PPWR Update: Week of August 10, 2026

Regulatory & Policy  |  August 12, 2026

Regulation (EU) 2025/40 applies from today in all 27 member states. It is a regulation, not a directive, so it binds directly with no national law needed first. Four things start now rather than later: the PFAS restriction on food-contact packaging, which sets three limits that all apply together, 25 ppb for any single PFAS and 250 ppb for the sum, both excluding polymeric PFAS, plus 50 ppm for total PFAS including polymeric; the Declaration of Conformity under Art. 39; the deadline for non-EU producers to appoint an authorized representative under Art. 45(3); and Germany's VerpackDG. Art. 67(5) is the one exception and waits until February 12, 2029.

What this means for you. The duty exists today, everywhere, whether or not the member state has named an enforcement authority. Thirteen still have not. What is NOT due today is most of the headline material: recyclability grades, recycled content minimums, the empty space cap and the reuse targets all sit at 2030 or later, and every one of those dates is a floor that moves later if the act it depends on is late. Nothing you print today needs a harmonized sorting label.

What to do. Confirm your Declaration of Conformity exists and is signed. If you are outside the EU, confirm your authorized representative is appointed in writing, per member state. If you use fluorinated food-contact materials, ask suppliers for total fluorine evidence now, because that duty is triggered on request above 50 mg/kg. Source: Regulation (EU) 2025/40, Art. 71, OJ L, 2025/40, 22.1.2025 [LOCKED].

Regulatory & Policy  |  August 12, 2026

Twelve actions for annulment against the PPWR are pending before the EU General Court, filed during 2025 and confirmed on the EUR-Lex record for the Regulation as at August 11, 2026: T-197/25, T-236/25, T-237/25, T-238/25, T-239/25, T-241/25, T-242/25, T-243/25, T-244/25, T-247/25, T-248/25 and T-249/25. Seven ask the Court to strike the whole Regulation. The rest target specific provisions, and they cluster: Art. 50 and Annex X, the deposit and return system rules, in three cases; Art. 29, the reuse targets, in six; Art. 25 and Annex V, the restricted packaging formats, in four; and Art. 7, the recycled content minimums, in one.

What this means for you. Nothing changes today. A pending annulment action does not suspend a regulation, and none of these cases has been reported as winning interim relief, so every date on this site still stands and you should plan against all of them. What it does tell you is where the legal risk sits. The four provision groups under attack are, between them, most of the expensive part of the Regulation, and they are the parts whose detail is still being written in delegated and implementing acts. If your 2030 capital plan depends on a single reading of the reuse targets or the format bans, that plan carries more legal uncertainty than the text alone suggests.

What to do. Keep complying. Do not treat litigation as a reason to delay a 2030 program, because if a case fails you will have lost years. Do flag it to whoever signs off your capital spend. Source: EUR-Lex record for Regulation (EU) 2025/40, "Affected by case", read August 11, 2026: EUR-Lex CELEX 32025R0040. The case notices themselves have not been read, so the applicants and their arguments are not reported here [SIGNALED].

Regulatory & Policy  |  August 12, 2026

Art. 12(6) and 12(7) required the Commission to adopt the harmonized labeling implementing acts by today. It has not. As at August 11, 2026 the EUR-Lex record for the Regulation lists no implementing act completing Art. 12, and the only act completing the Regulation at all is the pallet wrap exemption. The technical groundwork exists: the Commission's Joint Research Centre published a technical proposal for a harmonized sorting label in early 2026, taking a material-based approach built on pictograms, color coding and minimal text rather than the old alphanumeric codes.

What this means for you. The labeling obligation applies from August 12, 2028 or 24 months after those acts enter into force, whichever is later. That "whichever is later" is now doing the work. Every month the act slips, 2028 slips with it, so treat 2028 as a floor and not a deadline. The flip side is that you still do not know what the label will look like.

What to do. Do not commission final sorting-label artwork yet. Watch for the draft act and its consultation, because that is your only chance to comment on the pictogram set before it is fixed. Source: absence of any Art. 12 implementing act on the EUR-Lex record for Regulation (EU) 2025/40, read August 11, 2026: EUR-Lex CELEX 32025R0040. The JRC proposal has not been read in full, so no date or document number is stated for it [SIGNALED].

Site Update  |  August 12, 2026

If you sell under your own brand and you are a very small business, the packaging obligation may not be yours. We had this wrong in two places and have corrected it.

The general rule is that putting your brand on packaging makes you the manufacturer, which is why private label normally lands on the retailer rather than the factory. There is one exception. If the brand owner is a micro-enterprise and its packaging supplier is in the same member state, the obligation belongs to the supplier instead. Both of those have to be true at once. A micro-enterprise buying its packaging from another member state is still on the hook itself.

What this means for you. If you are a micro-enterprise brand owner, check where your packaging supplier is based, because that single fact decides whether this is your obligation or theirs. If you are a packaging supplier, check whether any of your customers are micro-enterprises in your own country, because for those accounts the duty is yours, not theirs. Corrected on the Roles & Obligations tab and in the article guide. Source: Regulation (EU) 2025/40, Art. 3(1)(13)(a) and (b).