EU Regulation
The Packaging and Packaging Waste Regulation — Regulation (EU) 2025/40, everyone calls it PPWR — entered into force on 11 February 2025. Most of it applies from 12 August 2026.
It replaces the old Packaging Directive 94/62/EC. That difference matters more than it sounds.
The old rules were a directive. Each of the 27 Member States wrote it into their own national law, slightly differently. Twenty-seven versions of the same idea. If you sold into five countries, you dealt with five rulebooks.
PPWR is a regulation. It applies directly, identically, in every Member State, on the same day. Nobody transposes it. Nobody softens it. The same articles, the same definitions, the same thresholds apply in Lisbon and in Helsinki.
For a business selling across borders, this is genuinely good news. One set of compliance documents now covers the entire single market.
The catch: there is no transition, no grandfathering, and no general exemption for small companies. Stock manufactured in July 2026 and still sitting on your shelf in September 2026 has to meet the rules.
Most of PPWR phases in slowly. Recyclability grades, recycled-content minimums, reuse quotas and the empty-space cap mostly land on 1 January 2030, not 2026. Ignore anyone selling you panic about those.
Three obligations do apply from 12 August 2026.
Every packaging type placed on the EU market must have a written EU Declaration of Conformity, drawn up under Annex VIII of the regulation. It references technical documentation prepared under Annex VII.
The good news, and this is the part most people get wrong: no notified body is required. Conformity is assessed under Module A — internal production control. The manufacturer draws up the technical file and signs the declaration themselves. There is no laboratory queue to join and no certification body to book.
The document must be kept for five years.
Intentionally added PFAS in food-contact packaging is banned. The limits are strict: 25 ppb for an individual non-polymeric PFAS, 250 ppb for the sum of non-polymeric PFAS, and 50 ppm for total fluorine including polymers. Limits on heavy metals apply too.
If your packaging touches food, or a product regulated like food, you need your supplier to confirm status in writing.
Packaging must carry the name, registered trade name or trademark, and a postal address, for both the manufacturer and, where relevant, the importer.
PPWR assigns different duties depending on your role. Getting this wrong is the most common mistake we see.
Manufacturer — draws up the technical file, signs the Declaration of Conformity.
Importer — the entity that first places non-EU packaging on the Union market. Under Article 21, if you put your own name or trademark on non-EU packaging, or you modify it, you take on the manufacturer's responsibilities. Read that sentence twice. Private-labelling an imported bottle can make you the manufacturer in the eyes of the regulation.
Distributor — must check that the packaging carries the required markings and that the upstream operators have done their job.
Authorised representative — under Article 22, a non-EU brand can appoint an entity inside the Union as its compliance anchor.
A non-EU brand shipping into a warehouse in Germany for onward sale to French customers is squarely in scope. The legal anchor is whoever first places the packaging on the Union market.
Article 16 obliges suppliers of packaging and packaging materials to provide the information and documents that certify conformity, including information on substances.
This is your right, not a favour. If you buy packaging, you can demand the conformity documentation from whoever sold it to you, and they are legally required to hand it over.
Practically, this means: write to your packaging supplier now. Ask for the Declaration of Conformity per Annex VIII, the substance declaration covering PFAS and heavy metals, and confirmation of the economic operator details printed on the pack.
If they cannot produce it before August, you have a supply problem, and you have found it in time to fix it.
PPWR does not set an EU-wide fine. Article 47 requires Member States to set penalties that are effective, proportionate and dissuasive, so the amounts vary by country.
The consequence that actually hurts is not the fine. It is market access. Packaging without a valid Declaration of Conformity may not be placed on the EU market. That means sales bans, removal from marketplaces, and stock you legally cannot sell.
We are collecting Declaration of Conformity documentation directly from Chubby Gorilla for the products we distribute, so it is available to our customers ahead of the deadline. If you buy from us, you should not have to chase a factory on another continent for a PDF.
Contact us with the SKUs you use and we will tell you where the documentation stands.
Most provisions apply from 12 August 2026. It entered into force on 11 February 2025 after an 18-month transition period. Some obligations — recyclability grades, recycled content, reuse quotas, the empty-space cap — apply from 1 January 2030 or later.
Yes. There is no general exemption for micro or small enterprises.
No. Conformity is self-assessed under Module A (internal production control). The manufacturer prepares the technical documentation and signs the Declaration of Conformity. No notified body is involved.
Yes. B2B packaging remains within scope, though some obligations — particularly around reuse and digital labelling — are adjusted.
Packaging used exclusively for goods exported outside the EU, and therefore never placed on the EU market, may fall outside the labelling and registration requirements. You must be able to demonstrate and verify this.
It may be excluded from certain reuse or recyclability targets where safety legislation or sector-specific rules require otherwise. It is not excluded from the regulation entirely.
No. Child resistance is a safety standard. PPWR is a packaging waste and substances regulation. They are separate requirements and you need both.
You may be. Under Article 21, an importer who places their own name or trademark on packaging, or modifies it, assumes the manufacturer's obligations.
This page is for information, not legal advice. Regulatory obligations depend on your product, your role in the supply chain, and the Member States you sell into. The source text is Regulation (EU) 2025/40 on EUR-Lex, and the European Commission published a guidance document and an FAQ in March 2026.
Related: Child-resistant packaging guide · Chubby Gorilla Europe · Products · Contact