PPWR 2026: the 5 concrete obligations that apply from 12 August

What takes effect on 12 August 2026

Regulation (EU) 2025/40, known as the PPWR, was adopted in January 2025. Its phased entry into force begins on 12 August 2026 with five obligations that are immediately binding on companies placing packaging on the European market.

Here is what your organisation must have in place before this date.

Obligation 1 — Packaging declaration of conformity

Every manufacturer or importer of packaging must be able to produce a declaration of conformity attesting that its packaging meets the essential requirements of the regulation: recyclability, restriction of hazardous substances, and marking.

This declaration is not yet subject to an official standardised format, but it must cover:

• Identification of the product (description, EAN/GTIN code where applicable)
• Reference to the requirements met (PPWR Articles 5 to 11)
• The identity and signature of the legal representative

To put in place now: appoint a PPWR compliance lead and create a declaration template for your main references.

Obligation 2 — Restriction of PFAS in food packaging

Packaging in direct contact with food may no longer contain per- and polyfluoroalkyl substances (PFAS) above the thresholds set by the regulation.

This restriction concerns in particular:

• Boards treated for moisture resistance
• Barrier plastic films
• The inner coatings of metal cans

Ask your packaging-material suppliers for the technical documentation attesting to the absence of intentional PFAS.

Obligation 3 — Mandatory marking on packaging

From 12 August 2026, certain packaging will have to display legible, standardised markings indicating:

• The nature of the material (according to the Commission’s harmonised nomenclature)
• The appropriate collection point for the consumer
• The sorting symbol if the packaging is intended for the general public

Industrial B2B packaging benefits from a simplified regime, but secondary packaging accessible to the final consumer is concerned.

Obligation 4 — Ban on unnecessary packaging

The regulation introduces a negative list of packaging judged unnecessary or excessive. Among the formats banned from 2026:

• Primary packaging for fresh, unprocessed fruit and vegetables below 1.5 kg (with exceptions for loose products)
• Certain miniature portion packaging in hospitality (sugar, condiments) below defined volumes

Check whether your product portfolio contains affected references and plan the transition.

Obligation 5 — Registration in the national register (EPR)

Producers must be registered in the Extended Producer Responsibility system applicable in each Member State where they place packaging on the market.

In France, the EPR scheme will be updated to incorporate the new PPWR categories. ADEME and Citeo are publishing a transition calendar. Companies already registered will have to update their declarations to include the new packaging types.

What does not yet take effect in August 2026

To avoid any confusion, here are the obligations that arrive later:

How to prepare your organisation

1. Map all your packaging by PPWR category (primary, secondary, tertiary, transport)
2. Assess each reference against the five obligations of August 2026
3. Document your compliance in an internal register
4. Train your purchasing, packaging and compliance teams on the new requirements
5. Plan the product changes needed by 2028 (recyclability by design)

Integrate the PPWR into your product development process and your supplier qualification frameworks: this is not a one-off project.