On 12 August 2026 most of the PPWR legislation becomes enforceable. From that day on: packaging you newly place on the EU market must comply. There is no general grace period and no national implementing law to postpone it. The European Commission did, however, clarify in August 2026 how enforcement will work and what happens to existing stock — and that is less abrupt than many summaries suggest.
Seven obligations become hard that day.
1. Declaration of conformity per packaging
As a manufacturer you complete a conformity assessment before 12 August 2026 for every individual packaging and, on a positive outcome, draw up an EU declaration of conformity. Without that declaration the packaging may not go on the market. You keep it for ten years for reusable packaging, five years for single-use, and provide the importer with a copy.
In practice the declaration is a packaging passport. What it must contain is set out in Annexes VII and VIII of the regulation: design data, material composition, the substantiation of minimisation, and the demonstration that harmful substances stay below the limit values. Recyclability must also be substantiated in it — this can already be done via the harmonised standard EN 13430, ahead of the performance grades that only apply from 2030.
This is not a form you fill in over an afternoon. The data is spread across the chain. See declaration of conformity.
2. Name and identification number on the packaging
From 12 August 2026 the manufacturer’s name, postal address and an electronic means of contact are on the packaging — or behind a QR code on the packaging. In addition, every packaging receives a type, batch or serial number. If that is not possible on the packaging, then on the packaged product.
This is the obligation missing from most Dutch summaries and the one that costs the most design work. Every print form, every label, every film: room has to be made. Importers moreover put their own details on it too.
3. PFAS limits in food-contact packaging
Three cumulative thresholds, all three at once: at most 25 ppb per individual non-polymeric PFAS, at most 250 ppb for the sum of non-polymeric PFAS, and at most 50 ppm total fluorine including polymers. In practice you screen for total fluorine — below 50 ppm the rest is very probably fine.
Formally this is not a PFAS ban: the PPWR sets maximum concentrations, not a product ban. The limits apply to the packaging unit as a whole, so including inks, varnishes, glues and adhesives, and they make no distinction between intentionally added and unintentionally present PFAS. No list of CAS numbers will be published: everything covered by the PFAS definition counts.
This affects pizza boxes, baking paper, grease-repellent coatings, popcorn bags. If you import from a third country, you must be able to provide proof that the packaging meets the EU standard. More on PFAS.
Not sure whether this applies to your packaging? The PPWR Check walks through your role, market and material in eight questions and shows per pillar what applies to you. Take the PPWR Check →
4. Heavy metals
The sum of lead, cadmium, mercury and hexavalent chromium remains capped at 100 mg/kg. This is not a new principle — it was already in the 1994 directive — but enforcement is getting stricter and the substantiation now goes into the technical documentation.
5. Packaging minimisation
The packaging must be designed for the minimum weight and volume its function allows, tested against the performance criteria in Annex IV. Misleading features — double walls, false bottoms, filling that suggests volume — are banned. Until 2030 you may substantiate conformity on EN 13428.
Note: the hard 50% empty space ratio only applies from 2030. The minimisation principle applies now. These are two different things. See empty space ratio.
6. EPR registration per member state
No market access without registration, and registration is per member state where you sell. Netherlands: Verpact. Germany: LUCID at the ZSVR. If you sell in a member state where you are not established, you appoint an authorised representative there.
At the same time the definition of producer changes, and with it who files the declaration. The “discarding on import” flow is no longer declared by the Dutch company that unpacks the goods, but by the foreign consignor. Contract packing is no longer exempt: a logistics service provider that unpacks and discards packaging must declare that packaging — even if the goods are not its own. See EPR, Verpact and LUCID.
7. Fulfilment and hospitality
Fulfilment service providers may only provide their services if the manufacturer or importer demonstrably meets its obligations. If you provide at least two of the services storage, unpacking, repackaging, addressing or dispatch, you can yourself be designated as the producer — for example when a seller from outside the EU delivers directly to European customers without an importer in the EU.
And hospitality must offer drinks for on-site consumption in reusable or refillable packaging. See PPWR for hospitality.
How strictly will this be enforced from day one?
This is the question on every purchasing desk, and the European Commission answered it explicitly in the second edition of its PPWR FAQ (August 2026): products will not be barred from the market on 12 August because their packaging is not yet compliant. Enforcement must not disrupt trade flows, supply chains or consumer access to goods.
Concretely, Article 62 prescribes a sequence. If an authority identifies non-compliance, it must first require the economic operator concerned to end it — so you get a warning and a reasonable window to put things right. Only if you do not take that chance and the non-compliance persists may the Member State go further: prohibit, recall or withdraw. The Commission also urges market surveillance authorities to be supportive — awareness-raising, requests for information, requests for corrective action with a realistic timeline — rather than sanction-oriented.
Do not read this as a postponement. It means that a defensible file plus a realistic plan gets you further on 12 August than panic does. Anyone with nothing to show when the authority calls is in a genuinely weak position.
What happens to your existing stock?
Here too the Commission is now clear. Packaging already placed on the market before 12 August 2026 may stay on the market — even if it does not comply with the PPWR. So you do not have to pull it back.
And packaging produced before that date but still sitting in your warehouse? It does not have to be destroyed, remanufactured or re-labelled. The information required by Articles 15(5) and 15(6) — the identifier and the manufacturer details — may be supplied for that stock via an accompanying document instead of on the packaging itself. The same applies to reusable packaging already in circulation.
For packaging you manufacture after 12 August 2026 the rule is: on the packaging itself, unless its size or nature genuinely does not allow it — then the accompanying document is permitted. Supplier no longer exists, or refuses to provide information? Then a best-efforts obligation applies: you ask the legal successor after a takeover, or you make your own substantiated assessment and record it.
What does not take effect on 12 August 2026
To pre-empt the misunderstanding: the recycled-content shares, the performance grades for recyclability, the 50% empty space ratio, the six banned formats and the reuse targets only take effect on 1 January 2030. The harmonised label arrives in 2028. Deposits on cans and PET EU-wide in 2029. The full sequence is on the timeline.
That does not mean you can wait. The decisions that make compliance possible in 2030 — material choice, supplier contracts, print forms — you make in 2026 and 2027.