On August 12, 2026, the EU Packaging Regulation (PPWR) will generally take effect. This marks the beginning of a new phase of packaging compliance for companies.
Since many design and recycling requirements will only take effect gradually in the coming years, not every future requirement needs to be implemented immediately. What matters now is establishing the basic framework for the new packaging compliance. The following six steps will ensure a smooth start:
1. Which packaging items are actually affected?
The first step is a comprehensive inventory of the packaging portfolio:
- Material & Type: What materials are used? Are they single-use or reusable systems?
- Intended Use: Is the packaging intended for food contact?
- Target Markets: In which specific EU countries is it placed on the market?
2. What is the company’s role?
The PPWR precisely allocates obligations according to market roles (manufacturer, importer, supplier, or distributor). The company’s specific role determines its legal responsibility:
- Clarification of obligations: The specific role must be clearly defined for each type of packaging.
- First-time placer on the market: Whoever places packaging on the EU market for the first time bears primary responsibility for compliance.
3. Is the necessary documentation available?
Technical documentation is a key component of compliance from day one:
- Documentation requirement: It forms the mandatory basis for the conformity assessment and the EU Declaration of Conformity.
- Retention periods: For single-use packaging, these documents must remain available for at least 5 years; for reusable packaging, for 10 years.
4. Is the supplier data reliable?
Important data on material composition originates directly from the packaging supplier:
- Early procurement: Technical data must not be sought only upon a request from regulatory authorities but must be stored in a structured manner.
- Supplier obligation: The PPWR expressly requires suppliers to provide all information necessary for demonstrating conformity.
5. Are there any critical substances in the packaging?
Material composition is coming under increasingly strict scrutiny:
- Heavy metals: Existing limit values must be strictly adhered to and documented.
- PFAS ban: Starting August 12, the new, strict restrictions on per- and polyfluoroalkyl substances (PFAS) will apply immediately to food contact packaging.
6. How sustainable is the packaging portfolio?
The effective date marks the start of a dynamic process for the coming years:
- Upcoming milestones: Further requirements regarding recyclability, recycled content, bans on empty space, and standardized labeling will follow in stages.
- Proactive development: New packaging should be designed today to meet future requirements, even if details are still to be specified by EU legislation.
Conclusion
The most important step right now is not to immediately implement every future PPWR regulation to perfection. The goal is to establish data, responsibilities, supplier processes, and structures starting August 12, 2026, in a way that ensures future requirements can be systematically met.
Contact us for comprehensive advice on your compliance issues relating to electrical and electronic equipment, packaging, batteries, and PV panels.
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