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What to expect from PPWR in 2026

Written by Shubhra Dixit | Feb 25, 2026 1:58:29 PM

📌 In this article, ESG researcher Shubhra Dixit explains what the EU’s Packaging and Packaging Waste Regulation (PPWR) means in practice for 2026 and what companies should have in place by 12 August 2026.

What companies can expect from PPWR in 2026 (and how to prepare)

PPWR will move from “future law” to daily reality in 2026. For EU businesses, including those in the Netherlands, 2026 is the year you need working processes, not just PowerPoints.

In this article we will walk through what companies can expect in 2026 and how they can prepare:

(1.) PPWR in 30 seconds

(2.) 12th of August 2026, the big switch

(3.) What PPWR will change for companies in 2026

(4.) How EU companies should prepare

(5.) In conclusion: from compliance project to normal business

 

1. PPWR in 30 seconds

The Packaging and Packaging Waste Regulation (PPWR) entered into force on 11 February 2025 and replaces the old Packaging and Packaging Waste Directive (PPWD). It creates a single, harmonized rulebook on packaging for all EU member states, covering design, recyclability, reused and recycled content, labelling and waste prevention.

The PPWR aims to reduce packaging waste by making sustainable packaging design the standard across the EU market. It applies to all companies placing packaging or packaged products on the EU market, regardless of sector or origin.

The first obligations begin applying from 12 August 2026, with additional targets and systems in later years.

 

2. 12th of August 2026: the big switch 

The key change in 2026 is that PPWR moves from “in force” to “applicable”. For most companies this means three things.

2.1 You are formally in scope

PPWR covers all packaging placed on the EU market and all packaging waste, regardless of material, sector or country of manufacture. That includes consumer packaging, transport packaging, ecommerce packaging and pallets, whether made of paper, plastic, glass, metal or wood.


2.2 Old national patchwork loses its central role

Because PPWR is a regulation, it applies directly and largely replaces the previous 94/62/EC Packaging Directive and many of the more fragmented national implementations. Dutch businesses still deal with national producer responsibility systems, but the core design and performance rules now come from one EU framework.

2.3 New obligations come into play

From 12 August 2026, most horizontal requirements begin to apply, with more specific targets and bans phased in later years. Authorities will expect companies to be able to show how they comply, not just that they intend to.


3. What PPWR will change for companies in 2026

The PPWR timeline stretches to 2040, but 2026 is about putting the foundations in place. For companies in the Netherlands and across the EU, the main 2026 priorities are conformity assessment documentation and recyclability grades.

 

3.1 Conformity assessment and documentation

Manufacturers and importers must perform a conformity assessment for each packaging type and keep technical documentation to prove compliance with the sustainability requirements in Articles 5 to 12. This includes design for recycling, minimization, restrictions on certain formats and hazardous substances, and conditions for compostability or reuse.

By August 2026 you need a functioning process to:

  • Group packaging into sensible “families” and record their materials, components and weights.

  • Check each family against PPWR design and material rules and record the assessment.

  • Produce and maintain EU DoC* that follow the PPWR model and can be shown to market surveillance authorities.

*The EU Declaration of Conformity (DoC) is the formal document in which a company confirms that a packaging type meets all applicable PPWR requirements. It links the conformity assessment, technical documentation and supporting evidence into one auditable statement that authorities can request at any time. In practice, the DoC becomes the central proof that packaging may legally be placed on the EU market.

For Dutch businesses used to lighter documentation under the old directive, this is a cultural shift toward packaging being an auditable compliance topic.

 

3.2 Design for recyclability and performance grades

PPWR sets out that, by 2030, all packaging must meet recyclability criteria and will be rated A, B or C based on recyclability performance. Packaging that does not meet the minimum recyclability performance class under the PPWR will be progressively restricted or banned according to phased timelines, with stricter requirements applying from 2030 and 2035



You do not need to hit those 2030 thresholds in 2026, but you do need to:

    • Start assessing whether each packaging family is designed so it can be collected, sorted and recycled without harming other streams.​
    • Identify obvious noncompliant designs and plan changes ahead of the 2030 deadline.

For Dutch brands that already optimise for local recycling schemes, PPWR will force a shift to think in terms of EU‑wide recyclability rather than only national guidelines.​

 

3.3 Substance restrictions: PFAS and heavy metals

PPWR introduces stricter limits on certain hazardous substances in packaging, including per‑ and polyfluoroalkyl substances (PFAS) in some food‑contact applications and heavy metals above defined thresholds. From 12 August 2026, packaging that exceeds those limits cannot be placed on the EU market.​

In practice, 2026 is the year to:

    • Map where PFAS, inks, coatings and additives appear in your packaging portfolio.​
    • Obtain updated compliance declarations from suppliers and replace high-risk materials.​

This will be particularly relevant for food, cosmetics and e‑commerce sectors where specialized barriers and coatings are common.​

 

3.4 Reuse and refill systems begin to matter

PPWR introduces reuse and refill obligations for certain packaging types, such as beverage packaging, food service and transport packaging, with targets ramping up after 2026. The regulation also requires that reuse systems for reusable packaging are in place from the time the PPWR applies.
For 2026, this means:

  • Mapping which of your packaging falls into reuse relevant categories in PPWR.

  • Starting pilots or partnerships for refill and reusable solutions in horeca, retail and logistics where Dutch local infrastructure can be an advantage.

  • Prepare for “Bring Your Own Container” (BYOC) requirements in horeca.

From 12 August 2026, food and beverage businesses must allow customers to bring their own containers for takeaway food and drinks without additional charges or less favorable conditions. In practice, this means horeca operators need procedures to safely accept customer containers, train staff, and ensure hygiene and operational workflows support refill options.

The exact numerical reuse targets are mostly post 2026, but authorities will expect to see that companies operating in affected segments are already planning for them.

 

3.5 Labelling and information management

PPWR introduces harmonized labelling requirements for packaging, including information on material composition, recyclability, waste sorting and, from August 2028, recycled content for certain plastics.​

In 2026, the priority is not yet reprinting every label, but:

    • Understanding which labelling elements are mandatory for your packaging categories.​
    • Building the data backbone so that when you print a recyclability or recycledcontent claim, it is consistent with your conformity assessment and technical documentation.​

For Dutch companies selling across borders, consistent EU-aligned labelling will reduce the need for country specific packaging variants over time.​ 

 

4. How EU companies should prepare in 2026

The EU market is already used to extended producer responsibility and relatively ambitious waste policies, but PPWR will still create work. If you operate in or export to theEU, 2026 is the year to:​

    • Build a packaging data hub: Centralise packaging specifications, materials, weights and components in one system so you have a single source of truth for EU compliance and EPR reporting. This is the basis for every PPWR obligation, from design checks to declarations of conformity.​
    • Set up a repeatable conformity assessment workflow: Define clear steps and responsibilities for checking each packaging family against PPWR requirements and issuing EU declarations of conformity. Automating parts of this process can reduce the risk of errors and make audits less painful.​
    • Prioritise “at risk” packaging: Identify packaging formats that are heavy, complex, nonrecyclable, PFASladen or dependent on exemptions, and prioritise redesign work on those lines between 2026 and 2030. This is especially important for Dutch exporters selling into multiple EU markets with varying waste infrastructures.​
    • Align PPWR work with other ESG regulations: PPWR interacts with other EU rules such as the Deforestation Regulation, CSRD and Digital Product Passport initiatives. Using shared systems for data and governance reduces duplicate work and makes your sustainability reporting more coherent.
    • Engage a professional: MasterSustainability.today helps automate your ESG needs, from PPWR to EUDR, from Carbon Management to CBAM. Reach out today for a personalized solution demo.

 

5. In conclusion: from compliance project to normal business

By the end of 2026, PPWR should no longer feel like a standalone project. For companies in the Netherlands and the wider EU, it will be part of routine product development, procurement and reporting: packaging designs are checked against PPWR, data is captured once and reused, and compliance files are always ready for an inspection.

The details and targets for 2030, 2035 and 2040 will keep evolving, including through delegated and implementing acts. What matters most in 2026 is that you have built the basic machinery: robust data, clear roles, a working conformity assessment process and a realistic roadmap for your riskiest packaging.​