you do with my inputs?
They are used to generate your report and nothing else. We do not sell data or share your packaging details. See the privacy policy for the full position.
Which of these apply to your packaging?
The free check takes 90 seconds and tells you whether the PPWR reaches your packaging at all. The full report maps every obligation that applies to you, cited to its article, with the supplier letters ready to send.