Brands with their name on the pack
If packaging or a packaged product is made under your name or brand, you are its manufacturer: you own the conformity assessment, the technical file and the declaration of conformity.
EU · Packaging · Regulation (EU) 2025/40
PPWR: packaging that is EU-ready at source.
The EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) has applied since 12 August 2026. Before packaging reaches the EU market it needs a conformity assessment, technical documentation and an EU declaration of conformity, with heavy-metal limits and, for food contact, PFAS limits met from day one.
- 12 Aug 2026
- applies across the EU
- 100 mg/kg
- lead, cadmium, mercury and Cr(VI) combined
- 2030
- recyclability grades and recycled content
Status · checked 28 Sep 2026 Applies since 12 Aug 2026
- PPWR enters into force
- PPWR applies generally
- 28 Sep 2026
- Harmonised sorting labels
- Recyclability, recycled content, empty space, re-use
- Higher recycled-content minimums
The short answer
What you need to know.
Checked against official sources on 28 September 2026.
- 01
The PPWR has applied since 12 August 2026 in every EU Member State. It entered into force on 11 February 2025 and replaces national packaging design rules with one EU regulation (Art. 71).
- 02
Before packaging is placed on the market, the manufacturer runs the Annex VII conformity assessment, draws up technical documentation and issues an EU declaration of conformity covering Articles 5 to 12. Importers check this has been done and mark the packaging with their name and postal address (Arts. 15 and 18).
- 03
Two substance limits apply now: lead, cadmium, mercury and hexavalent chromium together at or below 100 mg/kg in any packaging component, and PFAS limits for food-contact packaging (Art. 5).
- 04
Keep the file for 5 years for single-use packaging and 10 years for reusable packaging (Art. 15(3)).
- 05
The bigger design changes come from 2028 to 2040: harmonised sorting labels, recyclability grades, recycled-content minimums for plastic, empty-space limits and reusable transport packaging.
Who it applies to
Four roles, four sets of duties.
One company can hold several roles. For each packaging unit there is exactly one manufacturer across the EU; the producer is decided country by country.
Buyers bringing goods into the EU
You bring packaging or packaged products from India, China or Vietnam into the EU. Check the manufacturer’s conformity work and add your name and postal address to the packaging.
Whoever first supplies a country
The producer registers in each Member State where it first makes packaging available and finances collection and recycling. See our guide to packaging EPR in Germany and France.
Packaging makers in your supply chain
Carton, bag, bottle and label suppliers must give the manufacturer the information and documents needed to show the packaging conforms (Art. 16).
Key dates
Every date, with its source.
Only dates set in law or official publications. Anything still proposed is marked as proposed.
-
PPWR enters into force
Regulation (EU) 2025/40 is law, with an 18-month run-up to general application.
-
PPWR applies generally
Conformity assessment, technical documentation and EU declaration of conformity; heavy-metal limit of 100 mg/kg; PFAS limits for food-contact packaging; importer identification; EPR authorised representative for producers established outside a Member State.
- Today · 28 September 2026
-
Recycled-content method adopted by the Commission
Implementing acts setting how recycled content in plastic packaging is calculated and verified. The 2030 minimums start 3 years after these acts if that is later than 2030.
-
Empty space in sales packaging minimised
Economic operators filling sales packaging reduce empty space to what the packaging needs to work, including protecting the product.
-
Harmonised sorting labels
Packaging carries the EU label showing its material composition, or 24 months after the implementing acts enter into force if that is later.
-
Reusable packaging label
Reusable packaging placed on the market carries a label saying it is reusable (or 30 months after the implementing act, if later). Article 67(5) also applies from this date.
-
Recyclability, recycled content, empty space, re-use
Packaging reaches recyclability grade A, B or C; plastic parts meet post-consumer recycled-content minimums; grouped, transport and e-commerce packaging keeps empty space at or below 50%; at least 40% of transport packaging used within the EU is reusable in a re-use system; Annex V formats such as single-use plastic grouped packaging are restricted. Several of these dates move later if the Commission’s acts arrive late.
-
Recycled at scale
Packaging must also be recyclable at scale, not only by design (or five years after the Art. 6(5) implementing acts, if later).
-
Recyclability grade A or B
Grade C is no longer enough.
-
Higher recycled-content minimums
50% for contact-sensitive PET, 25% for other contact-sensitive plastics, 65% for single-use plastic beverage bottles and 65% for other plastic packaging. Operators also endeavour to reach 70% reusable transport packaging.
Plastic recycled content
The numbers to plan around.
Minimum post-consumer recycled content in each plastic part of packaging, averaged per manufacturing plant per year (Art. 7).
| Plastic packaging type | From 2030 | From 2040 |
|---|---|---|
| Contact-sensitive PET (not single-use beverage bottles) | 30% | 50% |
| Contact-sensitive, other plastics | 10% | 25% |
| Single-use plastic beverage bottles | 30% | 65% |
| All other plastic packaging | 35% | 65% |
2030 figures apply from 1 January 2030, or 3 years after the Art. 7(8) implementing act enters into force if that is later.
Since 12 Aug 2026 · Art. 5(4) 100 mg/kg
Lead + cadmium + mercury + hexavalent chromium, summed, in packaging or any packaging component.
Since 12 Aug 2026 · Art. 5(5) 25 ppb · 250 ppb · 50 ppm
PFAS in food-contact packaging: any single PFAS and the sum of PFAS by targeted analysis, and total PFAS including polymeric PFAS.
From 2030 · Art. 24 ≤ 50% empty space
For grouped, transport and e-commerce packaging you fill, once the calculation method is in force.
What you need from suppliers
The evidence file your supplier holds.
Ask for these per packaging component, not per product. We collect them at the factory and check them against the Regulation.
- EU declaration of conformity and technical documentationAnnex VII documentation covering Articles 5 to 12, or the data you need to prepare your own as manufacturer.
- Heavy-metals test reportLead, cadmium, mercury and hexavalent chromium together at or below 100 mg/kg, per component.
- PFAS results for food-contact packagingTargeted analysis below 25 ppb per PFAS and 250 ppb in sum, and total PFAS below 50 ppm.
- Material composition of every componentBody, closures, labels, inks, adhesives and coatings, for your sorting label and recyclability grade.
- Recycled content per plastic partThe post-consumer share and how the plant evidences it, averaged per plant per year.
- Dimensions, weights and fill dataPack sizes and product sizes to check empty space, and component weights for EPR reporting.
How SourceSquid helps
From your product list to an audit-ready file.
Our teams in Bengaluru and Ningbo collect the evidence at the factory, in the supplier’s own language, while production runs.
- 01
Packaging inventory
Every packaging component per SKU, by material, weight and supplier, including shipper cartons, poly bags, tape and fillers.
You receivePackaging bill of materials - 02
Role mapping
Who is manufacturer, importer and producer for each product and EU country you sell in.
You receiveRole and obligation map - 03
Supplier evidence
Declarations and test reports collected at source, with lab testing arranged in India or China where data is missing.
You receiveEvidence pack per component - 04
Technical documentation
Annex VII documentation assembled and a draft EU declaration of conformity prepared for your signature.
You receiveDraft technical file - 05
2030 roadmap
Recyclability and recycled-content gaps priced with your suppliers, with redesign options that keep protection intact.
You receiveRedesign and PCR roadmap - 06
Ongoing watch
Implementing and delegated acts tracked and mapped to your SKUs as they are adopted.
You receiveCompliance Radar updates
Sources
Official texts behind this page
Checked on 28 September 2026. This page explains the rules in plain English; for a view on your own products, ask our team or your legal adviser.
- Regulation (EU) 2025/40 on packaging and packaging waste (PPWR)Arts. 5, 6, 7, 12, 15, 16, 18, 24, 25, 29, 44, 45, 71; Annexes V, VII
- European Commission: packaging waste (Environmental Omnibus proposal, December 2025)Proposal to suspend the authorised representative obligation: not yet law
- Zentrale Stelle Verpackungsregister: PPWR and VerpackDG, what changed on 12 August 2026Manufacturer and producer roles; Art. 16 supplier information
Related compliance guides
Rules that often travel together.
DE · FR · EUPackaging EPRExtended producer responsibility in Germany (LUCID, VerpackDG) and France (Triman, IDU).→EU · chemicalsREACHSVHC communication under Article 33, ECHA notifications and Annex XVII restrictions.→EU · deforestationEUDRDeforestation Regulation: due diligence statements and plot geolocation for seven commodities.→
PPWR questions
Straight answers.
Dates checked against official sources. We update this page when the rules move.
anirudh@sourcesquid.coWhen does the PPWR apply?
Regulation (EU) 2025/40 entered into force on 11 February 2025 and has applied generally since 12 August 2026. Later requirements follow on fixed dates: harmonised sorting labels from 12 August 2028, recyclability grade A to C and plastic recycled-content minimums from 1 January 2030, recyclable at scale from 2035 and grade A or B from 2038. Several of these move later if the Commission’s implementing or delegated acts arrive late.
What does the PPWR require from importers?
Before placing packaging or packaged products on the EU market, importers check that the manufacturer has carried out the Annex VII conformity assessment, drawn up the technical documentation and issued an EU declaration of conformity. Importers also mark the packaging with their name, registered trade name or trademark and postal address, or use a digital data carrier or accompanying document where that is not possible (Art. 18(3)).
Which documents should I ask my packaging supplier for?
The EU declaration of conformity and the Annex VII technical documentation (or the data to prepare your own), a test report showing lead, cadmium, mercury and hexavalent chromium together at or below 100 mg/kg per component, PFAS test results for food-contact packaging, the material composition of every component, and the post-consumer recycled content of each plastic part.
What are the PFAS limits for food-contact packaging under the PPWR?
Since 12 August 2026, food-contact packaging may not be placed on the market if it contains PFAS at or above 25 ppb for any single PFAS or 250 ppb for the sum of PFAS measured by targeted analysis, or 50 ppm for total PFAS including polymeric PFAS (Art. 5(5)).
Do sellers outside the EU need an authorised representative under the PPWR?
Producers established outside a Member State that supply packaging there must appoint, by written mandate, an authorised representative for extended producer responsibility in each such Member State (Art. 45(3)). In December 2025 the Commission proposed suspending this obligation; that proposal is not yet law.
Start here
Your packaging file, built at the factory.
Send us your SKU list and packaging photos. We return a component-by-component PPWR gap list and the evidence each supplier needs to provide.