On August 12, 2026, Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC (the “PPWR”), became applicable. The PPWR applies to packaging placed on the EU market, regardless of the material used.

The key requirements applicable from August 12, 2026 include:

• requirements concerning substances in packaging, in particular minimizing the presence and concentration of substances of concern;
• new limits on per- and polyfluoroalkyl substances (PFASs) in food-contact packaging;
• a general requirement that all packaging placed on the market be recyclable; the detailed design-for-recycling criteria and the related requirements for demonstrating conformity will, however, apply only at a later stage;
• conformity assessment of packaging, preparation of technical documentation and an EU declaration of conformity;
• identification of the packaging and the manufacturer;
• obligations of importers and distributors to verify compliance with the applicable requirements of the PPWR.

Accordingly, as of August 2026, the PPWR imposes practical obligations primarily on manufacturers, importers and distributors of packaging. Businesses concerned should therefore review the composition of the packaging they use, as well as the documentation and internal processes for demonstrating compliance with the new regulatory framework.

Further obligations concerning recycled content, packaging minimization, harmonized labeling and reuse targets will become applicable progressively between 2028 and 2040. Member States are required to lay down rules on penalties for infringements of the PPWR by February 12, 2027.