PPWR – New Obligations for Companies and Packaging Importers from August 12, 2026

In 2024, the European Union introduced regulations concerning packaging and packaging waste – PPWR. These regulations will enter into force on August 12, 2026. Consequently, companies placing products on the EU market will be required to have EU declarations of conformity and technical documentation for packaging. In the following years, additional obligations will be introduced, including new labelling requirements, recyclability criteria, restrictions on empty space in packaging, and mandatory recycled content in plastics.

What is PPWR?

PPWR (Packaging and Packaging Waste Regulation) is an EU regulation concerning packaging and packaging waste. Its objective is to reduce packaging waste and harmonize packaging requirements across the EU.

Who is affected by the new regulations?

PPWR will apply to, among others:

• packaging originators (i.e. companies commissioning packaging under their own brand),
• packaging manufacturers,
• importers,
• companies packing products,
• e-commerce businesses.

In practice, any product placed on the EU market in packaging will be subject to PPWR requirements.

What will change from August 2026?

From August 12, 2026, companies will need to comply with the first set of PPWR obligations. New requirements related to packaging conformity assessment will be introduced.

Each type of packaging placed on the market will have to include:

• an EU declaration of conformity,
• technical documentation,
• data enabling identification of the manufacturer or importer.

Companies will also be required to control the chemical composition of packaging. The regulation introduces restrictions on substances such as heavy metals and PFAS (so-called "forever chemicals"). In practice, this will require more extensive documentation from suppliers and tighter control over materials used in packaging production.

PPWR and Imports & Customs Clearance

The new regulations will have a significant impact on importers. The importer is responsible for ensuring that packaging complies with EU requirements—even if it has been designed by a supplier outside Europe.

This means that the importer must have documentation confirming compliance with PPWR requirements and be prepared to present it during inspections. Before placing packaging on the market, the importer will also be required to verify whether the manufacturer has carried out a conformity assessment, prepared technical documentation, and met labelling requirements.

Customs and market surveillance authorities may request:

• a declaration of conformity,
• technical documentation,
• material testing results,
• data on packaging composition.

Inspections may take place both at the border and after products have been placed on the EU market. Lack of required documentation may result in goods being detained at the border, denied entry to the market, or withdrawn from the market.

At Rohlig SUUS Logistics, we support our clients in interactions with control authorities during import processes and in providing the necessary documentation required in customs procedures.

Harmonized Packaging Labelling Across the EU

From August 12, 2028 at the earliest, new harmonized packaging labelling requirements will apply. Packaging will need to include information regarding:

• material type,
• sorting instructions,
• recyclability,
• reuse and refill systems.

In some cases, digital solutions, such as QR codes, will also be used.

What will change from 2030?

The next stage of PPWR will apply from January 1, 2030 at the earliest. This phase will introduce requirements related to designing packaging for recycling and reducing excessive use of packaging materials.

The new regulations provide for:

• mandatory use of recyclable packaging,
• minimum recycled content in plastic packaging,
• reduction of empty space in transport packaging, including e-commerce,
• expansion of reuse and refill systems.

The EU aims to eliminate packaging that is difficult to sort and recycle, such as multi-material packaging or packaging containing excessive additives that hinder processing.

For grouped, transport, and e-commerce packaging, the EU will introduce a limit on empty space—no more than 50% of total packaging volume. Filling materials will also be counted as empty space. This will require better sizing of packaging, reduction of unnecessary fillers, and optimization of packing processes.

For many companies, PPWR will necessitate adjustments to packaging design processes, documentation, supplier cooperation, and product import procedures into the EU market.