PPWR: What Changes for Packaging as of Today (12 August 2026)

12 August 2026 marks the first major milestone of the new European Packaging and Packaging Waste Regulation (PPWR) (Regulation (EU) 2025/40). From this date, most of its provisions become directly applicable in all EU Member States, including Slovakia.

As this is a regulation, rather than a directive, it does not require national transposition. The rules therefore apply directly and uniformly across all EU countries from day one.

This article focuses exclusively on the provisions that take effect today (12 August 2026). Other widely discussed PPWR requirements, such as harmonised packaging labelling, minimum recycled content and reuse targets, will be introduced gradually between 2027 and 2040.

What Applies from 12 August 2026?

1. PPWR Replaces the Previous Packaging Directive

As of today, the PPWR replaces the former Packaging and Packaging Waste Directive (94/62/EC). While certain provisions of the Directive, particularly those concerning collection and recycling, remain applicable during a transitional period until 2028–2029, from 12 August 2026 a single, harmonised regulatory framework governs all packaging placed on the EU market, regardless of the material from which it is made.

2. PFAS Ban in Food Contact Packaging

From this date, it is prohibited to place on the market food contact packaging containing so-called "forever chemicals" (PFAS – per- and polyfluoroalkyl substances) above the concentration limits established by the Regulation.

This is one of the few obligations for which the Regulation explicitly sets 12 August 2026 as the date of application without any transitional period.

This requirement mainly concerns producers and distributors of food packaging (paper, plastic and composite materials), who should obtain confirmation from their suppliers regarding the material composition of their packaging.

3. Heavy Metal Limits Continue to Apply

The Regulation maintains the existing limit for the total concentration of heavy metals in any type of packaging. The combined content of lead, cadmium, mercury and hexavalent chromium must not exceed 100 mg/kg.

This requirement already existed under the previous Directive and continues without interruption under the PPWR.

4. Mandatory Conformity Assessment, Technical Documentation and EU Declaration of Conformity

For most businesses, this is the most significant practical and administrative change.

From 12 August 2026, every type of packaging placed on the EU market must have:

• a conformity assessment carried out in accordance with the Regulation,

• technical documentation prepared and maintained demonstrating compliance with the Regulation,

• an EU Declaration of Conformity issued.

Where packaging is also subject to other EU legislation (for example, legislation governing cosmetics or medical devices), a single combined Declaration of Conformity may be prepared, provided that it clearly identifies all applicable legislation.

5. Clearly Defined Responsibilities Throughout the Supply Chain

The Regulation clearly specifies which economic operator is responsible for ensuring packaging compliance, including manufacturers, importers, distributors, online marketplace operators and fulfilment service providers.

For example, where a company markets packaging under its own brand, it is regarded as the manufacturer under the Regulation, regardless of who physically produced the packaging.

Special provisions also apply to micro-enterprises that have packaging designed or manufactured by a supplier established within the same Member State.

As of 12 August 2026, every company should therefore clearly identify its role within the supply chain and understand the obligations associated with that role.

What Does Not Apply Yet?

To avoid confusion, it is worth noting that the following widely discussed PPWR requirements will only become applicable at a later stage:

• harmonised packaging and waste container labelling - from 2027 – 2028,

• minimum recycled content requirements for plastic packaging - from 2029 – 2030,

• limits on empty space in packaging and restrictions on excessive packaging – from 2028–2030,

• packaging reuse targets and bans on selected single-use plastic packaging (e.g. individually packaged condiments in HORECA and miniature hotel toiletries) –  from 1 January 2030.

What We Recommend You Do Now

• Verify whether any of your packaging comes into contact with food and assess its PFAS content.

• Check that you have the required technical documentation and are able to issue an EU Declaration of Conformity for all packaging types you place on the market.

• Clearly identify your role within the supply chain (manufacturer, importer or distributor) and the obligations associated with it.

• Review your contracts with packaging suppliers and include contractual provisions requiring compliance with the PPWR.

This article is intended to provide a general overview of the PPWR requirements applicable from 12 August 2026 and does not constitute legal advice. If you have specific questions regarding your packaging or your obligations under the Regulation, please do not hesitate to contact us.

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