PPWR compliance countdown: a practical strategic guide for Retail & Consumer businesses

The Packaging and Packaging Waste Regulation (PPWR) – Regulation (EU) 2025/40 – sets harmonised EU-wide rules for the entire life-cycle of packaging, covering design, placing on the market, labelling, waste prevention, re-use, collection and recycling. Its aim is to ensure the internal market functions smoothly whilst reducing environmental and health impacts and accelerating the shift to a circular economy.

With the Regulation's application date of 12 August 2026 fast approaching, businesses face critical compliance deadlines.

A leaked draft Commission Notice on PPWR interpretation has recently surfaced. Whilst unofficial and still subject to change, it represents a first step towards clarification, providing early clarity on some interpretative uncertainties that have emerged since the Regulation’s adoption in February 2025, including manufacturer definitions and PFAS compliance timelines. 

This newsletter provides an overview of the key obligations and timelines that economic operators in the Retail & Consumer sector should prepare for.

What is your role(s) under the PPWR?

The PPWR establishes distinct roles, each carrying specific obligations. Economic operators may hold multiple roles simultaneously, requiring them to fulfil all applicable obligations for each role. Understanding the various roles defined under the PPWR is therefore essential to identifying which obligations apply to your operations:

Manufacturer: the operator that manufactures packaging or has it designed/manufactured under its own name or trademark. 

The leaked draft Commission guidance clarifies that there is always only one manufacturer in a supply chain. For sales and grouped packaging, the manufacturer is normally the filler (i.e., the product brand owner). However, if the brand owner is a micro-enterprise and the packaging supplier is in the same Member State, the supplier becomes the manufacturer.

Manufacturers must:

• complete conformity assessment using internal production control;
• maintain comprehensive technical documentation evidencing compliance;
• draw up a Declaration of Conformity (DoC) confirming compliance;
• retain documentation for 5 years (single-use packaging) or 10 years (reusable packaging).

An authorised representative may be appointed to hold documentation, but cannot draw up the DoC.

Supplier:the operator that supplies packaging or packaging material to a manufacturer. 

Suppliers shall provide the manufacturer with all the information and documentation necessary for the manufacturer to demonstrate the conformity of the packaging and the packaging materials. That information and documentation shall be provided in either paper or electronic form.

Importer: the operator established within the Union that places packaging from a third country on the market. 

When placing packaging on the market, every importer should indicate on the packaging their name, registered trade name or registered trademark as well as their postal address and, where available, electronic means of communication through which it can be contacted (with exceptions where the packaging does not allow for such indications).

Distributor: the operator, other than the manufacturer or importer, that makes packaging available on the market. 

Distributors must:

• act with due care in relation to the applicable requirements of the regulation;
• ensure that their handling of the packaging does not adversely affect its compliance with those requirements;

• be prepared to participate actively in market surveillance tasks, providing authorities with all necessary information relating to the packaging concerned.

   

Producer: the operator first making packaging available in a Member State (or unpacking without being the end user). 

The producer has extended producer responsibility, which includes registration in the national producer register and reporting obligations and coverage of specified waste management costs.

What is ahead? Understanding PPWR requirements and timelines

Sustainability Requirements

• Substance restrictions 

Food-contact packaging containing PFAS at or above these thresholds cannot be placed on the EU market, as from 12 August 2026:

The draft Commission Notice confirms that the PPWR does not foresee a transitional period for these restrictions. This means that food-contact packaging placed on the market after 12 August 2026 must comply with PFAS limits even if it was manufactured before this date. "Placing on the market" means the first making available of packaging on the Union market, whether empty or filled, for distribution, consumption or use in commercial activity. This timing matters critically for importers managing cross-border stock.

• Recyclability requirements and timeline

Packaging must be designed for material recycling and be collectable, sortable and recycled at scale. 

• Mandatory recycled content in plastic packaging (%)

Excessive packaging and empty space limits

• Packaging minimisation 

From 1 January 2030, packaging weight and volume must be reduced to the minimum necessary; double walls, false bottoms and superfluous layers are prohibited (with limited geographical indication/design rights exceptions if protected before 11 February 2025). Technical documentation must explain minimisation decisions and testing.

• Empty-space limits

From 1 January 2030, the empty-space ratio must not exceed 50%. Empty space is the difference between total packaging volume and the volume of sales packaging; filling materials count as empty space. Specific rules apply for products with settlement or headspace needs.

RE-USE AND REFILL REQUIREMENTS FOR HORECA

Note: The 2027 obligation requires establishments to accept and accommodate customer-supplied containers (BYO). The separate 2028 obligation requires establishments to actively offer their own reusable packaging systems to customers. These are distinct compliance requirements.

Labelling Requirements

The leaked draft guidance clarifies that from 12 August 2028, Member States cannot maintain parallel national labelling requirements, ensuring truly harmonised EU-wide labels. Whilst there is a 3-year sell-through period for non-compliant packaging manufactured before the deadline, the guidance emphasises that businesses should begin redesigning now, given long procurement and design cycles.

Practical Takeaways

• Start planning now – many obligations have multi-year timelines;
• Technical documentation and the DoC form the foundation of PPWR compliance;
• Implementation will differ across Member States – keep track of national measures, particularly on deposit return schemes, re-use flexibilities and waste prevention programmes;
• The PPWR will have commercial impact across product design, sourcing, pricing, logistics and customer experience.

Conclusion

The PPWR represents a comprehensive overhaul of packaging regulation across the EU, with staged implementation beginning on 12 August 2026. Economic operators in the Retail & Consumer sector must act now to ensure compliance with the initial wave of obligations and prepare for the more demanding requirements that follow in the 2030s onwards. 

We understand that navigating the PPWR landscape can be complex. Our team is here to help you assess your obligations and develop a practical compliance strategy. 

Please feel free to contact our team to discuss how we can support you.