The European Union’s new Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, will begin applying from August 12, 2026, marking the first operational milestone in a phased framework that will reshape packaging design, compliance and material use across the bloc through to 2040.
The regulation establishes a harmonised legal framework for all packaging placed on the EU market, including products supplied by exporters outside the region. Its objectives are to reduce packaging waste, increase reuse and recycling rates, and ensure that packaging is designed for circularity under economically viable conditions.
From August 2026, the most immediate requirement for industry will be the introduction of a mandatory Declaration of Conformity (DoC). Under the regulation, manufacturers must formally declare that packaging complies with the applicable requirements and maintain supporting technical documentation. This documentation must follow the conformity assessment procedures set out in Annex VII and the structure defined in Annex VIII.
By issuing the declaration, the manufacturer assumes legal responsibility for compliance. Importers must verify that such documentation exists before placing packaging on the EU market and must ensure it remains available for inspection by market surveillance authorities.
European Commission guidance published in March 2026 clarifies that the “manufacturer” is not necessarily the packaging converter. In many cases, particularly for sales and grouped packaging, the role will fall to the filler or brand owner with control over packaging design and specifications. This interpretation is expected to have implications for contractual arrangements and compliance responsibilities across the supply chain.
While August 2026 marks the start of the regulatory regime, most material and design requirements will be introduced progressively. The regulation requires that all packaging placed on the EU market must be recyclable, with stricter design-for-recycling and recyclability-at-scale criteria applying from 2030.
Plastic packaging will also be subject to minimum recycled content thresholds from 2030, differentiated by application. These include targets for contact-sensitive and non-contact-sensitive packaging, as well as beverage bottles. In parallel, recycled content sourced from outside the EU will need to meet standards equivalent to those applied within the bloc, including criteria for collection systems and environmental performance.
The regulation also introduces limits on substances of concern. For food-contact packaging, restrictions on per- and polyfluorinated alkyl substances (PFAS) will apply from August 2026. Additional requirements will follow for specific applications, including compostability obligations for certain packaging formats and components.
Some widely cited restrictions on packaging formats, including single-use plastic packaging for small quantities of fresh fruit and vegetables, will not apply immediately. These measures are scheduled to take effect from 1 January 2030, reflecting the regulation’s staged implementation approach.
For packaging manufacturers, converters and brand owners, the initial phase centres on documentation, traceability and allocation of legal responsibility. Companies supplying into the EU market will need to establish robust data systems, ensure alignment with conformity assessment procedures and clarify roles within increasingly complex supply chains.
With additional milestones approaching in 2028 and 2030, the PPWR introduces a long-term transition pathway rather than a single compliance deadline. However, the August 2026 start date effectively signals the shift from preparatory work to enforceable obligations, particularly in relation to documentation and market surveillance.
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