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Article Highlights:
The EU Packaging and Packaging Waste Regulation, formally Regulation (EU) 2025/40, is the EU's new framework for packaging and packaging waste. It replaced the previous Packaging and Packaging Waste Directive with a directly applicable regulation.
Before starting a data collection project, determine what role your company has under the regulation. PPWR sets different obligations for manufacturers, importers, distributors, and other economic operators. The same company may have different responsibilities depending on how a product is made, branded, imported, and sold.
Once those roles are clearly established, businesses can then identify which packaging actually needs to be assessed. A packaging inventory is one of the fastest ways to define the scope of a PPWR project. Rather than immediately surveying every supplier about every component, start with the packaging associated with products sold in the EU. Include primary packaging, secondary packaging, and transport packaging.
What should manufacturers do first to comply with the EU Packaging and Packaging Waste Regulation (PPWR)? One logical place to start is by identifying their role in the supply chain, determining which packages they place on the EU market, and requesting any missing information from their packaging suppliers. The PPWR began applying on August 12, 2026, but its requirements don’t all take effect at the same time. Manufacturers that are behind should focus first on the obligations that apply today and build out their compliance programs from there.
The good news is that catching up with the PPWR and all its requirements doesn’t mean redesigning every package right away. A faster approach is to understand what packaging is in scope, identify the information you need, address the requirements already in force, and create a plan for the obligations that will apply later.
What Is the PPWR, and Is the August 2026 Deadline Urgent?
The EU Packaging and Packaging Waste Regulation, formally Regulation (EU) 2025/40, is the EU's new framework for packaging and packaging waste. It replaced the previous Packaging and Packaging Waste Directive with a directly applicable regulation.
The PPWR covers a wide range of issues, including:
Substances in packaging
Recyclability and recycled content
Packaging minimization
Reuse
Labeling
Producer responsibility
It entered into force in February 2025 and began applying on August 12, 2026.
However, August 12 was not the deadline for every requirement in the regulation. Several major requirements have later implementation dates or depend on additional EU measures that are still being developed. For manufacturers trying to adhere to the PPWR for the first time, these distinctions matter.
The immediate task for in-scope businesses is to identify the requirements that already apply to their packaging and collect the information needed to demonstrate compliance with them. Here are some critical steps to achieving that goal.
Step 1: Confirm Your Role Under PPWR
Before starting a data collection project, determine what role your company has under the regulation. PPWR sets different obligations for manufacturers, importers, distributors, and other economic operators. The same company may have different responsibilities depending on how a product is made, branded, imported, and sold.
This is important because the company physically making the packaging is not always the only company with responsibilities. An importer placing packaged products on the EU market, for example, has its own obligations to ensure that the packaging meets applicable requirements.
Businesses should start by mapping their business model. They can then determine which legal entity manufactures the packaging for their products, which entity imports it into the EU, and which entity places the packaged product on the market. Messing up these identifications at the beginning of the compliance process can send the entire project in the wrong direction.
Step 2: Map Your Packaging Portfolio Fast
Once those roles are clearly established, businesses can then identify which packaging actually needs to be assessed. A packaging inventory is one of the fastest ways to define the scope of a PPWR project. Rather than immediately surveying every supplier about every component, start with the packaging associated with products sold in the EU. Include primary packaging, secondary packaging, and transport packaging. Also consider e-commerce packaging where applicable.
The inventory does not need to be perfect on day one. Its purpose is to give organizations a workable picture of their packaging portfolio. Once businesses have captured the packaging configuration, materials, suppliers, products that use the packaging, and relevant EU markets, they can then go about prioritizing the gaps. High-volume products, food packaging, packaging with limited material information, and packaging supplied through complex supply chains are good places to start. This allows manufacturers to focus their resources where the compliance risk and potential data gaps are the greatest.
Step 3: Send Supplier Data Requests Immediately
For many companies, supplier data collection will take longer than the internal assessment. Article 16 of the PPWR requires suppliers of packaging or packaging materials to provide manufacturers with the information and documentation needed to demonstrate conformity with applicable requirements. This can include information needed for the technical documentation required under the regulation. That makes supplier outreach one of the first actions manufacturers should take.
Businesses should use a standard request that identifies the specific packaging or packaging component being assessed. Depending on the packaging and the requirements that apply, the request may need information about material composition, substances, applicable food contact documentation, specifications, or other supporting evidence. Avoid asking suppliers for a vague statement that everything they sell is PPWR compliant. A general declaration may not provide enough information to support your assessment of a specific packaging configuration, creating potential regulatory problems further down the line.
The goal is simple: identify what information you have, what information is missing, and which suppliers need to respond.
Step 4: Prioritize the PPWR Substance Restrictions That Apply Now
Chemical compliance is one of the areas that requires immediate attention. The PPWR requires packaging to be manufactured in a way that minimizes the presence and concentration of specific substances of concern. It also maintains a limit for the combined concentration of lead, cadmium, mercury, and hexavalent chromium in packaging or packaging components. The combined concentration of these chemicals must not exceed 100 mg/kg.
The most significant new substance requirement that began applying on August 12, 2026, concerns PFAS in food contact packaging. Food contact packaging cannot be placed on the EU market if it contains PFAS at or above the applicable limits. Those limits are 25 ppb for any targeted PFAS, 250 ppb for the sum of targeted PFAS, and 50 ppm for total PFAS, including polymeric PFAS. The regulation also contains specific provisions concerning total fluorine measurements above 50 mg/kg. The European Commission has issued guidance on how the PFAS limits may be tested and enforced. Importantly, there is no general transition period allowing newly placed food contact packaging containing noncompliant levels of PFAS to continue entering the market after August 12, 2026.
Manufacturers should also remember that PPWR does not replace other EU chemical requirements. REACH restrictions and applicable food contact materials legislation may continue to restrict substances used in packaging. This is where phthalates and bisphenols may become relevant. They are not subject to one universal standalone PPWR concentration limit comparable to the PFAS limits. Instead, their restrictions depend on the applicable chemical or food contact legislation and the intended use of the packaging.
Step 5: Prepare the Declaration of Conformity
Collecting supplier information is only part of the job. Manufacturers must also carry out the applicable conformity assessment, prepare the technical documentation required under Annex VII, and draw up an EU Declaration of Conformity when compliance with the applicable requirements has been demonstrated. The declaration follows the structure set out in Annex VIII.
For a company working quickly, the best starting point is to create a clear record for each packaging configuration. That record should identify the packaging and show which requirements apply. It should also connect those requirements to the evidence supporting compliance, such as supplier documentation, material specifications, test reports, or other relevant records. The Declaration of Conformity should identify the packaging covered by the declaration in a way that allows traceability, and should not function simply as a broad statement with no connection to the packaging being assessed.
This does not necessarily mean creating a completely separate file for every finished product. Where the same packaging configuration is used across multiple products, manufacturers may be able to organize the supporting evidence in a way that avoids unnecessary duplication while maintaining clear traceability.
Step 6: Address EPR Obligations in the Markets Where You Sell
As part of a company’s overall compliance project, packaging EPR should be reviewed as well. Manufacturers should be careful not to assume, however, that PPWR created one immediate EU-wide registration system. Producer responsibility obligations and registration requirements remain closely connected to individual member state systems. Companies selling packaged products across the EU may already have obligations in multiple countries under national packaging EPR rules.
The PPWR establishes a framework for national producer registers and further harmonization, but the timing and implementation of those requirements are not as simple as completing one new registration by August 12, 2026. The practical step for manufacturers is to review the countries where packaged products are currently sold and confirm whether the responsible legal entity is properly registered and meeting applicable national EPR requirements.
Organizations should not wait until the technical documentation project is complete to start this review. EPR compliance and product compliance are related, but they involve different processes that can move forward at the same time.
What Manufacturers Can Deprioritize for Now
This is where companies can save a significant amount of time. Not every major PPWR requirement applies today. Manufacturers should begin planning for future requirements, but they don’t need to complete every future packaging redesign before addressing the requirements already in force.
The detailed recyclability requirements, for example, are scheduled for implementation at a later date. The design for recycling requirements generally begins from January 1, 2030, or later depending on the timing of the relevant delegated acts. Other recycling obligations begin even later. Minimum recycled content requirements for plastic packaging are also generally scheduled for 2030 or thereabouts, depending on future implementation measures.
Of course, this doesn’t mean that manufacturers should ignore these requirements. Packaging redesigns, material changes, and supplier qualification can take years. But there’s a difference between planning for 2030 and treating every 2030 target as an immediate compliance deadline. For companies still catching up in 2026, the priority should be understanding the requirements that apply now, collecting the supporting data, and using that work to prepare for future changes.
Move From Manual PPWR Compliance to Centralized Compliance Tracking
For manufacturers that are behind on PPWR, the biggest challenge often comes from the struggle to organize all the data and information required to achieve adherence. Packaging data may be spread across multiple teams, product specifications, supplier emails, test reports, and spreadsheets. Without a clear way to connect that information and integrate it into a unified whole, it can be exceedingly difficult to see which packaging requirements are complete and where the gaps remain.
Compliance tool Z2 provides a centralized compliance system that can help bring packaging, supplier, substance, and regulatory information into a single intuitive dashboard. Manufacturers can use Z2 to track supplier requests, identify missing evidence, connect compliance records to specific packaging configurations, and prepare for future PPWR requirements as they come into effect.
To learn more about Z2 and how it can help businesses comply with the EU PPWR, schedule a free trial with one of our product experts.
