Every unit of packaging you place on the EU market will need a declaration of conformity and the evidence behind it, from 12 August 2026. PPWR, the Packaging and Packaging Waste Regulation, decides what that evidence is. The polybag, the hang tag, the mailer and the pallet wrap all count. The material data behind them sits with your packaging suppliers today.
Key takeaways
12 August 2026: from that date packaging cannot be placed on the EU market without a declaration of conformity and an Annex VII technical file.
One manufacturer per chain: whoever puts their name or trademark on the packaged product signs the declaration. For sales packaging that is usually the brand.
PFAS from 12 August 2026: food-contact packaging placed on the market after that date must meet the limits, whenever it was made. There is no sell-off period.
Apparel and footwear: hang tags, polybags, garment boxes and mailers are all packaging, and e-commerce boxes may hold no more than 50% empty space from 2030.
Data first: material composition, chemical tests and weights come from packaging suppliers, per format. Collecting them is the work.
What is PPWR, and what does it mean for a brand?
Regulation (EU) 2025/40 replaces the Packaging and Packaging Waste Directive of 1994 with a regulation that applies directly in every member state. It entered into force on 11 February 2025 and applies from 12 August 2026.
The PPWR regulation sets rules for the packaging itself. What it may contain, how much empty space it may hold, how recyclable it must be, how much recycled content it must carry, how it is labelled. It covers every format, from the polybag around a shirt to the pallet wrap around the shipment. The duty falls on whoever places the packaged product on the market.
Member states keep enforcement, penalties and the extended producer responsibility schemes; Germany, for one, is moving from VerpackG to VerpackDG. PPWR is one of the EU product rules in these guides.
Where PPWR stands
PPWR is in force and its general application date, 12 August 2026, has passed. The declaration of conformity, the technical file and the PFAS limits apply now. The Commission guidance, Notice C/2026/3084, is published.
Still to come: the implementing acts on empty-space calculation, then the harmonised sorting labels from 12 August 2028 and the reusable-packaging labels from 12 February 2029. The recyclability grades and recycled-content minimums follow from 1 January 2030. Verify each against EUR-Lex before you plan around it; we update this paragraph when one moves.
Manufacturer or producer: your role under PPWR
Your duties depend on which role you hold in each chain, and the Commission guidance allows only one manufacturer per chain. Pick the wrong role and you either sign for evidence your supplier holds, or miss a duty that was yours.
Two roles carry the duties: the manufacturer, who signs the declaration, and the producer, who registers with the extended producer responsibility scheme and pays the fees.
Manufacturer
- You have packaging or a packaged product designed or manufactured under your own name or trademark
- For sales and grouped packaging, the manufacturer is often the brand owner
- Solely responsible for ensuring packaging meets sustainability criteria
- Must compile the technical documentation (Annex VII) and issue the EU Declaration of Conformity
- Exception: If your brand is a micro-enterprise and your supplier is in the same Member State, the supplier becomes the Manufacturer
Producer
- You make packaged products available for the first time in a specific member state
- Responsible for extended producer responsibility (EPR) registration
- Must handle reporting and paying eco-modulated fees
- Obligations apply in the country where the packaging becomes waste
PPWR compliance: requirements for brands
Seven requirement blocks follow, in the order they apply, each with the evidence that proves it and the article it comes from. The declaration of conformity comes first because every other block feeds it.
The PPWR declaration of conformity and the supplier data behind it
Terms to know · EPR (Extended Producer Responsibility)
A policy principle requiring packaging producers to finance the collection, sorting, and recycling of their packaging waste through fees to a compliance scheme.
No packaging goes on the market without an Annex VII technical file and a signed EU declaration of conformity. The declaration is held by the manufacturer and produced when an authority asks, within ten days.
12 August 2026.
Collect the chemical, volumetric and material data from every packaging supplier. Keep the declaration five years for single-use packaging, ten for reusable.
Bill of materials per format, the harmonised standards applied, the minimisation, recyclability and PFAS calculations, and the signed declaration.
Regulation (EU) 2025/40, Articles 15, 16, 38, 39, Annex VII, Annex VIII
The same supplier evidence feeds the product passport under ESPR. In Tappr it sits in Brand Cloud per format, retrieved when the declaration is due, not assembled from inboxes the week before.
Substances of concern: PFAS and heavy-metal limits per format
Food-contact packaging may not exceed the PFAS limits. Those are 25 ppb for a targeted substance, 250 ppb for the sum of targeted substances, or 50 ppm total fluorine. Lead, cadmium, mercury and hexavalent chromium together may not exceed 100 mg/kg.
12 August 2026. The test is the date of placing on the market, not the date of production. Stock placed before that date may stay on the market; food-contact packaging placed after it must comply, however old it is.
Test every food-contact format now and phase out the coatings that fail.
The Commission's three-step test starts with total fluorine; under 50 mg/kg passes. The lab report goes in the Annex VII file.
Regulation (EU) 2025/40, Article 5, Annex VII
Packaging minimisation: no more than the product needs
Packaging weight and volume must be the minimum the function needs. "Consumer acceptance" and "marketing" are not accepted reasons for more.
1 January 2030.
Assess each format against the Annex IV criteria, such as protection and hygiene. Remove double walls, false bottoms and layers that do no work.
An Annex IV assessment per format, showing which design requirement stops further reduction, with test results or modelling behind it.
Regulation (EU) 2025/40, Article 10, Annex IV
E-commerce: at most 50% empty space from 2030
Grouped, transport and e-commerce packaging may hold at most 50% empty space. Earlier drafts said 40%; the adopted text says 50%.
1 January 2030 (or 3 years after implementing acts).
Size e-commerce boxes to the sales packaging inside. Bubble wrap, paper and foam chips count as empty space. A product shipped in its own sales packaging is exempt from the 50% rule but still has to meet minimisation.
The volume of the sales packaging against the volume of the box, per format.
Regulation (EU) 2025/40, Article 24
Recyclability: every format graded from 2030
All packaging must be recyclable. From 2030 it must reach grade A, B or C, meaning over 70% recyclable; below that it counts as technically non-recyclable. From 2035 it must be recycled at scale. From 2038 grade C is banned.
1 January 2030 (Design for Recycling), 1 January 2035 (Recycled at scale).
The full Annex VII recyclability assessment waits for the delegated acts, expected in 2028. Until then, show that each format can be recovered by material recycling under existing standards such as EN 13430:2004.
In time, a conformity assessment placing each format in grade A, B or C, filed with the technical documentation.
Regulation (EU) 2025/40, Article 6, Annex II (Table 3 and 4)
Recycled content: minimum shares per plastic format from 2030
Plastic parts must carry minimum post-consumer recycled content from 2030: 30% for contact-sensitive PET, 10% for other contact-sensitive plastics, 30% for single-use beverage bottles, 35% for other plastic packaging. A plastic part under 5% of the packaging weight is exempt.
1 January 2030.
Line up recycled-content supply now, and start collecting the percentages from suppliers. The calculation method is not adopted yet; the implementing acts are due in December 2026. Do not sign long contracts tied to a private methodology before then.
The recycled-content percentage per manufacturing plant and year.
Regulation (EU) 2025/40, Article 7
Harmonised labelling and the 2028 artwork programme
An EU-wide label showing material composition so the consumer can sort it. Reusable packaging also carries a QR code or other data carrier to count trips.
12 August 2028 for sorting labels; 12 February 2029 for reusable-packaging labels. Both follow implementing acts due in August 2026.
Plan the artwork change now. National sorting labels that conflict with the EU label, such as the French Triman, must go.
For reusable packaging, the tracking behind the QR code: trips, returns, rotations.
Regulation (EU) 2025/40, Article 12
PPWR for apparel, footwear and textile brands
If you sell apparel or footwear, four points in PPWR land on your packaging in particular. The apparel page shows where a brand starts.
What counts as packaging
Dust bags for shoes and garments are packaging when they contain or protect the product for the end user. So are hang tags and labels attached to the product, and hangers sold with a garment. Hangers sold on their own and RFID tags are not.
The 50% empty space crisis for DTC
Soft garments in standard mailers leave a lot of air. From 2030, air or tissue above 50% of the box volume is a breach. Box-to-product fit becomes a data problem before it is a packaging problem.
The 5% plastic exemption
A plastic part under 5% of the packaging unit's weight is exempt from the recycled-content minimums. Claiming that exemption for a polybag or a trim needs a bill of materials weighed to the gram.
Recyclability exemption
Sales packaging made of textile, and of lightweight wood, cork, ceramic or porcelain, is exempt from the Article 6 recyclability requirements.
PPWR timeline: what applies when
One date has passed and binds you now: 12 August 2026, the declaration, the technical file and the PFAS limits. The rest lands between 2028 and 2038, and each step below names what it asks for.
PPWR Enters into force
General application date
Technical documentation, EU Declarations of Conformity (DoC), and strict PFAS limits apply.
Calculation methodologies
Empty space ratio (50%) calculation methodologies adopted; compostability requirements apply for sticky labels.
Harmonised EU sorting labels
Harmonised EU sorting labels become mandatory; conflicting national labels (like the Triman) must be phased out.
Reusable packaging labels
Reusable packaging labels and QR codes become mandatory.
Major compliance milestone
Design for recycling (Grades A/B/C), recycled content minimums, packaging minimisation, 50% empty space ratio, and reuse targets become strictly binding.
"Recycled at scale"
"Recycled at scale" recyclability criteria applies.
Grade C banned
Packaging must meet recyclability grades A or B (Grade C banned).
Stricter targets
Step-up to stricter recycled content and reuse targets.
What to have in place now that 12 August 2026 has passed
Six things an authority can ask for today. Run every format in your portfolio through them.
Map your packaging portfolio
Name the manufacturer and the producer for every packaging format and every market you sell in.
Collect supplier data
Collect the Article 16 data from packaging suppliers per format: bill of materials, chemical tests, weights.
Test for PFAS
Run the three-step total-fluorine test on every food-contact format; anything that fails cannot be placed on the market.
Review minimisation and empty space
Measure your e-commerce boxes against the products inside; fillers count as empty space against the 50% limit.
Check recycled content
Set current recycled content against the 2030 minimums, 35% for most plastics, and weigh every plastic part against the 5% exemption.
Prepare the Annex VII documentation
Have the Annex VII file and the signed declaration ready per format before the product ships, not after the authority writes.
Data and suppliers: what you must track
A declaration is only as complete as the data behind it. The table sets what the regulation requires against what a supplier-fed system holds for you.
What PPWR means for your team, every format and every season
The risk under PPWR is not the recyclability targets. It is the evidence: one supplier certificate missing for one format, and that packaging cannot be placed on the market.
Since 12 August 2026 an authority can ask for the file and expect it within ten days. What has to be in place:
- Article 16 data collected from suppliers, per format: bill of materials, chemical tests and weights, each season, from a link rather than an email thread.
- A live bill of materials per SKU: so the 5% plastic exemption and the 50% empty-space ratio are calculations, not estimates.
- Certificates kept with the format: PFAS lab results, recycled-content verifications and the signed declaration, ready for the ten-day request.
- The Annex VII file and the declaration generated from that data: assembled once, not rebuilt per shipment.
The brands most exposed after August 2026 are not the ones with the worst packaging. They are the ones with the worst data.
PPWR questions, answered
Does PPWR apply to packaging already in our warehouses?
What is the PPWR declaration of conformity?
We are a small business. Are we exempt?
Do we need to keep using national logos like the Triman?
What is the PPWR timeline?
What happens to composite packaging, such as paper with a plastic lining?
Official sources
All claims, guidelines, and compliance frameworks in this document are drawn directly from the following official European Union legislative acts, directives, and institutional guidance resources:
- Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC
- Commission Notice C/2026/3084: Guidance document for Regulation (EU) 2025/40 on packaging and packaging waste
- European Commission FAQ: FAQ on Packaging and Packaging Waste Regulation (PPWR) - Environment
- European Commission Overview: Packaging waste: Environment overview
- European Parliament Legislative Train Schedule: Revision of the packaging and packaging waste directive