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, 250 ppb for the sum, or 50 ppm total PFAS including polymeric is banned (Art. 5(5)). 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(8)) binds later, around mid-2031, being 18 months after both the Art. 6(4) delegated acts (due Jan 1, 2028) and the Art. 6(5) implementing acts (due Jan 1, 2030) enter into force. 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 |
| Minimization keeps binding, but under the old regime. Art. 70(1)(b) keeps the Directive 94/62/EC essential requirements and EN 13428:2004 in force until December 31, 2029. The PPWR Art. 10 duty replaces them on January 1, 2030, and the Art. 24 empty-space cap lands the same day. | Art. 70(1)(b) | 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 |
|---|---|---|---|
| Where packaging covered by an EPR scheme is identified as such, that identification may be achieved only by a corresponding symbol in a QR code or other standardized open digital-marking technology. Art. 12(9) does not compel marking, it restricts the means, so the effect is that a standalone printed mark such as a Green Dot can no longer serve the purpose. This is the first PPWR artwork change and it lands well before the 2028 harmonized label, so plan artwork and data carriers for it now. | Art. 12(9) | Locked | Brand owner / manufacturer, Importer, Distributor / retailer, Online marketplace, 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 |
| Art. 12(8) restricts potentially misleading marks from August 12, 2026 and widens on August 12, 2028, since it reaches only matters for which PPWR lays down harmonized labeling. The standalone printed EPR-scheme mark stops being available for that purpose earlier, on February 12, 2027, under Art. 12(9). | Art. 12(8) | Locked | Brand owner / manufacturer, Importer, Distributor / retailer, Online marketplace, Non-EU seller |
| QR or other standardized open digital-marking requirements are slated with the 2028 labeling wave; the technical specification (ACT-09) has not been started, so budget artwork and data-systems flexibility. PPWR does not create a Digital Product Passport; that is an ESPR instrument. | Art. 12 (ACT-09 pending) | Signaled | Brand owner / manufacturer, Importer, Non-EU seller |
| Obligation | Article | Evidence | Applies to |
|---|---|---|---|
| Deposit return systems are required for single-use plastic beverage bottles and metal beverage containers of up to 3 litres (no lower bound; member states may exempt below 0.1L where not technically feasible). A member state at 80 percent or more separate collection in calendar year 2026 could seek exemption by notifying the Commission by January 1, 2028, so coverage is not automatically all 27. 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, and the PFAS limits for food-contact packaging. Minimization binds from day one too, but under the Directive 94/62/EC essential requirements that Article 70(1)(b) keeps in force until December 31, 2029, not yet under PPWR Article 10. The recyclability grade, recycled-content minimums, the Article 10 minimization duty, the 50 percent empty-space cap, and reuse targets apply from January 1, 2030, and harmonized labeling from August 12, 2028, or 24 months after the Art. 12(6) or 12(7) implementing acts enter into force, whichever is the latest. So the Declaration of Conformity is required day one, but mainly attests identity, substances, and minimization, with the design attestations added as their delegated acts arrive.
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.
Whichever of them meets one of the five independent tests in Art. 3(1)(15), which is not a ranking. Limbs (a) and (b) catch a manufacturer, importer or distributor established in a member state that supplies for the first time from within that state on that same territory. Limbs (c) and (d) catch one established in a member state or a third country supplying another member state directly to end users, and a business customer that consumes what it buys is an end user under Art. 3(1)(23), so direct cross-border B2B is caught. Limb (e) catches unpacking without being an end user unless someone else is the producer under (a) to (d). There is no cascade and no test that turns on whether an EU manufacturer exists, so the producer can differ per member state and per route to market: selling through a distributor established in the destination market can make that distributor the producer there. Limb (c) and (d) producers must appoint an authorized representative by written mandate in each member state they supply other than their state of establishment (Art. 45(3)). Packaging suppliers and converters owe the manufacturer conformity information and Annex VII documentation (Art. 16), and distributors must verify producer registration, Art. 12 labeling and upstream duties (Art. 19). Online marketplaces are not producers under PPWR. Which limb applies to your company is a question about your route to market in each member state. Source: Regulation (EU) 2025/40, Arts. 3(1)(15), 3(1)(23), 16, 19, 44 and 45, read in the OJ PDF on August 8, 2026 [LOCKED].
Yes, but how it applies depends on the route to market. PPWR reaches any company that makes packaging or packaged products available on the EU market for the first time, wherever it is based. Selling directly to end users in a member state makes the seller the producer there under Art. 3(1)(15)(c) or (d), and Art. 45(3) then requires an authorized representative appointed by written mandate in each such member state. Selling instead through an importer or a distributor established in the destination market can put the producer obligation on that party under limb (a) or (b). Online marketplaces are not producers under PPWR; under Art. 45(4) and (6) a platform must obtain and assess the producer registration number and self-certification before allowing use of its service. EPR registration remains country-by-country, and some member states add their own requirements: Austria requires an authorized representative for cross-border distance sellers with no de minimis volume.
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, and the calculation-method act is due February 12, 2028. Two related duties sit elsewhere: Article 24(4) requires empty space in sales packaging to be reduced to the functional minimum from February 12, 2028, and the general packaging minimization duty in Article 10 applies from January 1, 2030.
PFAS are banned from food-contact packaging from August 12, 2026 at three limits under Art. 5(5): 25 ppb for an individual PFAS, 250 ppb for the sum of PFAS, both excluding polymeric PFAS, and 50 ppm for total PFAS including polymeric. The Commission's June 2026 guidance recommends a stepwise test: total fluorine first, and under 50 mg/kg the sample can be treated as compliant. 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 Article 6(8), with the framework set by the Article 6(4)(d) delegated act, but binds later. Art. 6(8) sets the clock at 18 months from entry into force of BOTH the Art. 6(4) delegated acts (due January 1, 2028) and the Art. 6(5) implementing acts (due January 1, 2030). On the later of those, modulation binds around mid-2031, not 2029. National PROs already modulate fees by design today, so a low-grade format carries a recurring annual cost.