The countdown to the new EU packaging regulations has begun! As the most far-reaching and stringent packaging legislation in the EU in recent years, the PPWR regulation will reshape packaging compliance standards across the entire industry, profoundly impacting all companies exporting to the EU. The following is a complete interpretation of the core points of the regulation:

 

1. What is the PPWR?

 

The Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, is the European Union's new framework governing packaging and packaging waste. It replaces the former Packaging Directive with a directly applicable regulation that establishes harmonized requirements across all EU Member States.

 

The regulation applies to all packaging placed on the EU market, regardless of the material used or whether the product is manufactured inside or outside the European Union. Its objective is to reduce packaging waste, improve recyclability, increase resource efficiency, and support the transition to a circular economy.

 

2. When does the PPWR apply?

 

The PPWR entered into force on 11 February 2025, but most provisions become applicable on 12 August 2026.

 

Not every obligation begins on that date. Some requirements—including recyclability performance grades, recycled plastic content targets, reuse targets, and certain labeling obligations—will be phased in over the coming years through 2030 and beyond. Companies should therefore view August 2026 as the beginning of compliance rather than the final deadline.

 

3. Does the PPWR apply to companies outside the European Union?

 

Yes.

 

The regulation applies whenever packaging is placed on the EU market, regardless of where the packaging or product is manufactured. This means exporters from China, Chinese Taiwan, South Korea, the United States, Canada, Mexico, and other countries must ensure that their packaging complies before products are supplied within the EU.

 

For many manufacturers, PPWR compliance will become another essential market-access requirement alongside CE marking and other EU product legislation.

 

4. What are the main compliance requirements?

 

The PPWR introduces requirements covering the entire packaging lifecycle, including:

• Packaging design and minimization

• Recyclability

• Restrictions on substances of concern

(The list is expected to be published by December 31, 2026. Possible measures include: incorporating restrictions in Annex XVII of the REACH Regulation; incorporating “recyclable design” requirements; these requirements may be continuously adjusted until 2030; and introducing digital identification technology to convey material information.)

• Heavy metal limits

(Covering: Lead (Pb), Cadmium (Cd), Mercury (Hg), and Hexavalent Chromium (Cr(VI)), applicable to all packaging, effective August 12, 2026. Currently using PPWD limits, but limits may be further reduced (becoming stricter) in the future.)

• PFAS restrictions for food-contact packaging(Effective date: August 12, 2026)

• Technical documentation

• Declaration of Conformity

• Economic operator identification

• Extended Producer Responsibility (EPR)

 

The exact obligations depend on the packaging type and the implementation timeline established by the Regulation.

 

5. What should companies do before August 2026?

 

Businesses should begin preparing now by:

• Reviewing every packaging format placed on the EU market.

• Identifying packaging materials and chemical composition.

• Collecting supplier declarations and technical documentation.

• Evaluating recyclability and packaging design.

• Confirming responsibilities under applicable EPR schemes.

• Preparing internal compliance documentation and declarations.

 

Starting these activities early can help avoid disruptions once the Regulation becomes generally applicable.

 

6. What documentation will manufacturers need?

 

The PPWR places greater emphasis on demonstrating compliance through documentation.

 

Depending on the packaging and applicable provisions, manufacturers may need:

• Technical documentation supporting compliance.

• An EU Declaration of Conformity.

• Records demonstrating conformity with applicable requirements.

• Supplier material information.

• Documentation supporting restricted substance compliance.

• Identification of the responsible economic operator.

 

Maintaining complete and accurate documentation will become a key part of market access under the PPWR.

 

7. How can BACL help?

 

Preparing for the PPWR requires coordination between product designers, packaging suppliers, manufacturers, importers, and regulatory teams.

 

BACL can support manufacturers through services including:

• Packaging material evaluation

• Chemical testing for packaging materials

• Heavy metal and PFAS testing, where applicable

• Packaging technical documentation review

• Declaration of Conformity support

• Regulatory gap assessments

• Extended Producer Responsibility (EPR) consulting

• Regulatory training on PPWR requirements

 

By helping companies understand both the current obligations and the future implementation timeline, BACL can assist manufacturers in preparing their packaging for continued access to the European market.

 

Source:

https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste_en

 

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