Packaging and packaging waste regulation (PPWR)

Several requirements for manufacturers apply from 12 August 2026. However, a number of provisions will apply at later dates.

Manufacturers must ensure that packaging complies with the sustainability and labeling requirements set out in Articles 5–12 of the EU Packaging Regulation before placing packaging on the market.

The sustainability requirements applying from 12 August 2026 include provisions on hazardous substances (Article 5). Provisions on reusable packaging, (Article 11) also apply, but from an earlier date, namely 11 February 2025, which is the date the Regulation entered into force. Transitional provisions also apply, meaning that the so-called essential requirements in the Packaging Directive will continue to apply until they are replaced by provisions in the EU Regulation.

Packaging that was placed on the market before 12 August 2026 and does not comply with the sustainability requirements applicable from that date may continue to be made available on the market. However, if packaging poses a risk to the environment or human health, the manufacturer must take corrective measures to ensure compliance with the regulation. This applies to packaging placed on the market from the date the regulation entered into force, i.e. from 11 February 2025.

For reusable packaging, Article 11 of the EU Packaging Regulation states that the criteria for reusability shall apply from 11 February 2025, which is the date of entry into force of the Regulation. However, the EU Packaging Regulation shall be applied from 12 August 2026. This means that reusable packaging placed on the EU market before 11 February 2025 is required to comply with these requirements retroactively, as explicitly stated in Article 15.9 of the Regulation. Reusable packaging placed on the market after 11 February 2025 must comply with the relevant requirements. However, the competent authorities will only be able to compliance with Article 11 and other provisions of the Regulation after 12 August 2026. The requirements set out in Article 11 are essentially the same as the requirements for reusable packaging established in the previous Packaging Directive and the harmonised standard EN 13429:2004 on reusable packaging.

The information set out in Articles 15.5 and 15.6 is intended to enable traceability of the manufacturer of the packaging.

Article 15.5 of the EU Packaging Regulation states that manufacturers must ensure that the packaging has a type number, batch number, serial number or other identifying marking. If it is not possible to indicate this on the packaging due to the size or nature of the packaging, the information must be provided in a document accompanying the packaged product.

Article 15.6 of the EU Packaging Regulation states that manufacturers must indicate the following information on the packaging:

• The manufacturer’s name, registered trade name or registered trademark.
• The postal address and, where applicable, the electronic means of communication through which they can be contacted.

The stated postal address shall indicate a single contact point where the manufacturer can be contacted. The information shall be provided on the packaging or in a QR code or other data carrier. If this is not possible, the required information shall be provided as part of the information via the QR code or other digital data carrier for which the Commission will adopt provisions in secondary legislation, or in a document accompanying the packaged product.

There may be labelling requirements in other EU legal acts concerning, for example, the contents of the packaging. As a general rule, such requirements apply in parallel with the labelling requirements in the EU Packaging Regulation.

A manufacturer of packaging shall, in accordance with Article 15.7, ensure that the information provided is clear, understandable and legible and does not replace, obscure or risk being confused with information required under other Union acts concerning the labelling of the packaged product.

According to Article 15.2, the manufacturer shall draw up the technical documentation before the manufacturer places packaging on the market. The documentation requirements are set out in Annex VII of the EU Packaging Regulation. The requirement to prepare technical documentation applies from 12 August 2026 and shall therefore be drawn up for all packaging placed on the market after this date.

The technical documentation shall, among other things, contain information on the design, construction and intended use of the packaging. The documentation shall also contain information demonstrating that the packaging complies with the sustainability requirements in Articles 5–11 and the labelling requirements in Article 12.

For several of these requirements, standards are available that can support the assessment. If the manufacturer has used a standard in its assessment, this shall be indicated in the technical documentation. However, the use of harmonised standards is not mandatory. Nor is it mandatory to use analyses, but if the manufacturer relies on analyses to support its assessment of compliance, this shall be indicated in the technical documentation. For example, if PFAS analyses have been conducted to verify compliance with Article 5.5, this shall be documented.

The documentation shall include information on how the packaging complies with applicable sustainability requirements in Articles 5–11. For requirements that apply from a  later date, such information does not need to be included until those requirements become applicable. This applies, for example, to the requirement on recycled content (Article 7) and recyclability (Article 6), which apply from 2030.

In order to prepare the technical documentation, the manufacturer may need to obtain information from suppliers of packaging materials. According to Article 16, suppliers shall provide all information and documentation necessary for demonstrating compliance, in one or more languages that can easily be understood by the manufacturer.

Manufacturers shall retain the technical documentation as follows:

1. In the case of single-use packaging: for five years from the date on which the packaging was placed on the market.
2. In the case of reusable packaging: for ten years from the date on which the packaging was placed on the market.

The technical documentation does not need to be shared or accompany the packaging. However, upon request by a national authority, it shall be provided and must then be in one or more languages easily understood by that authority (Article 15.10).

Even though the manufacturer shall retain the documentation, importers shall also ensure that authorities can access it upon request, with the same retention periods.

If technical documentation is missing, incomplete or incorrect, Member States shall ensure that corrective measures are taken (Article 62).

When the manufacturer has assessed that the packaging complies with the applicable requirements, the manufacturer shall draw up an EU declaration of conformity in accordance with Article 39 and Annex VIII. By doing so, the manufacturer assumes responsibility for compliance.

Manufacturers shall retain the declaration:

1. Single-use packaging: five years.
2. Reusable packaging: ten years.

Importers shall retain a copy for the same period and make it available upon request.

If other Union legislation applies, a single declaration may be issued covering all acts, with references (Article 39.3).

Authorities shall annually verify parts of declarations and take corrective measures, including withdrawal of non-compliant products (Article 39.5).

A supplier is any natural or legal person supplying packaging or packaging materials to a manufacturer.

Suppliers shall provide all necessary information and documentation, including technical documentation required under Articles 5–11.

A supplier may in some cases be considered a manufacturer.

If a manufacturer is also a producer according to Article 3.1.15, it shall comply with producer responsibility requirements.

A manufacturer may appoint a representative by written mandate. Tasks are defined in Article 17, including providing documentation to authorities. The obligations in Article 15.1 and the preparation of technical documentation may, however, not be delegated.

Where an importer places packaging on the market under his own name or trademark, or modifies packaging already placed on the market, in such a way that compliance with the relevant requirements of the EU Regulation may be affected, the importer shall be considered to be a manufacturer and shall have the same obligations as manufacturers under Article 15.

Several requirements for importers apply from 12 August 2026. However, several provisions will apply at a later date, see the section ”Important dates” on this page.

If an importer is also a producer, as defined in Article 3.15, it shall comply with the requirements on extended producer responsibility.

Packaging producer – what applies to you

Where a distributor places packaging on the market under its own name or trademark, or modifies packaging already placed on the market in such a way that compliance with the relevant requirements of the Regulation may be affected, the distributor shall be considered to be the manufacturer and shall be subject to the same obligations as manufacturers under Article 15.

Where a distributor falls within the definition of micro-enterprise and the natural or legal person who supplies the packaging to the distributor is established in the Union, the person who supplies the packaging shall be considered to be the manufacturer and shall be subject to the same obligations as manufacturers under Article 15.

Several requirements for distributors apply from 12 August 2026. However, several provisions will apply at a later date, see the section ”Important dates” on this page.