If you sell packaged products into the EU, your preparation for August 2026 requires answers to two questions:
First is, do you know exactly what packaging you are using, and the second, can you prove that it complies if someone asks?
From 12 August 2026, the EU's Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40), or PPWR, will apply across all Member States. The regulation introduces new requirements around packaging materials, recyclability, documentation and producer responsibility. For online sellers, that means looking beyond the product's retail packaging. The shipping carton, mailer bag, void-fill, tape and protective inserts can all form part of the packaging you need to account for.
PPWR replaces the older Packaging and Packaging Waste Directive with a single EU regulation. The previous 1994 Directive established recycling targets but left much of the implementation to individual Member States. Over time, that resulted in 27 national EPR systems with different registration requirements, fees and approaches to recyclability and it was messy.
Because PPWR is a regulation and not a directive, it applies directly across the EU without each Member State having to transpose it into national law first.
The regulation is part of the EU's wider effort to reduce packaging waste, including the target of reducing packaging waste by 55% by 2030 under the European Green Deal. PPWR puts more emphasis on packaging minimisation, recyclability, recycled content and documentation that can be checked by regulators.
PPWR entered into force on 11 February 2025. General application date is 12 August 2026 under Article 71. Other requirements and targets are introduced later. (European Commission; EUR-Lex)
For e-commerce businesses, the scope extends beyond the product's retail box. Shipping cartons, mailing bags, protective inserts, tape and void-fill can all be relevant.
PPWR can apply to businesses that manufacture, import, fill, distribute or sell packaged products in the EU. That includes Amazon and Shopify sellers, private-label brands, fulfilment companies and businesses based outside the EU that sell directly to EU customers.
The specific obligations depend on the role a business has in the supply chain.
For example:
Non-EU sellers should establish, for each country they sell into, who the importer of record is, who qualifies as the responsible producer, whether an authorised representative is required, and who is handling EPR registration, reporting and the Declaration of Conformity.
PPWR is an EU-wide regulation, but packaging EPR systems remain organised nationally. Under Article 44, registration is national and precedes market access. A registration in Spain does not cover sales into Germany or France. A seller operating in all three markets therefore needs to deal with the respective national requirements, including their reporting and fee structures.
The term "authorised representative" can be confusing because PPWR uses it in two different contexts.
The Article 17 authorised representative deals with product-conformity tasks that a manufacturer may delegate. This is the general product-safety role.
The Article 45 EPR representative is a separate role connected specifically with producer-responsibility obligations under Chapter VIII. In a situation when a producer makes sales directly into another Member State, it must appoint an authorised representative for EPR there by written mandate. The representative is the locally established party responsible for handling registration and maintaining the relevant national compliance records on the producer's behalf.
These roles should not be assumed to be interchangeable. If a seller already has a product-safety representative for GPSR purposes, that appointment does not automatically satisfy the PPWR EPR requirement. It is wise to check the mandate and the applicable legal requirements.
Before making major packaging changes, it makes sense to establish where your current packaging stands.
If you are using standard corrugated cardboard boxes, paper mailers and common plastic packaging materials, your packaging may already fit within the current PPWR recyclability framework.
Of course it is not that simple, there are materials that deserve closer attention. The seller needs to focus closely on two of them, EPS foam used as primary packaging and PVC bags or film. Where these materials are part of your packaging mix, an alternative may be necessary. When that's the case, documentation alone will not solve the problem.
For many sellers, the immediate priority is to understand and document their existing packaging rather than redesign everything before August 2026.
Once you have established your role, the next step is to document the packaging you actually use and to do that here is a quick list of tasks.
Map your packaging.
Create a list of every packaging format used across your products: retail boxes, mailers, inserts, tape, void-fill and other transport materials. Link each format to the relevant SKUs or product families. It is also useful to distinguish primary packaging from secondary and transport packaging.
Record the materials.
For each packaging format, record the material, weight, dimensions and supplier. For multi-layer packaging, include relevant coatings and adhesives because they can affect recyclability assessments.
Appoint an EPR representative where required.
For a non-EU producer making distance sales directly into an EU country, the appointment needs to be made through a written mandate. This is a separate matter from any product-safety representative appointed under other EU legislation.
Prepare the Declaration of Conformity.
The Declaration of Conformity is the formal statement that the relevant packaging meets the applicable PPWR requirements. It should describe the packaging that you are actually placing on the market.
Build the technical file.
The Declaration of Conformity needs supporting evidence. Organise that evidence by packaging type rather than keeping everything in a general supplier folder.
Review EPR requirements country by country.
Check the registration and reporting requirements for every market in which you sell. Establish whether the responsibility sits with you, an importer or an authorised representative.
One of the practical problems for sellers is assuming that a single declaration can cover an entire catalogue. That may not work where the packaging varies.
For example, if orders are shipped in three different mailer types depending on their size, the documentation needs to reflect those packaging configurations rather than relying on one generic statement.
Under PPWR, the manufacturer prepares a written Declaration of Conformity and keeps it with the technical documentation. According to the regulation, the documentation must be retained for five years for single-use packaging and ten years for reusable packaging. (EUR-Lex)
A DoC will typically contain a unique identification number, the manufacturer's name and address, details of an authorised representative where applicable, identification of the packaging itself, the relevant PPWR requirements, references to applicable standards, and the date, place and signature of the person issuing it.
The declaration is not submitted automatically. It needs to be available when requested by a market surveillance authority.
Changes to the packaging can also mean changes to the documentation. If you replace a mailer supplier, change the material, alter the dimensions, switch a coating or make another significant design change, check whether the existing DoC and supporting technical documentation still accurately describe the packaging being shipped.
Marketplaces are also relevant. Under PPWR, covered online platforms must obtain a producer's registration number and self-certification of EPR compliance before onboarding them. A seller that cannot provide the required information may therefore face marketplace restrictions even before a regulator takes action.
The technical file contains the evidence supporting the Declaration of Conformity.
For packaging composition and design, this can include a description of the packaging, its intended use, manufacturing drawings, material information for each layer, and details of coatings, adhesives and closures.
Supporting evidence can include recyclability and minimisation assessments, applicable standards, recycled-content calculations and laboratory test reports or supplier declarations.
Where relevant, particularly for food-contact packaging, the file should also contain evidence concerning substances of concern, including PFAS (per- and polyfluoroalkyl substances).
From 12 August 2026, food-contact packaging is banned if it contains PFAS above the specified limits:
These requirements are particularly relevant to food and beverage brands, subscription food boxes, meal-kit businesses and pet-food brands using flexible food-contact packaging. If you sell products such as fashion, beauty or other non-food goods where the packaging does not contact food, this PFAS provision will likely not be relevant to you.
Recyclability is one of the areas that will have a larger commercial impact over the longer term, even though some of the requirements do not take effect until 2030.
From 1 January 2030, packaging cannot be placed on the EU market unless it is recyclable.
Recyclability is assessed using grades rather than a simple pass/fail test.
Packaging is scored:
with at least grade C required to remain on the market. From 1 January 2038, grade C will no longer be sufficient. Packaging will need to achieve grade A or B.
Plastic packaging will also be subject to minimum recycled-content requirements. The targets increase over time and vary according to the type of packaging:
These targets do not require action before August 2026, but businesses using plastic packaging should understand them when making longer-term packaging decisions.
Not every PPWR requirement starts in August 2026.
Recyclability labelling depends on the Commission's implementing acts. Recycled-content targets begin in 2030, and reuse packaging programmes are also part of the later timetable.
The practical point is to separate the requirements that apply now from those that need to be planned for later. Otherwise, it is easy to spend time changing packaging for a requirement that does not yet apply.
At a minimum, your packaging records should cover:
Assigning one person to own this process can make a significant difference. Documentation tends to become difficult to manage when everyone is responsible for it but nobody has clear ownership.
For most sellers, PPWR does not mean redesigning all packaging before 12 August 2026. The situation is different if you are using materials such as EPS foam or PVC that require attention.
For everyone else, the immediate task is more straightforward: understand the packaging you use, organise the supporting evidence, and establish which obligations apply to your business in each market.
The businesses most likely to struggle are those that treat PPWR as a one-time deadline. The regulation creates an ongoing set of documentation, reporting and packaging requirements, with additional obligations coming into force over the following years.
If the packaging data and supporting documents are organised now, future changes in 2028, 2030 and beyond become much easier to manage.
FAQ
This article provides general information and is not legal advice. Sellers should verify the requirements applicable to their products, business role and target countries against Regulation (EU) 2025/40 and relevant national EPR rules.