What's changing

From 12 August 2026, the EU Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40, known as "PPWR") applies in full across all 27 EU Member States.

PPWR replaces the previous Packaging and Packaging Waste Directive. The key difference is that PPWR is a regulation, not a directive — it applies directly and identically in every EU country from day one, rather than depending on each country writing its own local version into national law.

If you sell packaged products into the EU, there are two separate requirements you need to have in place before 12 August 2026.

1. Extended Producer Responsibility (EPR) registration

You must be registered as a producer in every individual EU country where your packaging (or packaged products) is placed on the market for the first time.

• This means registering in each relevant country separately — there is no single "lead country" registration that covers you EU-wide.
• Registration can be done directly by your business, or through an authorised representative based in that country.
• EPR registration and fees remain managed at national level (e.g. schemes like Lucid in Germany), even though the underlying packaging rules are now harmonised across the EU.

Action needed: Confirm which EU countries you place packaging on the market in, and check your registration status in each one.

2. Packaging technical documentation & Declaration of Conformity (DoC)

For each packaging type you place on the EU market, you will need:

• Technical documentation covering the packaging's design, materials, test data, and how it meets PPWR's essential requirements (Articles 5–12).
• A signed EU Declaration of Conformity, confirming that the packaging complies with those requirements.

Retention periods:

Action needed: For each distinct packaging type/format you use, gather or prepare the supporting technical file and signed DoC. If you don't manufacture the packaging yourself, you may need to request the DoC and technical documentation from your packaging supplier or manufacturer.

Key things to keep in mind

• No grace period — packaging placed on the EU market after 12 August 2026 must comply, even if it was produced before that date.
• Enforcement typically comes through customs checks, market surveillance inspections, or customer/retailer audits — not just proactive checks by regulators.
• Some further details (such as exact national registration mechanics) are still being finalised by individual Member States and the European Commission, so requirements in a specific country may continue to be refined after 12 August 2026. We'll keep you updated as this develops.

Questions?

If you're unsure which countries you need to register in, or need help gathering documentation for specific packaging types, please get in touch and we can talk through your specific setup.