Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste (“PPWR”) has already entered into force, but will generally apply from 12 August 2026. Individual obligations will, however, phase in gradually.
The PPWR will affect practically all companies that place packaging or packaged products on the EU market. This will typically include packaging manufacturers, manufacturers of packaged products, companies selling products under their own brand, importers, distributors and e-shops. In addition, a number of companies may have several roles at the same time.
What should companies gradually do?
1. Map packaging
Prepare an overview of all packaging used, broken down by material, type, supplier and purpose of use.
2. Request data from suppliers
Obtain information on the composition of packaging, recyclability, recycled content and, in the case of packaging intended to come into contact with food, also on PFAS.
3. Prepare documentation
Set up technical documentation and supporting materials to demonstrate compliance with the PPWR.
4. Reporting
Verify registrations, reporting obligations and responsibility for packaging in individual Member States.
5. Review contracts
Amend contracts with suppliers, distributors and logistics partners so that it is clear who is responsible for data, documentation and compliance of packaging with the PPWR.
The Commission is also required to adopt, by 12 August 2026, an implementing regulation on harmonised labels and digital marking of packaging, including a methodology for identifying material composition.
Summer Digital Legal Update 2026 here.