From directive to regulation
For thirty years, EU packaging rules came from Directive 94/62/EC, implemented differently in each Member State. The Packaging and Packaging Waste Regulation – Regulation (EU) 2025/40, the PPWR – replaces it. It was published in the Official Journal on 22 January 2025 and, under Article 71, applies from 12 August 2026.
That date is now six months away. Not every obligation starts on that day: the regulation phases in its most demanding requirements – recyclability, recycled content, harmonised labels – from 2028 onwards, often tied to delegated or implementing acts that are still to come. But several things do change on 12 August 2026, and they need preparation now.
For the full picture of the regulation, see our PPWR regulation guide and the glossary entry on the Packaging and Packaging Waste Regulation.
What changes on 12 August 2026
The legal basis switches. Article 70 repeals Directive 94/62/EC with effect from 12 August 2026. A small number of directive provisions continue for a transition period – for example, rules on recycling targets and on data reporting until the end of 2028, and the transmission of data to the Commission until the end of 2029 – but the product requirements come from the regulation from that day. National rules transposing the directive no longer set the baseline.
Packaging becomes a product with a conformity file. Article 15 makes the packaging manufacturer responsible for placing only packaging on the market that meets the requirements laid down in or pursuant to Articles 5 to 12. Before placing packaging on the market, the manufacturer must carry out the conformity assessment procedure in Annex VII (Article 38), draw up the technical documentation, and – once compliance is demonstrated – draw up an EU declaration of conformity following the model in Annex VIII (Article 39).
The documentation has to be kept for 5 years for single-use packaging and 10 years for reusable packaging (Article 15(3)). Packaging must also bear a type, batch or serial number or other identifying element (Article 15(5)), and the manufacturer’s name and postal address must be on the packaging or available through a QR code or other data carrier (Article 15(6)).
Who is the manufacturer? Under Article 3, the manufacturer is the person who manufactures packaging or a packaged product – but where someone has packaging or a packaged product designed or manufactured under its own name or trademark, that person is the manufacturer. For many brand owners and importers, that means the obligations are theirs, not their packaging supplier’s. Our problem page am I a packaging producer? works through the common cases.
PFAS in food-contact packaging (Article 5(5))
The most concrete change on 12 August 2026 concerns per- and polyfluoroalkyl substances. From that date, food-contact packaging shall not be placed on the market if it contains PFAS at or above:
- 25 ppb for any PFAS measured with targeted PFAS analysis (polymeric PFAS excluded);
- 250 ppb for the sum of PFAS measured by targeted analysis (polymeric PFAS excluded);
- 50 ppm for total PFAS, including polymeric PFAS.
If total fluorine exceeds 50 mg/kg, the supplier must, on request, provide proof of how much of it is PFAS and how much is not, so the packaging manufacturer can complete its technical documentation. Article 5(6) requires compliance with the PFAS limits and with the heavy-metals limit to be demonstrated in that documentation.
Article 5(4) also continues a familiar rule: the sum of lead, cadmium, mercury and hexavalent chromium in packaging or its components shall not exceed 100 mg/kg.
What to do now: identify every food-contact packaging item in your range – papers, boards, coated trays and wrappers are typical candidates – and ask suppliers for PFAS test data or declarations that refer to the Article 5(5) limits. If your products are themselves food-contact articles, see also selling a food-contact product.
What comes later
Much of the PPWR is scheduled for later dates, several of which depend on acts the Commission has still to adopt. In each case the regulation sets “the later of” a fixed date and a period after the relevant act:
- Recyclability (Article 6): design-for-recycling criteria apply from 1 January 2030 or 24 months after the delegated acts under Article 6(4) enter into force, whichever is later; from then, packaging must reach recyclability grade A, B or C. The “recycled at scale” condition follows from 1 January 2035 at the earliest.
- Recycled content (Article 7): plastic parts of packaging must contain minimum shares of post-consumer recycled content from 1 January 2030 or three years after the implementing act on calculation and verification, whichever is later.
- Harmonised labels (Article 12): packaging must carry a harmonised label on material composition from 12 August 2028 or 24 months after the implementing acts under Article 12(6) and (7) enter into force, whichever is later. The regulation requires the Commission to adopt those implementing acts by 12 August 2026. Packaging manufactured or imported before the labelling deadlines may still be made available for three years after the requirement takes effect (Article 12(12)).
These dates are a reason to start supplier conversations early, not to change artwork today: the label design and the recyclability criteria themselves are not yet laid down.
A preparation order for 2026
- Map your packaging. List each packaging item per product, with material, supplier and whether it is food-contact.
- Settle who the manufacturer is for each item under Article 3, and who will sign the declaration of conformity.
- Close the PFAS question for food-contact packaging before August, with test data or supplier declarations that cite the limits.
- Build the technical documentation per Annex VII and prepare a declaration of conformity per Annex VIII.
- Add identification and contact details – batch or type number and manufacturer address – to packaging or its data carrier.
- Track the later dates for recyclability, recycled content and labels, and the Commission acts they depend on.
Extended producer responsibility and registration rules also continue under the regulation, see the glossary entry on extended producer responsibility. If you are still working out what the rules mean for your business, start with what the packaging rules mean for me.
How Conphora helps
The PPWR turns packaging into a regulated product with its own file. Conphora gives you the structure for it:
- Packaging records per product – material, supplier, food-contact status and the person responsible as manufacturer.
- Supplier requests for PFAS and heavy-metal data, with answers stored next to the packaging item.
- Technical documentation and declarations of conformity kept with versions and retention dates.
- Deadline tracking for 12 August 2026 and the later PPWR dates as the Commission adopts the acts they depend on.
Six months to 12 August 2026. Start with the PFAS check and the manufacturer question – both take supplier time. See plans and pricing →