📌 Now that the PPWR implementation deadline has well and truly passed, ESG researcher Rosaida Brahim reflects on what happened and what is expected to happen in the near future.
The Packaging and Packaging Waste Regulation (PPWR) aims to reduce packaging related waste by making sustainable packaging design the standard across the EU market.
Although it was officially adopted in 2024, we've just passed the first real implementation deadline on 12 August 2026. And though legislation like this isn't new (the PPWR replaces the similarly named PPWD, the Packaging and Packaging Waste Directive), it requires many businesses to do a complete overhaul of their existing packaging practices.
It doesn't matter how large or small your company is, and it doesn't matter what sector your company is in. If your company places packaging or packaged goods on the EU market, there is a very good chance you're obligated to meet the PPWR's compliance standards.
This includes companies who are taking packaging already on the market and personalizing it for their own brand. So even if you're convinced you don't have any obligations under the PPWR, it's always a good idea to double check.
It has been about two months since the Packaging and Packaging Waste Regulation (PPWR) implementation deadline passed.
These are the obligations that have been binding since 12 August 2026:
| The EU-Declaration of Conformity (EU-DoCs) | |
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All packaging types placed on the market must have a signed EU-DoC. The EU-DoC, which pledges that all technical documentation has been completed, and all due diligence has been carried out, is legally binding and is the reference guide for authorities. |
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| EPR registration | |
| Your business needs to be registered in the dedicated EPR register of every EU Member State where your packaging is entering the market.
In the Netherlands that runs through Verpact, in Germany through the LUCID register, and in Italy through CONAI, each with its own registration, reporting and fee structure. There is no single EU-wide registration. |
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| Substance restrictions on PFAS and heavy metals | |
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Packaging placed on the market before 12 August 2026 may be used up; packaging placed on the market after that date must comply. |
The PPWR contains no general grace period. There is, however, a gap of sorts in how it is enforced.
Under Article 68(1), Member States have until 12 February 2027 to lay down their penalty rules and notify them to the Commission. Penalties must be effective, proportionate and dissuasive, and under Article 68(2) they must include administrative fines for infringements of Articles 24 to 29. Most Member States have not yet published PPWR-specific penalty regimes. Germany, for example, has scheduled the fines for direct PPWR infringements in its new Packaging Law Implementation Act (VerpackDG) to apply from 12 February 2027.
That does not mean compliance can wait until February. The PPWR falls under the EU's market surveillance framework (Regulation (EU) 2019/1020, via Article 66), so national authorities can act today. Where a DoC is missing or incorrect, Article 62 allows authorities to require corrective action and, if that doesn't happen, to restrict or withdraw the packaging from the market. For many businesses, a forced withdrawal of stock would be more costly than a fine.
If you are not yet fully compliant, the priority is to get there as soon as possible.
The Packaging and Packaging Waste Regulation (PPWR) has defined different roles, each with their own set of obligations, in order to reach its very ambitious goals.
As a business your role — as manufacturer, supplier, distributor, or trader — is largely defined. But the European Union and each of its Member States also have roles to play, and this is where question marks start popping up.
That's because, in order to successfully fulfill their obligations, businesses are at times dependent on the EU and its Member States to meet their deadlines.
Take 12 August 2026. Under Article 12(6), the Commission was due to adopt implementing acts by that date establishing a harmonized label and the specifications for labelling requirements and formats, as well as the methodology for identifying the material composition of packaging using standardised, open digital marking technologies.
And just as many businesses missed their PPWR deadlines, so did the Commission. Neither act has been adopted. In late October 2026, the Commission indicated it now expects to adopt the labelling act in the second quarter of 2027, after a public consultation. Because the harmonized label applies from 12 August 2028 or 24 months after the implementing act enters into force, whichever is later (Article 12(1)), a 2027 act realistically pushes on-pack labelling to around mid-2029.
This isn't a reason for businesses to push back their PPWR implementation strategies. The obligations they need to meet have been set and can now be enforced.
For those who successfully navigated the 12 August 2026 deadline, there isn't much time to catch your breath. The Packaging and Packaging Waste Regulation (PPWR) is a staggered regulation, with obligations phasing in over more than a decade.
It's not enough to be up to date (or, for many, to catch up) to the latest set of PPWR obligations.
There are steps your company can take today that will make tomorrow's compliance obligations easier to fulfill:
Build one packaging dataset
Record materials, weights, components, suppliers and countries of sale for every packaging type. The same data feeds your DoCs, EPR reporting and, later, your labels.
Get supplier evidence in writing
Collect material declarations, PFAS and heavy-metal test results and recycled-content certificates now, rather than chasing them before each deadline.
Map your role per country
Your company can be a manufacturer in one market and an importer or producer in another, each with different obligations.
Check recyclability before 2030
From 2030, packaging must meet design-for-recycling criteria (Article 6), and EPR fees will increasingly reflect recyclability performance. Redesigns take time, so start with your highest-volume packaging.
Plan for recycled content and empty space
Plastic packaging faces minimum recycled-content targets (Article 7), and grouped, transport and e-commerce packaging a 50% maximum empty-space ratio (Article 24). Securing recycled material and resizing packaging both have long lead times.
Assign someone to track secondary legislation
Labels, producer registers and recyclability grades all depend on acts the Commission still has to adopt. Knowing when they land lets you act quickly.
Compliance with the Packaging and Packaging Waste Regulation (PPWR) is essential for any business placing packaging or packaged goods on the EU market, and it's much easier said than done.
Now that the first major mountain has been scaled, businesses need to be ready for the next phases of implementation.
MasterSustainability.today offers an automated, end-to-end solution for companies working towards their PPWR obligations: from preparing your Declarations of Conformity (DoCs) to navigating your EPR obligations to being audit ready.
Ready to face the next mountain? Explore our PPWR solution and request a brochure.
Sources
Packaging and Packaging Waste Regulation - EU - 2025/40 - EN - PPWR - EUR-Lex
Verpact
Packaging Europe — EU Commission misses deadline to harmonize PPWR’s labelling requirements
EU Packaging Regulation: PPWR obligations from 2026 - WKO