New EU rule turns packaging into a compliance product — many brands lack the paperwork

Since 12 August 2026, packaging may only be placed on the EU market if a declaration of conformity exists for it. The requirement follows from the EU’s Packaging and Packaging Waste Regulation (PPWR), which now applies — and it covers not only packaging manufacturers but every business that sells packaged products on the European market.

Regulation (EU) 2025/40 entered into force on 11 February 2025 and applies from 12 August 2026. From that date four requirements apply: a declaration of conformity must be drawn up for all packaging before it is placed on the market. The packaging must carry an identification — a type, batch or serial number — so that the declaration and the packaging can be matched. The name and contact address of the manufacturer or importer must appear clearly and durably. And all packaging must respect a combined limit of 100 mg/kg for lead, cadmium, mercury and hexavalent chromium; food-contact packaging must in addition meet new limits for PFAS (per- and polyfluoroalkyl substances).

Public debate has centred on PFAS in pizza boxes and takeaway packaging. But the other requirements reach far wider: the box around a lamp, the bag around a sweater, the blister pack around a toy and the carton around a piece of furniture are all packaging within the meaning of the regulation. Brands and importers that have never treated packaging as a compliance topic now face a documentation requirement that many have yet to meet.

Responsibility follows the role as economic operator. As a rule it is the manufacturer of the packaging who must ensure conformity — but the business that places the packaged product on the market must be able to demonstrate that the requirements are met. It cannot simply point to its packaging supplier, and where the goods are imported from outside the EU, the importer takes over a substantial part of the obligations.

Because the PPWR is a regulation, the rules apply directly and identically in every Member State. There is no national transposition that could delay them, and no transitional arrangement for products already on sale.

There is also uncertainty. Harmonised standards and a number of implementing acts that will specify how the requirements are documented in practice are still being prepared, and authorities’ controls on packaging are new. How strictly the rules will be enforced in the first period is therefore an open question — but that does not change the fact that the obligation applies now.

The requirements also tighten in stages: from 12 August 2028 packaging must carry harmonised labelling of its material composition, and from 2030 requirements on recyclability, minimum recycled content in plastics and limits on empty space in packaging follow.

For businesses selling packaged goods in the EU the recommendation is therefore clear: map packaging per product, obtain material declarations from suppliers, draw up declarations of conformity, and ensure identification and manufacturer or importer details on the packaging.

“The PPWR makes packaging a product with its own technical documentation, on a par with CE-marked goods. The big surprise for many brands is not the rules themselves but that the responsibility sits with them — and that the deadline has already passed,” says Conphora.

About Conphora

Conphora is a Danish platform for automated validation of, and oversight over, EU regulations and product compliance. Conphora helps companies selling products in the EU keep track of requirements, documentation and regulatory change across the supply chain.