Businesses and Institutions: compliance efforts are still ongoing

One month has passed since Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) became applicable.

Since 12 August 2026, the new European regulatory framework has been generally applicable. However, its implementation follows a progressive timetable: some obligations are already in force, while others will apply over the coming years or still require the adoption of the relevant technical provisions.

Although no official data are yet available on the level of compliance achieved, surveys carried out by private organisations indicate that the situation is still evolving. Market research shows that a large proportion of the companies surveyed have begun mapping the packaging concerned and requesting the necessary documentation from their suppliers. However, the overall level of preparedness still appears limited, and only a very small number of companies consider their compliance process to be complete.

The process is also still ongoing at institutional level. By the end of August, only two Member States had reportedly completed their national adaptation measures, while the
EUROPEN PPWR Tracker
indicated that only 5 of the 30 secondary legislative acts provided for under the Regulation had been adopted.

The PPWR is therefore applicable, but businesses, national authorities and European institutions are still putting in place a significant proportion of the tools required for the full implementation of its complex system of obligations.

The first PPWR obligations now in force

As of 12 August, before placing packaging on the European Union market, manufacturers must ensure that they have complied with the PPWR requirements already applicable to the specific type of packaging concerned.

Before placing packaging on the market, the manufacturer must also:

• carry out the conformity assessment;
• prepare the technical documentation and the relevant EU Declaration of Conformity;
• ensure that the packaging can be identified and traced by indicating its type, batch number, serial number or another suitable identification element;
• indicate on the packaging its name, registered trade name or registered trademark, as well as its postal contact details and, where available, electronic means of communication;
• establish appropriate procedures to ensure that conformity is maintained in series production.

Pursuant to Article 3(1), point 13, a manufacturer is a natural or legal person who manufactures packaging or a packaged product. A person who has packaging or a packaged product designed or manufactured under its own name or trademark is also considered a manufacturer, even where the physical production is carried out by a third party. The Regulation provides for a specific exception for certain micro-enterprises, subject to the conditions laid down in the same provision.

The substantive provisions already applicable include the restriction on PFAS in food-contact packaging. From 12 August 2026, such packaging may not be placed on the market if it contains PFAS in concentrations equal to or above the limits laid down in Article 5(5) of the PPWR.

Where packaging placed on the market is found not to comply with the Regulation, the manufacturer must promptly take the necessary corrective measures, including withdrawal or recall where appropriate.

Compliance documentation must be retained for 5 years for single-use packaging and 10 years for reusable packaging.

Towards 2030: the next PPWR obligations

Not all the new environmental requirements introduced by the PPWR are already applicable.

Obligations relating, among other things, to recyclability, minimum recycled plastic content, packaging minimisation, and certain restrictions and requirements concerning reuse will progressively become applicable over the coming years, in many cases starting from 2030.

Companies are advised to verify that all packaging placed on the market from 12 August 2026 is properly documented, identified and compliant with the requirements already applicable, while at the same time planning the necessary adjustments in preparation for the subsequent PPWR deadlines.

For further information, write to:
regulatoryaffairs@trusticert.com