PPWR since 12 August 2026: who now needs a packaging declaration of conformity
The EU Packaging and Packaging Waste Regulation (PPWR) has applied since 12 August 2026. For shops with their own brands, the key question is who the packaging's manufacturer is. Often the answer is: you.
The rule
Regulation (EU) 2025/40 applies from 12 August 2026. Before placing packaging on the market, its manufacturer has to assess it against the requirements that apply to it, draw up technical documentation (Annex VII) and issue an EU declaration of conformity (Annex VIII).
Who counts as the manufacturer
If you have packaging designed or made under your own name or trademark, that manufacturer is usually you, even if a supplier produces it.
- Importers, the first to bring packaging or packaged goods from outside the EU onto the EU market, check that the manufacturer has done this and keep a copy of the declaration (Article 18).
- Distributors who resell products already on the EU market check labels and manufacturer details, but do not draw up the technical documentation (Article 19).
The requirements come in stages
Substances of concern, recyclability, recycled content, minimisation, labelling and others each have their own date, and some depend on EU acts that are not adopted yet. Check the current situation before you rely on a date. Packaging already placed on the EU market before a sustainability or labelling requirement applied does not need to meet it when it is sold on later (recital 14).
What to do now
- For each packaging type, work out whether you are the manufacturer, the importer or a distributor.
- As a manufacturer, keep a file per packaging type: components, materials, weights and the products shipped in it.
- Record your assessment and evidence with dates, so you can produce the documents when asked.