Compliance

PPWR: what your importer must be able to file

The EU Packaging and Packaging Waste Regulation applies from 12 August 2026. If you import packaging into the EU, the documentation obligation is yours — and it cannot be pushed back onto a supplier outside the EU unless that supplier provides the paper. We provide it.

The short version

Regulation (EU) 2025/40 (PPWR) was published on 22 January 2025, entered into force on 11 February 2025 and applies from 12 August 2026 (Article 71), replacing Directive 94/62/EC.

From that date, packaging placed on the EU market must be covered by a conformity assessment and a Declaration of Conformity (DoC) (Article 15), with technical documentation kept and produced to market surveillance authorities on request.

Article 15(12) matters for buyers sourcing in Asia: under the conditions set out there, the person supplying the packaging can be treated as the manufacturer. In practice that means the supplier — not only your EU entity — may carry the conformity obligation for the packaging as placed on the market.

What we hand over with an order

• Declaration of Conformity naming the packaging, the material and the applicable harmonised standards.
• Technical documentation file: material composition by layer, grammage, adhesives and coatings, and statements on substances of concern.
• Migration and food-contact test reports from accredited laboratories, where the packaging touches food.
• Recyclability statement — mono-material or multilayer, how it sorts in EU collection streams, and what limits recyclability if it is multilayer.
• Data your registration needs: material type and weight per unit, so your importer can complete LUCID (Germany) or the equivalent national register.

Requirements that arrive later — plan the structure now

• Recyclability as a market-access condition (Article 6 and Annex II): packaging is graded A (≥95 % recyclable by weight), B (≥80 %) or C (≥70 %). Packaging below grade C cannot be placed on the market from 1 January 2030, and grade C from 2038.
• Harmonised labelling (Article 12(1)): material-composition labelling from 12 August 2028 or 24 months after the relevant implementing acts, whichever is later.
• Recycled-content requirements and restrictions on certain single-use formats phase in from 2030. As with everything above, the timetable depends on the packaging format — check the articles that apply to yours.

What this means when you specify packaging

Choosing a structure in 2026 is choosing its market access in 2030. If you want a pouch, a carton or a tray to still be sellable in the EU after 2030, the recyclability grade has to be designed in now: mono-material where the barrier allows, separable components where it does not, and a documented reason when neither is possible. That conversation belongs at the specification stage, not at the customs stage — tell us your target market and shelf life and we will quote the structures that keep their grade.

Frequently asked questions