From 12 August 2026, packaging compliance becomes an operational requirement
Regulation (EU) 2025/40 (PPWR) — Packaging and Packaging Waste Regulation
From 12 August 2026, Regulation (EU) 2025/40 (PPWR) becomes applicable, fully replacing Directive 94/62/EC and introducing a uniform regime governing packaging across its entire life cycle: design, manufacture, placing on the market, labelling, reuse and end-of-life. The Regulation is not limited to packaging manufacturers: it affects any business that places packaged products on the market.
WHO IS AFFECTED
- Manufacturer – Assesses conformity, prepares the technical documentation and draws up the EU Declaration of Conformity (Art. 39, Annex VIII).
- Importer – Verifies that packaging from third countries meets EU requirements before it is placed on the market.
- Distributor / Logistics provider – Ensures that transport, storage and handling do not compromise packaging conformity along the supply chain.
- Producer – The entity first making packaging available on the national market: must register with the national ERP register, on pain of a marketing ban.
KEY OPERATIONAL OBLIGATIONS FROM 12 AUGUST
- EU Declaration of Conformity — mandatory document drawn up by the manufacturer in accordance with Annex VIII, supported by consistent technical evidence (Annex VII).
- Substantial restrictions on packaging intended for food contact — PFAS ban above threshold (25 ppb per targeted substance, 250 ppb cumulative, 50 mg/kg total fluorine) and a 100 mg/kg limit on the combined concentration of lead, cadmium, mercury and hexavalent chromium.
- Record-keeping — the declaration and supporting technical documentation must be retained for 5 years (single-use packaging) or 10 years (reusable packaging) from placing on the market.
- Supply-chain information flow — the manufacturer signs the declaration but cannot certify conformity alone: it depends on continuous data from suppliers and material producers.
NOTE — SPECIAL CASES AFFECTING THE “MANUFACTURER” QUALIFICATION
- Own-brand goods: a party that has packaging designed or made by a third party and places it on the market under its own name or trademark is the manufacturer, not the material producer (typical of retail private-label goods).
- Micro-enterprises: if the brand owner is a micro-enterprise (< 10 employees, turnover/balance sheet ≤ €2 million) and the packaging supplier is established in the same Member State, the declaration obligation falls on the supplier.
RECOMMENDED NEXT STEPS
Compliance activities — reviewing material composition, gathering technical evidence, revising supplier contracts and correctly identifying your role within the supply chain — require significant lead time. We remain available to map your company’s regulatory exposure and to prepare the required documentation.
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