PPWR Is Now Live: The First Packaging Rules Brands Need to Know

The first measures under the Packaging and Packaging Waste Regulation (PPWR) are now officially in force, introducing new legal requirements for businesses placing packaging on the EU market.

Among the first requirements are a legally binding Declaration of Conformity, new restrictions on PFAS in food-contact packaging and a requirement for packaging placed on the EU market to be recyclable.

Declaration of Conformity

From 12 August 2026, businesses must provide a legally binding Declaration of Conformity (DoC) for every item of packaging placed on the EU market.

The declaration must demonstrate that the packaging meets the relevant legal requirements covering areas including recyclability, recycled content, reuse, minimisation and empty space.

Each packaging format, material and configuration requires its own DoC. The documentation must include the manufacturer’s name and address, a statement of sole responsibility and a unique identification number for tracking.

It must also identify the packaging type, material and batch or serial number, alongside a conformity statement referencing Articles 5 to 12 of the regulation and a signature stating the place and date.

A new DoC will be required whenever packaging is changed in a way that could affect its legal conformity.

New substance restrictions

The PPWR also introduces restrictions on PFAS in food-contact packaging.

Under Article 5, businesses cannot place food-contact packaging on the EU market if it meets or exceeds specified PFAS concentration limits.

The restrictions have been the subject of industry debate, with concerns previously raised around technical, legal and methodological issues.

A European Commission notice published in June 2026 stated that there is currently no harmonised EU-level methodology for calculating PFAS in food packaging. Instead, it recommended a stepwise approach using total fluorine quantification and direct total oxidisable precursors analysis.

Packaging produced before 12 August 2026 that exceeds the PFAS limit does not need to be withdrawn from the market.

The Commission has also clarified that EN 13428:2004 can no longer create a presumption of conformity for minimising dangerous substances and demonstrating conformity after 12 August 2026.

However, until an updated harmonised standard becomes available, businesses can continue using EN 13428:2004.

Recyclability becomes a requirement

Article 6(1) of the PPWR also now applies, requiring all packaging placed on the EU market to be recyclable.

Under the regulation, packaging must be designed for recyclability, using secondary raw materials of comparable quality to primary raw materials.

It must also be separately collected, sorted into specific waste streams without contaminating them and recycled at scale.

However, the European Commission has until 1 January 2028 at the latest to establish the detailed design-for-recycling criteria.

Until then, businesses can refer to EN 13430 and the framework of the previous Packaging and Packaging Waste Directive when assessing compliance with the relevant requirements.

A step towards a more circular packaging system

Commenting on the new measures, European Commissioner for Environment, Water Resilience and a Competitive Circular Economy Jessika Roswall said the PPWR is intended to reduce waste, increase recycling, make food-contact packaging safer by limiting harmful substances such as PFAS and reduce dependence on virgin raw materials.

The regulation also aims to replace fragmented national rules with a more consistent framework for businesses operating across the EU.

However, the introduction of new requirements brings adjustment costs for businesses as they adapt to the new rules.

With the first PPWR measures now legally binding, packaging businesses placing products on the EU market will need to account for the new requirements around documentation, materials, substances and recyclability.