Regulation (EU) 2025/40 (PPWR) is directly applicable in all 27 EU member states from August 12, 2026. This is the obligation checklist by deadline, role, and evidence label. Use the interactive PPWR Atlas to filter it to your role and packaging types.
| Obligation | Article | Evidence | Applies to |
|---|---|---|---|
| Prepare and hold a Declaration of Conformity for every packaging format placed on the EU market, covering minimization, recyclability, PCR content, and substances of concern. Recyclability fields stay provisional until the Art. 6(4) design-for-recycling act (ACT-02, due Jan 1, 2028). | Arts. 5 to 12 | Locked | Brand owner / manufacturer, Importer, Non-EU seller |
| PFAS limits bind for food-contact packaging: above 25 ppb per substance or 250 ppb total PFAS is banned. Test grease-resistant paper and board formats immediately; reformulation lead times run 12 to 18 months. | Annex I | Locked | Brand owner / manufacturer, Importer, Non-EU seller |
| Register with the EPR system in every member state where you sell, and pay fees. Rates are national; harmonized grade-based eco-modulation (Art. 6(4)(d)) binds later, about mid-2029. The harmonized registration format (ACT-08) is overdue, so registration stays country-by-country. | Art. 45(1) | Locked | Brand owner / manufacturer, Importer, Online marketplace, Non-EU seller |
| The general packaging minimization duty starts: weight and volume limited to what protection and function require. The quantified 50% empty-space cap for grouped, transport, and e-commerce packaging follows in 2030. | Art. 24 | Locked | Brand owner / manufacturer, Importer, Online marketplace, Non-EU seller |
| Verify before making packaged goods available: required labels present, the producer is registered for EPR, and conformity documentation exists. Do not supply non-compliant stock. | Arts. 5 to 12, 45 | Signaled | Distributor / retailer |
| Appoint an Authorized Representative where national law requires one (Austria: mandatory at any volume). The Environmental Omnibus AR suspension (COM/2025/982) is not adopted, and it excludes non-EU producers in any case. | Art. 45(3) + national law | Signaled | Non-EU seller |
| Obligation | Article | Evidence | Applies to |
|---|---|---|---|
| The harmonized EU sorting label becomes mandatory on consumer packaging (or 24 months after the Art. 12 implementing acts enter into force, whichever is later). National labels such as Triman and Italy’s alphanumeric codes cannot be maintained alongside it. | Art. 12(1) | Locked | Brand owner / manufacturer, Importer, Distributor / retailer, Online marketplace, Non-EU seller |
| Marks that could mislead or confuse on waste handling are restricted once the harmonized label applies. That is when the standalone Green Dot goes; a fee-paid symbol may then appear only inside the QR code (the Green-Dot-specific reading is SIGNALED pending the final labeling act). | Art. 12(8) | Locked | Brand owner / manufacturer, Importer, Distributor / retailer, Online marketplace, Non-EU seller |
| Digital Product Passport and QR data-carrier requirements are slated with the 2028 labeling wave; the technical specification (ACT-09) has not been started, so budget artwork and data-systems flexibility. | Art. 13 (ACT-09 pending) | Signaled | Brand owner / manufacturer, Importer, Non-EU seller |
| Obligation | Article | Evidence | Applies to |
|---|---|---|---|
| Deposit return systems operate in all 27 member states for single-use plastic bottles and metal beverage containers 0.1L to 3L. Containers need deposit marking per national scheme, and deposits are charged through the distribution chain. Nine member states still have no operating DRS today. | Art. 50 | Signaled | Brand owner / manufacturer, Importer, Distributor / retailer, Online marketplace, Non-EU seller |
| Obligation | Article | Evidence | Applies to |
|---|---|---|---|
| Packaging below recyclability Grade C (under 70% recyclable by weight) cannot be placed on the EU market (or 24 months after the Art. 6(4) acts, whichever is later). Screen multilayer laminates, PVC, carbon-black plastic, and EPS now; per-category criteria arrive with ACT-02. | Art. 6 + Annex II Table 3 | Locked | Brand owner / manufacturer, Importer, Distributor / retailer, Non-EU seller |
| Minimum post-consumer recycled content binds for plastic packaging: 30% PET contact-sensitive, 10% other contact-sensitive, 30% single-use plastic beverage bottles, 35% other plastic. Only post-consumer material counts; methodology pending ACT-03. | Art. 7(1) | Locked | Brand owner / manufacturer, Importer, Non-EU seller |
| The maximum 50% empty-space ratio binds for grouped, transport, and e-commerce packaging (or 3 years after the Art. 24(2) implementing acts; the calculation-methodology act is due Feb 12, 2028). | Art. 24(1) and (2) | Locked | Brand owner / manufacturer, Importer, Online marketplace, Non-EU seller |
| Reuse targets apply: at least 40% of transport and e-commerce packaging reusable within a re-use system, and final distributors ensure at least 10% of alcoholic and non-alcoholic beverages in reusable sales packaging. The calculation methodology (Art. 30(3) implementing act) is due June 30, 2027. | Art. 29(1) and (6) | Locked | Brand owner / manufacturer, Importer, Distributor / retailer, Online marketplace, Non-EU seller |
| Obligation | Article | Evidence | Applies to |
|---|---|---|---|
| The recyclable-at-scale test is slated to tighten grade assessments from 2035. This line is provisional: it has not yet been independently re-verified against the primary text, so treat it as planning context only. | Art. 6 (verify against 6(5)/(6)) | Signaled | Brand owner / manufacturer, Importer, Non-EU seller |
| If the Environmental Omnibus AR suspension is adopted, it expires January 1, 2035, and Authorized Representative duties resume for EU-established producers selling cross-border. Non-EU producers were never covered by the suspension. | COM/2025/982 (proposal) | Speculative | Brand owner / manufacturer, Non-EU seller |
| Obligation | Article | Evidence | Applies to |
|---|---|---|---|
| Only packaging recyclable within grades A or B (Annex II Table 3) may be placed on the EU market. Grade C is no longer sufficient; formats sitting at Grade C need a redesign path well before this date. | Art. 6(3) | Locked | Brand owner / manufacturer, Importer, Distributor / retailer, Non-EU seller |
| Obligation | Article | Evidence | Applies to |
|---|---|---|---|
| Second-tier PCR minimums bind: 50% PET contact-sensitive (except single-use beverage bottles), 25% other contact-sensitive plastic, 65% single-use plastic beverage bottles, 65% other plastic. | Art. 7(2) | Locked | Brand owner / manufacturer, Importer, Non-EU seller |
| Reuse Phase 2 endeavour targets: operators shall endeavour to reach 70% reusable transport and e-commerce packaging, and final distributors at least 40% of beverages in reusable packaging. These are endeavour obligations, softer than the 2030 targets. | Art. 29(1) and (6) | Locked | Brand owner / manufacturer, Importer, Distributor / retailer, Online marketplace, Non-EU seller |
No. PPWR requirements attach to packaging formats, not individual SKUs. The Declaration of Conformity is drawn up per packaging type, a stable combination of format, component structure, material composition, and compliance-relevant features, so every SKU that uses the identical packaging shares one declaration. A change of material, supplier, weight, or format triggers a new version.
From August 12, 2026 the substantive obligations are the Declaration of Conformity, EPR registration and fees in every market, the PFAS limits for food-contact packaging, and the general packaging minimization duty. The recyclability grade, recycled-content minimums, the 50 percent empty-space cap, and reuse targets apply from January 1, 2030, and harmonized labeling from August 12, 2028.
Nowhere. There is no EU portal or central authority for it. You hold it on file and produce it to a national market surveillance authority on request. That is different from EPR registration, which does go into national registers such as Germany's LUCID. The declaration follows the Annex VIII structure and travels through the supply chain with the packaging.
Brand owners and manufacturers hold the primary obligation. Importers are treated as producers when there is no EU manufacturer. Online marketplaces are the backstop registrant for non-EU sellers. Packaging suppliers and converters have technical information duties, and distributors handle labeling compliance and pass-through obligations.
Yes. PPWR applies to any company placing packaging or packaged goods on the EU market, wherever it is based. A non-EU seller typically complies through its EU importer, who becomes the producer, through an online marketplace acting as backstop registrant, or by appointing an EU authorized representative where national law requires one. Austria requires one at any volume. EPR registration remains country-by-country.
PPWR Annex II grades packaging recyclability by weight: Grade A is 95 percent or more recyclable, Grade B is 80 percent or more, and Grade C is 70 percent or more. Below 70 percent is non-recyclable and cannot be placed on the EU market from January 1, 2030. From January 1, 2038 only Grade A or B is allowed. Exact per-material criteria are pending the design-for-recycling delegated act, ACT-02, due January 1, 2028.
From January 1, 2030, grouped, transport, and e-commerce packaging may not exceed a 50 percent empty-space ratio under Article 24. The figure is 50 percent, not the 40 percent that circulated in earlier drafts. A general packaging minimization duty applies from August 12, 2026, and the calculation-method act is due February 12, 2028.
PFAS are banned from food-contact packaging from August 12, 2026 at concentrations exceeding 25 ppb for an individual PFAS or 250 ppb for total PFAS. Test grease-resistant paper and board formats now, since reformulation lead times run 12 to 18 months.
Grade-based eco-modulation of EPR fees is mandatory under Articles 6(4) and 45(1) but binds later, about mid-2029, roughly 18 months after the design-for-recycling act, due January 1, 2028. National PROs already modulate fees by design today, so a low-grade format carries a recurring annual cost.