The first obligations of Regulation (EU) 2025/40 on packaging and packaging waste (Packaging and Packaging Waste Regulation, PPWR ) have been in force since 12 August 2026. This text replaces the historic Directive 94/62/EC and redraws, uniformly in all Member States, the rules on the design, placing on the market and end-of-life of packaging.Since it is a regulation and not a directive, the new rules are directly applicable in every EU country , without the need for national transposition: a substantial difference compared to the past, which reduces the fragmentation between the laws of individual Member States and strengthens the single market for packaging.
The PPWR entered into force on 11 February 2025 , but its concrete application is staggered over a multi-year horizon that reaches up to 2040.
August 12, 2026 represents only the first stage of this journey.
What changes immediately (August 12, 2026)
The new provisions that apply from now on mainly concern substances, documentation and the responsibilities of operators:- Restriction on PFAS in food contact packaging. Food packaging (takeaway containers, fast food wrappers, microwave popcorn bags, baking paper, pizza boxes, etc.) containing perfluoroalkyl substances exceeding established limits can no longer be placed on the EU market. The goal is to reduce exposure to these persistent substances, known as "forever chemicals," for both consumer health and the environment.
- EU Declaration of Conformity . Manufacturers must prepare this document before placing packaging on the European market, certifying compliance with the Regulation's requirements.
- Technical documentation and markings. Information and markings that allow the manufacturer or importer of the packaging to be identified and contacted are now mandatory.
- Harmonized definitions . The PPWR standardizes the definitions of manufacturer, producer, importer, and distributor at EU level, with differentiated obligations depending on the role played in the supply chain (a company can hold multiple roles simultaneously).
- Registration for Extended Producer Responsibility (EPR). It remains necessary to continue complying with existing national EPR regimes: the PPWR is currently added as an additional level of European compliance, without replacing them.
- Packaging already in circulation : Packaging placed on the market before August 12, 2026, can, in principle, continue to circulate; packaging placed after this date must comply with the new requirements.
The next stages: 2028 and 2030
The PPWR timetable provides for the gradual entry into force of further obligations:- From 2028, a harmonized labelling system will come into force across the EU , designed to facilitate separate collection and increase recycling and composting efficiency. A QR code with additional information on the packaging's composition and collection methods is also planned, replacing the current system based on Decision 97/129/EC.
- From 2030, most of the substantive obligations will come into force , including:
- limits on empty space in packaging and targets for reducing waste generated;
- reuse targets for specific packaging categories;
- restrictions on certain small formats of single-use plastic , for example in the hotel and restaurant sector;
- requirement that all packaging be recyclable;
- mandatory minimum content of recycled plastic in plastic packaging;
- EPR contributions modulated according to the recyclability class (AC classes) and priority access to recycled materials for producers, in proportion to the packaging placed on the market.
Why it's a good idea to take action now
Although the most challenging deadlines are in 2028 and 2030, operators who currently place packaging on the EU market, import it from non-EU countries, or distribute it already have to deal with new documentary and substantive requirements.Areas to focus on in the short term:
- Understand your role in the supply chain (manufacturer, importer, distributor, producer for EPR purposes) because your obligations change accordingly.
- Check for the presence of PFAS in food contact packaging and, if necessary, replace suppliers or materials.
- Prepare the EU Declaration of Conformity and organize the supporting technical documentation.
- Centralize packaging data , currently often scattered across suppliers, emails, and spreadsheets, into a single dossier that includes regulatory references, market rules, and evidence of compliance.
- Continue to comply with the national EPR regimes already in force, while simultaneously monitoring the indications of the national authorities, which in 2026 remain the operational reference alongside the PPWR.
- Those importing from non-EU countries should ensure that the required documentation is ready before the goods arrive at customs to avoid delays or disputes.