Today, 12 August 2026, marks the general application date of the EU Packaging and Packaging Waste Regulation (PPWR), starting the phased rollout of new requirements aimed at reducing packaging waste, improving circularity and further harmonising packaging rules across the Single Market.

Among the requirements relevant from today are the PFAS limits for food-contact packaging, the 100 mg/kg combined limit for certain heavy metals, requirements relating to substances of concern, as well as manufacturer identification, technical documentation and Declaration of Conformity obligations. The general requirement that packaging placed on the market must be recyclable also applies, while the detailed Design-for-Recycling methodology will only become mandatory later.

In addition to its guidance document he Commission has also recently published an updated version of its PPWR FAQs, shared with members on 3 August, providing several important practical clarifications – in particular regarding existing stocks, identification and traceability, technical documentation and flexible enforcement.

More information

• ‍Existing/carry-over stock: importantly, the Commission has confirmed that packaging already produced or held in stock before 12 August, but not yet placed on the market, does not need to be destroyed, remanufactured or physically relabelled. The identification and manufacturer information required under Article 15 may instead be provided through accompanying documentation. This addresses an issue repeatedly raised by FESI members, particularly regarding existing shoeboxes, polybags and other carry-over packaging.‍
• Identification and traceability: identification does not need to be at individual unit level. A type, model, batch or equivalent identifier linked to the relevant compliance documentation may be sufficient. Standard items such as tape, bags or desiccants can therefore generally be managed through batch-level traceability.‍
• Technical documentation: external laboratories and service providers may support conformity assessment, but the manufacturer remains legally responsible for drawing up and maintaining the technical documentation. Suppliers are required to provide the information needed to demonstrate compliance.‍
• Substances of concern: the obligation to minimise substances of concern applies from today. Pending an updated standard, Annex C of EN 13428:2004 may be used as an assessment method, although it does not provide a full presumption of conformity. For the existing heavy-metals limit, the Commission recommends CEN report CR 13695-1/2000. For food-contact packaging, PFAS limits also apply from today, while work towards a fully harmonised EU testing methodology continues.‍
• Enforcement: The updated FAQs also contain a new section on enforcement. The Commission has asked national market-surveillance authorities to take a supportive and proportionate approach during the initial implementation period, prioritising warnings and giving economic operators a reasonable opportunity to take corrective action before moving towards measures such as prohibition, recall or withdrawal.

However, this guidance is not legally binding on national authorities. Companies should therefore remain prepared to provide their Declaration of Conformity and supporting technical documentation when requested.

Timeline:

The PPWR is only starting to apply today: a significant part of the framework still needs to be developed through around 30 pieces of secondary legislation, including delegated and implementing acts, standards and further guidance.

Key upcoming milestones include:

• 2028: harmonised packaging material/sorting labelling requirements start applying;
• 2029: new labelling requirements for reusable packaging;
• 2030: major Design-for-Recycling requirements, recycled-content targets for plastic packaging, packaging minimisation requirements, the 50% empty-space limit for grouped, transport and e-commerce packaging, and several reuse targets;
• 2035: packaging will also need to meet the “recycled at scale” requirement; and
• 2040: higher recycled-content and reuse targets will apply.

Work on the secondary legislation is already underway. On 6 August, the Commission opened feedback on the draft implementing regulation establishing harmonised formats for national packaging producer registers and reporting. As previously communicated, FESI is collecting member input on this initiative.

Next Step:

FESI is currently compiling implementation challenges and practical questions from members with a view to sharing these with the European Commission, Member States and relevant partner organisations. Particular attention will be given to divergent national interpretations and practical difficulties encountered during the first months of application.