Foundations
PPWR requirements: what applies, to whom, and when
Last regulatory verification: 12 August 2026 · 4 official sources
Every core obligation in Regulation (EU) 2025/40 mapped to its article, the role it binds, its date and the evidence it needs. Evergreen, including 2026.
Key facts
- Regulation (EU) 2025/40 entered into force on 11 February 2025 and generally applies from 12 August 2026.(S01)
- Obligations differ by role: manufacturer, authorised representative, importer and distributor each have separate duties.(S01)
- Several requirements — recyclability performance grades, recycled content, minimisation criteria — depend on secondary legislation still to be adopted.(S01)
Short answer
PPWR — Regulation (EU) 2025/40 — applies from 12 August 2026. From that date, packaging placed on the EU market needs technical documentation under Annex VII and an EU Declaration of Conformity under Article 39. Design obligations such as recyclability grades and recycled content phase in from 2030, but several of them require decisions and supplier evidence years earlier.
Every core obligation, mapped
Most PPWR summaries list topics. The useful question is narrower: which article binds you, from when, and what document proves it. That is what the matrix below answers. Rows marked as pending a secondary act have a fixed date but a method that is still being written — see the secondary legislation tracker.
PPWR requirement matrix — obligation, basis, role, date, evidence
Technical documentation exists before placing on the market
In force- Legal basis
- Article 4 and Annex VII
- Who it binds
- Manufacturer (or the operator placing packaging on the market under its own name)
- From
- 12 August 2026
- Evidence
- Annex VII file: design, materials, applicable requirements, supporting evidence
EU Declaration of Conformity drawn up and signed
In force- Legal basis
- Article 39 and Annex VIII
- Who it binds
- Manufacturer
- From
- 12 August 2026
- Evidence
- Signed Declaration referencing the packaging and the requirements met
Documentation kept and produced on request for 5 years
In force- Legal basis
- Articles 15–19
- Who it binds
- Manufacturer, importer, distributor, authorised representative
- From
- 12 August 2026
- Evidence
- Retention process and a named responsible person per configuration
Heavy metals sum limit and minimisation of substances of concern
In force- Legal basis
- Article 5
- Who it binds
- Manufacturer
- From
- 12 August 2026
- Evidence
- Supplier declarations, material specifications, analytical results where relevant
PFAS below thresholds in food-contact packaging
In force- Legal basis
- Article 5(5) and Annex
- Who it binds
- Manufacturer, importer
- From
- 12 August 2026
- Evidence
- Total fluorine screening and, where triggered, targeted PFAS analysis per component
Recyclable by design against the design-for-recycling criteria
Pending secondary act- Legal basis
- Article 6
- Who it binds
- Manufacturer
- From
- 1 January 2030
- Evidence
- Design assessment against the criteria once the delegated act is adopted
Minimum recycled content in plastic packaging
Pending secondary act- Legal basis
- Article 7
- Who it binds
- Manufacturer
- From
- 1 January 2030
- Evidence
- Verified recycled share per unit with chain-of-custody documentation
Packaging minimised in weight and volume
In force- Legal basis
- Article 10
- Who it binds
- Manufacturer
- From
- 12 August 2026
- Evidence
- Documented justification against the performance criteria in the Regulation
Empty space ratio no higher than 50%
Phases in- Legal basis
- Article 24
- Who it binds
- Manufacturer, final distributor, online seller
- From
- 1 January 2030
- Evidence
- Calculated ratio per packaging configuration with the inputs retained
Harmonised material, sorting, reuse and deposit labelling
Pending secondary act- Legal basis
- Articles 12 and 13
- Who it binds
- Manufacturer, producer
- From
- After the labelling implementing act transition
- Evidence
- Artwork conforming to the harmonised symbols and data-carrier specification
Restricted single-use formats not placed on the market
Phases in- Legal basis
- Article 25 and Annex V
- Who it binds
- Manufacturer, final distributor
- From
- 1 January 2030
- Evidence
- Format screening of the range against Annex V, with exemptions justified
Reuse targets met where the operator is in scope
Phases in- Legal basis
- Articles 29 and 33
- Who it binds
- Economic operators in scope
- From
- 1 January 2030
- Evidence
- Reuse system description, rotation data and reporting
| Requirement | Legal basis | Who it binds | From | Evidence |
|---|---|---|---|---|
| Technical documentation exists before placing on the marketIn force | Article 4 and Annex VII | Manufacturer (or the operator placing packaging on the market under its own name) | 12 August 2026 | Annex VII file: design, materials, applicable requirements, supporting evidence |
| EU Declaration of Conformity drawn up and signedIn force | Article 39 and Annex VIII | Manufacturer | 12 August 2026 | Signed Declaration referencing the packaging and the requirements met |
| Documentation kept and produced on request for 5 yearsIn force | Articles 15–19 | Manufacturer, importer, distributor, authorised representative | 12 August 2026 | Retention process and a named responsible person per configuration |
| Heavy metals sum limit and minimisation of substances of concernIn force | Article 5 | Manufacturer | 12 August 2026 | Supplier declarations, material specifications, analytical results where relevant |
| PFAS below thresholds in food-contact packagingIn force | Article 5(5) and Annex | Manufacturer, importer | 12 August 2026 | Total fluorine screening and, where triggered, targeted PFAS analysis per component |
| Recyclable by design against the design-for-recycling criteriaPending secondary act | Article 6 | Manufacturer | 1 January 2030 | Design assessment against the criteria once the delegated act is adopted |
| Minimum recycled content in plastic packagingPending secondary act | Article 7 | Manufacturer | 1 January 2030 | Verified recycled share per unit with chain-of-custody documentation |
| Packaging minimised in weight and volumeIn force | Article 10 | Manufacturer | 12 August 2026 | Documented justification against the performance criteria in the Regulation |
| Empty space ratio no higher than 50%Phases in | Article 24 | Manufacturer, final distributor, online seller | 1 January 2030 | Calculated ratio per packaging configuration with the inputs retained |
| Harmonised material, sorting, reuse and deposit labellingPending secondary act | Articles 12 and 13 | Manufacturer, producer | After the labelling implementing act transition | Artwork conforming to the harmonised symbols and data-carrier specification |
| Restricted single-use formats not placed on the marketPhases in | Article 25 and Annex V | Manufacturer, final distributor | 1 January 2030 | Format screening of the range against Annex V, with exemptions justified |
| Reuse targets met where the operator is in scopePhases in | Articles 29 and 33 | Economic operators in scope | 1 January 2030 | Reuse system description, rotation data and reporting |
What applies first
The 2026 layer is documentation-led and it is the layer that catches most businesses out. Nothing about it depends on new secondary legislation: the Annex VII technical file and the Article 39 Declaration are required as the packaging is placed on the market, not later on request. If a customs authority, a retailer or a market surveillance authority asks and the file does not exist, the packaging is treated as non-compliant even where the packaging itself is perfectly well designed.
The chemical layer applies on the same date. The heavy metals sum limit carries over from the previous packaging regime, and the PFAS restriction in food-contact packaging is new and strict enough that many existing barrier coatings and greaseproof papers need supplier evidence they have never been asked for. See PFAS in food-contact packaging.
What phases in later
The 2030 layer is design-led: recyclability grades, recycled content, the empty space cap and the Annex V format restrictions. These are the expensive ones, because they touch tooling, material specification and supply agreements. Decisions taken during a normal packaging refresh in 2026 or 2027 will still be on shelf in 2030.
A note on how to read dates in PPWR
Who each obligation binds
PPWR distributes obligations across economic operators, and the roles are not interchangeable. The manufacturer carries the conformity duties: documentation, the Declaration, and the requirements themselves. Importers must verify that those duties have actually been discharged before placing packaging on the EU market. Distributors have lighter but real checking duties. Separately, the producer role carries extended producer responsibility obligations at national level. See manufacturer vs producer and importer requirements.
What "compliant" means in practice
Compliance under PPWR is evidential. For each packaging configuration you should be able to answer, on paper: which requirements apply to it, what proves each one, who holds that proof, and who signed the Declaration. Where any of those four answers is missing, the configuration is a gap, regardless of how the packaging performs physically.
Official sources for this page
Every statement above is written against these sources. Where a Commission document and the Regulation differ, the Regulation controls.
- Regulation (EU) 2025/40 — EUR-LexBinding law
- PPWR Implementation HubCommission guidance
- Commission PPWR GuidanceCommission guidance
- Commission PPWR FAQCommission guidance
- Sources last verified
- 12 August 2026
- Content last updated
- 12 August 2026
- First published
- 12 August 2026
Written and maintained by the PPWRDeclaration.com editorial team. General information about Regulation (EU) 2025/40 — not legal advice.
Why this matters
What happens if the documentation isn't there
The packaging can be restricted
Packaging without valid technical documentation is treated as non-compliant. Market surveillance authorities can require corrective action, restrict sale, or withdraw it from the market.
Penalties apply per Member State
Each Member State sets its own penalties for non-compliance, and they apply where the packaging is placed on the market — not where your business sits.
Buyers block you first
Retailers, distributors and importers increasingly ask for the Declaration and supporting evidence before onboarding. No file usually means no listing.
Late evidence costs more
Supplier declarations and lab testing have long lead times. Discovering a gap close to a deadline forces rushed testing or packaging redesign.