From 12 August 2026, the Packaging and Packaging Waste Regulation (PPWR) will apply throughout the European Union. This means that the PPWR is no longer a future piece of legislation, but a framework that businesses must now take into account.
At the same time, this date does not mean that all obligations will apply in full immediately. There is still uncertainty on several points regarding definitions, interpretations and practical implementation. The European Commission published an updated FAQ on 3 August 2026, but at least thirty further documents are expected by the end of 2029.
Not everything comes into force straight away
Although the PPWR is now in force, not all obligations come into effect immediately. In our previous article, we already discussed key dates relating to the PPWR. Verpact has now published a timeline setting out the various effective dates and is asking companies to continue operating on the basis of the situation as it stood prior to 12 August 2026, pending further clarification from the EU. Nevertheless, the direction is clear: the PPWR will have an increasingly significant impact on material choices, documentation and compliance.
What is immediately relevant?
The most important aspect requiring immediate attention as of 12 August 2026 is compliance with the requirements regarding hazardous substances set out in Article 5.
These requirements include, amongst other things, the existing limit on the concentration of heavy metals in packaging to a maximum of 100 ppm. For many companies, this is therefore not an entirely new obligation, but under the PPWR it remains an essential criterion for compliance.
In addition, it is highly likely that packaging will need to be adapted in the relatively short term to incorporate the use of logos and symbols. This, too, requires attention from companies that develop, specify or place packaging on the market.
The declaration of conformity becomes a key requirement
A significant change is that the manufacturer must carry out a conformity assessment for each individual item of packaging. A declaration of conformity may only be drawn up following a positive assessment. Without this declaration, the packaging may not be placed on the EU market.
The obligation lies with the manufacturer, but suppliers must provide the correct data. As a result, documentation, product specifications, test results and traceability are becoming increasingly important.
Essential requirements remain the basis for packaging design
An important point is that the essential requirements, as set out in the previous European Directive on packaging and packaging waste, remain in force. For the time being, they continue to form the basis for packaging design.
This means that companies must not only consider the new PPWR obligations, but must also continue to comply with the existing design principles that have been in force for some time.
The definition of ‘producer’ is changing
Under the PPWR, the definition of ‘producer’ is also changing. A key consequence of this is that, in many cases, the responsibility for reporting on packaging that is released during disposal upon import shifts to the foreign supplier. This is particularly relevant when a company is itself the end-user of packaged products, unpacks the packaging and arranges for its collection.
For companies with international supply chains, this may have implications for responsibilities, contracts and administrative processes. It is therefore advisable to analyse in good time how this shift will affect their own supply chain.
Coffee pods, tea bags and coffee capsules are covered by the regulations
The PPWR also has direct implications for certain product categories.
Coffee pods and tea bags that still contain residue when discarded will be classified as packaging from 12 August 2026. Reporting and levies for these products will therefore come into effect on that date. For coffee capsules, a later start date applies, namely 1 January 2027.
In the case of coffee pods and tea bags, companies must report the packaging materials used under the packaging type ‘packaging, other’ and pay the rate set for 2026 for each material.
What does this mean for the polymer industry?
Much of the discussion surrounding the PPWR centres on packaging design. However, for the polymer industry, the real change begins earlier in the supply chain.
For polymer suppliers, converters and manufacturers, the PPWR is changing the way materials are selected, documented and verified. Recycled material, chain of custody, technical documentation and material traceability are becoming increasingly important for market access. This means that the question is no longer simply which material is technically or commercially suitable, but also which material demonstrably complies with current and future regulations.
What should companies do now?
Despite the current uncertainties, a wait-and-see approach is not a sensible strategy. Companies can already take concrete steps to prepare themselves.
At the same time, this date does not mean that all obligations will apply in full immediately. There is still uncertainty on several points regarding definitions, interpretations and practical implementation. The European Commission published an updated FAQ on 3 August 2026, but at least thirty further documents are expected by the end of 2029.
Not everything comes into force straight away
Although the PPWR is now in force, not all obligations come into effect immediately. In our previous article, we already discussed key dates relating to the PPWR. Verpact has now published a timeline setting out the various effective dates and is asking companies to continue operating on the basis of the situation as it stood prior to 12 August 2026, pending further clarification from the EU. Nevertheless, the direction is clear: the PPWR will have an increasingly significant impact on material choices, documentation and compliance.
What is immediately relevant?
The most important aspect requiring immediate attention as of 12 August 2026 is compliance with the requirements regarding hazardous substances set out in Article 5.
These requirements include, amongst other things, the existing limit on the concentration of heavy metals in packaging to a maximum of 100 ppm. For many companies, this is therefore not an entirely new obligation, but under the PPWR it remains an essential criterion for compliance.
In addition, it is highly likely that packaging will need to be adapted in the relatively short term to incorporate the use of logos and symbols. This, too, requires attention from companies that develop, specify or place packaging on the market.
The declaration of conformity becomes a key requirement
A significant change is that the manufacturer must carry out a conformity assessment for each individual item of packaging. A declaration of conformity may only be drawn up following a positive assessment. Without this declaration, the packaging may not be placed on the EU market.
The obligation lies with the manufacturer, but suppliers must provide the correct data. As a result, documentation, product specifications, test results and traceability are becoming increasingly important.
Essential requirements remain the basis for packaging design
An important point is that the essential requirements, as set out in the previous European Directive on packaging and packaging waste, remain in force. For the time being, they continue to form the basis for packaging design.
This means that companies must not only consider the new PPWR obligations, but must also continue to comply with the existing design principles that have been in force for some time.
The definition of ‘producer’ is changing
Under the PPWR, the definition of ‘producer’ is also changing. A key consequence of this is that, in many cases, the responsibility for reporting on packaging that is released during disposal upon import shifts to the foreign supplier. This is particularly relevant when a company is itself the end-user of packaged products, unpacks the packaging and arranges for its collection.
For companies with international supply chains, this may have implications for responsibilities, contracts and administrative processes. It is therefore advisable to analyse in good time how this shift will affect their own supply chain.
Coffee pods, tea bags and coffee capsules are covered by the regulations
The PPWR also has direct implications for certain product categories.
Coffee pods and tea bags that still contain residue when discarded will be classified as packaging from 12 August 2026. Reporting and levies for these products will therefore come into effect on that date. For coffee capsules, a later start date applies, namely 1 January 2027.
In the case of coffee pods and tea bags, companies must report the packaging materials used under the packaging type ‘packaging, other’ and pay the rate set for 2026 for each material.
What does this mean for the polymer industry?
Much of the discussion surrounding the PPWR centres on packaging design. However, for the polymer industry, the real change begins earlier in the supply chain.
For polymer suppliers, converters and manufacturers, the PPWR is changing the way materials are selected, documented and verified. Recycled material, chain of custody, technical documentation and material traceability are becoming increasingly important for market access. This means that the question is no longer simply which material is technically or commercially suitable, but also which material demonstrably complies with current and future regulations.
What should companies do now?
Despite the current uncertainties, a wait-and-see approach is not a sensible strategy. Companies can already take concrete steps to prepare themselves.
- Identify which packaging is affected
- Check compliance with Article 5, including the limit value of 100 ppm
- Compile packaging dossiers with technical and administrative supporting documentation
- Prepare a declaration of conformity for each individual packaging item
- Request data from suppliers in good time
- Assess the impact of logos and symbols
- Check the implications of the amended definition of ‘producer’
- Continue to actively monitor new European and national guidelines
