PPWR — what changed on 12 August 2026

Regulation (EU) 2025/40 — the Packaging and Packaging Waste Regulation — has applied since 12 August 2026. It replaces Directive 94/62/EC, and the change of instrument matters more than the change of content: a Regulation applies directly in every member state, without national transposition and without twenty-seven slightly different versions of the same rule.

There was no grace period on the application date. What arrives later arrives on its own dates, and those are the ones worth planning against.

The dates

From	What applies
12 Aug 2026	The Regulation applies. Conformity documentation required. Restrictions on substances of concern, including PFAS limits in food-contact packaging
12 Aug 2028 at the earliest	Harmonised labelling: material composition and sorting information on packaging, and matching labels on waste receptacles. The date is a floor, not a fixed deadline — see below
1 Jan 2030	Design-for-recycling requirements. Minimum recycled content in plastic packaging. Empty-space limit. Reuse obligations for transport packaging. Certain single-use formats prohibited
2038 / 2040	Stricter recyclability grading, and higher recycled-content minimums

Why 2028 is not a date to plan artwork against

Article 12 reads 12 August 2028, or twenty-four months from the entry into force of the implementing acts that define the labels, whichever is the latest. Two acts, and the clock only starts when they exist. They were due by 12 August 2026 and have not been adopted. Until they are, no compliant artwork can be produced, because the pictograms have not been specified.

The labelling regime also does not apply to transport packaging at all, except for e-commerce packaging. Pallet wrap is outside it.

Two things in this area that are live: the standalone printed Green Dot stops from 12 February 2027, and reusable-packaging labels start no earlier than 12 February 2029.

Stretch film and the reuse target

The first delegated act under the Regulation, Delegated Decision (EU) 2026/429, exempts pallet wrappings and straps from the 100% reuse requirement in Article 29(2) and (3) — that is, for movements inside one company, within a group, or between companies in the same member state. The Commission concluded that full reuse of these two formats would cost more than it delivered.

What it does not do is remove the broader 40% reuse target for transport and sales packaging from 1 January 2030. Pallet wrap still counts inside that category; operators simply do not have to hit it through this particular format. Nor does it touch design-for-recycling or recycled-content minimums, which apply to stretch film like everything else.

What applies to you now

1. Conformity documentation

Packaging placed on the EU market has to be demonstrably conforming, with technical documentation behind it and an EU declaration of conformity drawn up by the manufacturer under Article 15. Importers verify that this was done and keep a copy; distributors check the document exists before making the packaging available.

The word manufacturer is the trap. It does not mean the plant that ran the extruder. It means whoever markets the packaging under their own name or trademark — so a brand owner who has sacks made to order is the manufacturer, and the converter is not. Article 21 makes that explicit: put your brand on it, and the declaration is yours to issue.

The practical consequence for anyone buying inside the single market is that “our supplier says it complies” was never the document the regulation asks for, and a declaration naming somebody else’s brand does not cover yours.

See what a Declaration of Conformity must contain.

2. Substances of concern

Restrictions on substances of concern in packaging apply now, including limits on PFAS in food-contact packaging. For the products on this site the practical effect is on coatings and barrier treatments rather than on the base polymer or the board.

If any of your packaging is food-contact and carries a grease- or water-resistant treatment, that treatment is what to ask about.

3. EPR registration

Extended producer responsibility was already in force under national schemes and continues, harmonised in structure but still administered country by country. If you place packaging on the market in Germany you register with LUCID; in the Netherlands with the national fund; and so on.

PPWR does not remove the need to register in each market. And EPR producer is not the same role as PPWR manufacturer — the first decides who registers and pays, the second decides who signs the declaration. The Commission’s June 2026 guidance is explicit that both are assigned per packaging and per market, not per company, so one business can hold different roles for different lines in different countries.

What arrives in 2030 — and why it is a now problem

Three of the 2030 requirements have lead times measured in years, not months, because they change what the packaging is rather than what is written about it.

Design for recycling

Packaging will have to meet recyclability performance criteria, graded, with the lowest grades no longer placeable on the market. For the materials a packaging buyer handles — the three this site supplies, and the pallets and board that arrive with everything else:

• Polyethylene film and sacks are recyclable in principle and the question is contamination — printed inks, multi-layer laminates and non-PE additives are what pull a grade down.
• Corrugated is already among the best-performing materials, and the risk is coatings: a wet-strength or plastic-coated liner can move a box from a paper stream to a residual one.
• Wooden pallets sit outside the plastic-specific rules but inside the general regime.

Recycled content in plastic packaging

Minimum recycled content becomes mandatory for plastic packaging from 1 January 2030, with separate thresholds for contact-sensitive packaging, beverage bottles and everything else, and higher thresholds again from 2040.

The exact percentages should be read from the current official text rather than from any summary, including this one — they were amended during the legislative process and are the single most-cited and most-misquoted figures in the regulation.

What is not in doubt is the direction, and the practical consequence: secure your recycled-content supply and your documentation of it early. Post-consumer recyclate is a constrained market, and the demand step in 2030 is visible to everyone in it.

Empty space, and packaging minimisation

Grouped, transport and e-commerce packaging faces a limit on the ratio of empty space in the pack, alongside a general obligation to minimise packaging weight and volume to what the product needs.

This is the requirement most likely to change a specification you already have. A pallet stacked to a pattern nobody has revisited in five years, or a sack specified two gauges heavier than the waste needs, is exactly what it targets. The truck and pallet load calculator and the bin liner size finder are useful here for a reason that has nothing to do with compliance: the same change that reduces empty space reduces freight.

Reuse of transport packaging

Obligations to use reusable transport packaging between sites arrive in 2030, with targets that differ by what is moved and between whom.

The scope and the percentages are the part of the regulation most likely to be adjusted by implementing acts, so this page deliberately does not quote a figure. What is stable enough to plan on: pallets, crates and rigid transport items are in scope, and single-use transport packaging between fixed sites is the use case under pressure.

What to ask a supplier, today

Five questions. A supplier who cannot answer them is a supplier who has not started.

1. Who draws up the declaration of conformity for this packaging, and can I see it?
2. What is the recycled content, as a percentage, and how is it evidenced? Certification of recyclate is a document, not an assurance.
3. What is in the packaging besides the base material? Coatings, inks, adhesives and additives are where recyclability grades and substance restrictions bite.
4. What is your plan for the 2030 recycled-content thresholds? The honest answer is a supply arrangement, not a statement of intent.
5. Will you restate the specification in PPWR terms? Material, recycled content, recyclability, and the empty-space ratio for the pack as shipped.

What we do

Every quotation states the material, the polymer grade, and the recycled content where there is any. We get the conformity documentation out of the plant at quotation stage rather than at dispatch, and we check that the declaration names the plant as a legal entity, identifies the product code you are actually buying, and is dated after the last specification change.

We do not issue the declaration and could not: we are an agent, we take no title to the goods and we place nothing on the market. Where your line is private label, the declaration is yours to issue under Article 21, and what you need from the plant is the technical documentation to support it.

We are not a compliance consultancy and this page is not legal advice. It is what a packaging buyer needs to know to ask the right questions and to plan a specification that will still be legal in 2030.

What this means for what you buy

PPWR obligations attach to the packaging itself, so the practical questions are specification questions. For stretch film and catering film that means recycled content, recyclability and the declaration that has to accompany them.

Send the specification you buy today and we will tell you where it stands against the regulation before you re-order, rather than after.