From 12 August 2026, the European Union’s new Packaging and Packaging Waste Regulation – Regulation (EU) 2025/40 (PPWR) becomes generally applicable across the EU.
The Regulation represents one of the most significant changes to European packaging legislation in decades. Unlike the previous Packaging and Packaging Waste Directive, the PPWR is an EU Regulation and is therefore directly applicable in all EU Member States, creating a substantially more harmonised legal framework for businesses operating across the European market.
The new rules affect manufacturers, importers, distributors, retailers and other economic operators placing packaging or packaged products on the EU market.
What changes from 12 August 2026?
The PPWR applies broadly to all packaging, irrespective of the material used, and to packaging waste generated by industry, manufacturing, retail, distribution, offices, services and households.
Its objective is not simply to improve recycling. The Regulation introduces requirements covering the entire lifecycle of packaging – from its composition and design to reuse, recycling and eventual waste management.
Among the areas businesses should pay particular attention to are:
Packaging composition and substances of concern
Companies will face stricter requirements concerning substances contained in packaging.
Of particular importance for the food industry, from 12 August 2026 food-contact packaging containing PFAS above the thresholds established by the Regulation may no longer be placed on the EU market.
The PPWR also maintains limits relating to the concentration of lead, cadmium, mercury and hexavalent chromium in packaging.
Compliance with relevant requirements must be supported by appropriate technical documentation.
New compliance obligations for manufacturers and importers
The PPWR introduces a more structured product-compliance framework for packaging.
Manufacturers will have obligations concerning conformity assessment, technical documentation and the EU Declaration of Conformity. Importers and distributors will also have responsibilities to verify that packaging placed on the European market complies with applicable requirements.
This means that packaging compliance will increasingly need to become part of companies’ broader product-compliance and supply-chain procedures.
Recyclability
One of the central objectives of the PPWR is for packaging placed on the EU market to become recyclable in an economically viable manner.
However, companies should be aware that not every major PPWR requirement becomes mandatory on 12 August 2026.
Several important obligations are being introduced progressively. In particular, key recyclability requirements and performance grades will apply primarily from 2030 onwards, giving businesses a transitional period to redesign packaging and adapt their supply chains.
Recycled content
The Regulation introduces minimum recycled-content requirements for certain plastic packaging.
These requirements will also be phased in, with important targets applying from 2030 and becoming progressively more ambitious thereafter.
For companies relying heavily on plastic packaging, access to compliant recycled materials and the ability to document their origin and composition are likely to become increasingly important procurement considerations.
Packaging minimisation
The PPWR aims to reduce unnecessary packaging and requires packaging to be designed so that its weight and volume are reduced to the minimum necessary for functionality.
This may have significant implications for product and packaging design, particularly where packaging contains unnecessary layers, empty space or components used predominantly for presentation rather than protection or functionality.
Reuse and refill
The Regulation also establishes reuse and refill requirements for certain sectors and packaging formats.
These provisions are particularly relevant to businesses operating in food and beverages, hospitality, transport packaging, e-commerce and distribution.
Again, many of the quantitative targets are subject to later application dates and sector-specific rules.
Why businesses should act now
Although many of the PPWR’s most demanding quantitative requirements will apply progressively over the coming years, 12 August 2026 marks an important legal transition.
Businesses should not interpret the phased implementation as a reason to postpone compliance work.
Packaging specifications, supplier agreements and manufacturing processes often cannot be changed quickly. Companies operating internationally may also depend on packaging manufacturers and raw-material suppliers located outside the European Union.
A practical PPWR compliance review should therefore consider:
• which packaging used or supplied by the company falls within the Regulation;
• whether the company acts as manufacturer, importer, distributor or other economic operator for each product;
• whether existing packaging complies with applicable chemical and material requirements;
• whether the necessary technical documentation and conformity procedures are in place;
• whether supplier contracts provide sufficient information and guarantees regarding packaging compliance;
• whether current packaging design will satisfy future recyclability, recycled-content and minimisation requirements; and
• which requirements will become applicable to the company’s products between 2026 and 2030.
Particular importance for companies importing into the EU
The Regulation is especially relevant for European businesses importing packaged goods or packaging from third countries.
Compliance cannot simply be delegated to a non-EU supplier. European importers have their own obligations and should ensure that manufacturers provide the information and documentation necessary to demonstrate conformity with EU requirements.
As a result, companies may need to review their supply agreements, technical specifications, declarations, compliance warranties and contractual liability provisions.
A new regulatory framework for the European market
The PPWR is intended to create a more circular European packaging economy while simultaneously harmonising requirements across the Single Market.
For businesses, however, it also represents a significant compliance exercise.
The key message is therefore not that every packaging rule changes overnight on 12 August 2026. Rather, 12 August marks the beginning of a new EU-wide regulatory framework, with obligations being introduced progressively over the coming years.
Companies that begin reviewing their packaging portfolios and supply chains now will be considerably better positioned for the more demanding requirements approaching in 2030.
Milanova & Partners advises companies operating in Bulgaria and across the European Union on EU regulatory compliance, commercial agreements and the implementation of new European legislation affecting their business operations.
This article is intended for general information purposes only and does not constitute legal advice.
Source: Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC
