New Obligations for Packaging Producers from 12 August 2026

The new Regulation (EU) 2025/40 on Packaging and Packaging Waste(PPWR) will become applicable from 12 August 2026 and will fundamentally reshape the rules governing packaging and packaging waste management across the European Union.

The Regulation introduces directly applicable requirements for packaging producers, importers, distributors and online sellers placing packaging or packaged products on the EU market. The new obligations go beyond packaging labelling and also cover technical documentation, conformity assessment, environmental claims and producer responsibility for the accuracy of information provided.

For producers of packaging and packaged products, the coming months will be crucial for identifying areas requiring adjustments of internal processes, documentation and packaging solutions themselves.

The objective of the PPWR is to improve sustainability, recyclability, traceability, and harmonisation of packaging rules throughout the EU. At the same time, the Regulation significantly strengthens conformity assessment and market surveillance requirements.

1. Mandatory Identification of the Producer and Importer on Packaging

One of the most significant new obligations effective from August 2026 will be the mandatory identification of economic operators directly on the packaging.

According to the PPWR, packaging must contain:

Producer information (Article 15)

- the name of the producer,

- the registered trade name or trademark,

- the postal address at which the producer can be contacted,

- a type number, batch number, serial number or another element enabling identification of the packaging.

Importer information (Article 18)

- the name orregistered trade name or trademark,

- the postaladdress at which the importer can be contacted.

Distributor obligations (Article 19)

Before making packaging available on the market, the distributor must verify that:

- the producer subject to Extended Producer Responsibility (EPR) obligations for packaging is registered in the producer register,

- the packaging isproperly labelled,

- the producer andimporter have complied with the requirements under Articles 15 and 18.

The purpose of this obligation is to ensure higher product traceability and clear identification of the responsible economic operator within the supply chain.

Packaging Labelling Requirements

The o bligation to label packaging is regulated under Article 12 and will become effective in August 2028.

Packaginglabels will include:

- information on the material composition of the packaging,

- harmonised pictograms,

- information enabling consumers to correctly sort packaging waste.

Together with harmonised labelling of collection containers (Article 13), these measures aim to unify waste sorting systems across the EU, reduce sorting errors and improve recyclability of materials.

2. Restrictions on PFAS and Heavy Metals

From 12 August 2026, strict limits on certain substances in packaging will apply(Article 5).

ThePPWR introduces limits for PFAS substances in food-contact packaging:

- 25 ppb for individual non-polymeric PFAS,

- 250 ppb for thesum of non-polymeric PFAS,

- 50 ppm for totalfluorine content covering both polymeric and non-polymeric PFAS.

In addition, the combined concentration of lead, cadmium, mercury, and hexavalent chromium must not exceed 100 mg/kg.

Although restrictions on heavy metals already existed under previous legislation, thePPWR introduces stricter compliance control and enforcement requirements.

3. EU Declaration of Conformity

FromAugust 2026, every packaging type must be accompanied by an EU Declaration of Conformity (Articles 38, 39 and Annex VII).

The producer will be responsible for preparing and issuing the declaration, confirming that the packaging complies with the PPWR requirements, particularly Articles 2, 3 and 4 and guaranteeing compliance with Articles 5 to 12 applicable to the relevant packaging.

This includes requirements relating to substances in packaging, recyclability, recycled content, packaging minimisation, packaging labelling, reusable packaging requirements.

The producer must ensure that this documentation is available before the packaging is placed on the market.

The Declaration of Conformity must be supported by technical documentation containing in particular:

- packaging specifications (composition, description, intended use, conceptual design, manufacturing drawings),

- test reports.

Retention period for documentation:

- m5 years forsingle-use packaging,

- 10 years for reusable packaging.

Packaging that does not comply with the Regulation may no longer be placed on the EU market after the applicable transitional periods expire.

4. Registration in Extended Producer Responsibility (EPR) Systems

The PPWR also strengthens requirements relating to Extended Producer Responsibility(Articles 44 and 45).

Producers will be required to register in each Member State where they place packaging on the market for the first time.

This obligation will be particularly important for online sellers and companies operating across multiple EU Member States.

5. Reusable Packaging Systems

New requirements will also apply to operators placing reusable packaging on themarket (Article 26 et seq. and Annex VI).

From August 2026, it will be necessary to ensure a functioning system for collectionand return of packaging, cleaning and refurbishment, redistribution, collection points and clear consumer information.

The PPWR places strong emphasis on ensuring that reusable packaging systems operate effectively within a genuinely closed-loop reuse system.

How to Prepare for the Upcoming Changes

We recommend that packaging producers already begin to:

- review packaging labelling and identification of economic operators,

- analyse EPR obligations across individual EU Member States,

- assess packaging material composition and supply chains,

- prepare technical documentation and Declarations of Conformity,

- evaluate the reyclability of packaging portfolios,

- assess future obligations relating to reuse and recycled content.

The PPWR represents one of the most significant changes to European packaging legislation in recent decades. Early preparation will be essential to ensure compliance and minimise risks when placing packaging on the EU market.

‍