Countdown for Businesses
Objectives of the Packaging Regulation
The European packaging landscape is facing its most significant transformation in decades. The new EU Packaging and Packaging Waste Regulation (PPWR – Regulation (EU) 2025/40) has already entered into force. Following the expiry of the transitional period, it will become directly applicable and legally binding in all EU Member States from 12 August 2026, without the need for national implementing legislation.
The regulation aims at a drastic reduction of packaging waste and the establishment of a resource-efficient, well-functioning circular economy. For businesses, this results in an immediate need for action.
The Timeline: What Applies and When?
The requirements of the PPWR will be introduced in stages in order to allow economic operators time to adapt:
- From 12 August 2026 (Phase 1): Fundamental manufacturer obligations apply. For any type of packaging placed on the market from this date, an EU declaration of conformity must have been supported by technical documentation. In addition, stricter limits for substances of concern (e.g. PFAS in food-contact packaging) will apply immediately, alongside the first manufacturer labelling requirements.
- Expected to be introduced in stages from 2028 (subsequent phases): On the basis of implementing acts yet to be adopted, requirements will be introduced relating to: minimum levels of recycled content in packaging, harmonised labelling requirements for recyclability, and recyclability requirements for packaging.
Three Key Steps for Preparation
In order to ensure compliance, businesses must address the following three key areas:
1. Applicability Assessment: What Role(s) Does Your Company Have in the Supply Chain?
The PPWR draws a strict distinction between different types of “economic operators”.
As companies frequently assume multiple roles in international supply chains, it is essential to clearly identify their respective packaging-related roles in order to determine the scope of their obligations under the Regulation.
2. Product Portfolio Analysis and Clarification of Definitions: What Constitutes Packaging vs Packaging Material?
As under the previous Packaging Directive, the PPWR essentially distinguishes between three types of packaging:
- sales packaging,
- grouped packaging, and
- transport packaging,
as well as between packaging components and packaging materials.
With respect to packaging materials, suppliers must, from August 2026 onwards, provide comprehensive conformity documentation.
Companies should therefore conduct a systematic review and clustering of their entire product portfolio at an early stage. Only in this way can it be determined with precision which specific obligations apply to which products or components.
3. Labelling Requirements: What Must Be Indicated on Packaging from August 2026?
For all packaging placed on the market from 12 August 2026, manufacturers must provide the following administrative information directly on the packaging:
- Traceability: A unique type, batch, or serial number.
- Manufacturer identification: Name, registered trade name or registered trade mark, and the postal address.
- Digital contact details: An email address and/or a URL. This information may also be made available digitally (e.g. via a QR code).
In addition, importers must, from 12 August 2026, also indicate on the packaging:
- their name, registered trade name or registered trade mark, and
- their postal address.
Practical Guidance
Businesses should not wait until summer 2026. The preparation of technical documentation, negotiations with international suppliers, and the adaptation of packaging layouts require several months of lead time. We would be pleased to assist you in conducting an individual applicability assessment for your business model and to review your packaging for compliance with the PPWR. Please do not hesitate to contact us at any time should you have any questions.
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