The European packaging landscape is on the verge of a major change: The new “Packaging and Packaging Waste Regulation” (“PPWR” – Regulation (EU) 2025/40) will take effect on 12.08.2026, following the expiration of a transition period. In principle, the PPWR applies to all packaging, regardless of whether it is used in industry, by distributors, or in retail. Even custom-designed packaging for industrial equipment generally falls within the scope of the PPWR.
What is the timeline?
The requirements of the PPWR will come into effect in stages. Starting 12.08.2026, the following obligations will apply to packaging manufacturers:
Packaging placed on the market as of this date requires an EU declaration of conformity and technical documentation.
Higher limit values for harmful substances will apply (e.g., regarding PFAS in food packaging).
Packaging must be labeled.
Thereafter, additional requirements regarding the sustainability and labeling of packaging will apply in phases, for example:
Harmonized labeling regarding material composition and the recycled content, as well as requirements for the void ratio of sales packaging, starting in 2028
Labeling regarding reusability starting in 2029
Requirements for recyclability and the minimum recycled content, as well as the minimization of weight and volume, starting in 2030
What do companies need to do?
To comply with the requirements taking effect on 12.08.2026, the following preparatory steps are necessary.
1. Clarify roles
The PPWR distinguishes between various economic actors, including “suppliers” of packaging materials, “manufacturers”, “importers”, and “distributors” of packaging; there are also “producers” of packaging, who have an extended producer responsibility. Each role entails different obligations. Determining the appropriate role can be complex and depends on the specific circumstances of each case. For example, for the “manufacturer” role, it makes a difference whether a supplier provides rigid (e.g., pallets) or flexible (e.g., cardboard boxes) packaging components. Labeling is also a key factor. Companies must first clarify their role under the PPWR to determine the obligations that apply to them.
2. Classify Products
The PPWR distinguishes between different types of packaging (sales, grouped, and transport packaging) as well as packaging components and materials. Affected companies should verify which types of packaging or pre-manufactured products they are handling. It may also be unclear (as has been the case in the past) whether an item constitutes packaging or not (Annex II of the PPWR lists positive and negative examples).
3. Implement labeling
Manufacturers must affix their name or brand, a mailing address, and a means of electronic communication to packaging they place on the market on or after 12.08.2026. In addition, packaging must bear a type, batch, or serial number. Importers of packaging are also subject to labeling requirements. Special requirements regarding environmental claims about the packaging’s properties must be observed too (in addition to the restrictions under the “EmpCo Directive”).
4. Prepare Documentation
The manufacturer’s EU Declaration of Conformity, required as of 12.08.2026, must be based on technical documentation. This includes, among other things, a general description of the packaging, designs and materials of components, a list of the applicable standards/specifications, and test reports. To prepare the documentation, the manufacturer may need information from suppliers, who are in turn obligated to provide information and documents. It is often advisable to review or amend supply contracts to establish a contractual basis for compliance with packaging regulations.
There is not much time left; affected companies should continue or urgently begin preparing for the PPWR’s entry into force. We are happy to assist you with this – please contact us.
Dr. Armin Schwabl, LL.M.
Partner, Attorney
1010 Vienna, Parkring 2
T +43 1 514 35 288
Armin.Schwabl(at)cerhahempel.com