Regulation (EU) 2025/40
PPWR: what does the Packaging Regulation ask of you?
- Who it applies to
- Every company that makes packaging, has it made under its own brand, imports it, sells it on, supplies it or ships it for others. The producer is whoever first makes it available in a Member State.
- The dates
- The Regulation applies from 12 August 2026, directly, with no national transposition. Several design duties follow on later days, each set out below.
- The one thing to do
- Make packaging conform to Articles 5 to 12, draw up the technical documentation and the declaration, mark it, and register as a producer in each Member State you supply.
Two answers give the PPWR duties your role carries, before the facts about your packaging.
Answer above to read the determination for your case; the full tool takes your answers with it.
See the dutiesAt a glance
Who carries which article
A company is often several of these at once, and each brings its own article. The portal asks which.
| Operator | Articles | Duties |
|---|---|---|
| Manufacturer | 5, 6, 7, 10, 11, 12, 15, 22, 24, 25, 26, 29, 39 | 31 |
| Importer | 5, 7, 10, 12, 18, 21, 22, 24, 25, 26, 29 | 21 |
| Distributor | 12, 19, 21, 22, 24, 25, 26, 29 | 15 |
| Supplier | 16, 22 | 3 |
| Fulfilment service provider | 20, 22, 24, 29 | 7 |
| Authorised representative | 17, 22 | 3 |
| Producer | 44, 45 | 8 |
The day each later duty applies
Everything else applies from 12 August 2026. Where the Regulation says "or later", the Commission's own act can push the day back.
| From | Article | Duty |
|---|---|---|
| 24(4) | Reduce empty space in sales packaging to the minimum | |
| or later | 12(1) | Mark packaging with the harmonised material label |
| or later | 12(2) | Label reusable packaging as reusable, with a QR code |
| or later | 6(1) | Make all your packaging recyclable |
| or later | 6(3) | Assess each packaging's recyclability grade, A to C |
| or later | 7(1) | Use the minimum recycled content in plastic parts |
| 10(1) | Reduce packaging weight and volume to the minimum | |
| or later | 24(1) | Limit empty space in transport and e-commerce packaging |
| 25(1) | Stop placing the Annex V packaging formats on the market | |
| 29(1) | Use reusable transport packaging to meet the re-use target | |
| 29(5) | Use reusable boxes for grouping products |
The EU declaration of conformity
Article 39(2) gives the declaration the model structure of Annex VIII, one per packaging type, in the language the Member State requires. These are its points, in the Regulation's words:
- 1. No … (unique identification of the packaging):
- 2. Name and address of the manufacturer and, where applicable, the manufacturer’s authorised representative:
- 3. This declaration of conformity is issued under the sole responsibility of the manufacturer.
- 4. Object of the declaration (identification of the packaging allowing traceability): description of the packaging:
- 5. The object of the declaration referred to point 4 is in conformity with the relevant Union harmonisation legislation: … (reference to the other Union acts applied).
- 6. References to the relevant harmonised standards or the common specifications used or references to the other technical specifications in relation to which conformity is declared:
- 7. Where applicable, the notified body … (name, address, number) … performed … (description of intervention) … and issued the certificate(s): … (details, including the date of the certificate(s), and, where appropriate, information on the duration and conditions of validity).
- 8. Additional information:
The technical documentation
Article 15(2) has the manufacturer draw up the technical documentation, and Annex VII lists what it contains:
- a a general description of the packaging and its intended use;
- b conceptual design, manufacturing drawings and materials of components;
- c descriptions and explanations necessary for the understanding of the drawings provided under point (b) and the schemes and operation of the packaging;
- d a list of:
- d(i) the harmonised standards, referred to in Article 36, applied in full or in part;
- d(ii) the common specifications, referred to in Article 37, applied in full or in part;
- d(iii) other relevant technical specifications used for measurement or calculation purposes;
- d(iv) in the event of partly applied harmonised standards or common specifications, an indication of the parts which have been applied;
- d(v) in the event of harmonised standards or common specifications not being applied, a description of the solutions adopted to meet the requirements referred to in point 1;
- e a qualitative description of how the assessments provided for in Articles 6, 10 and 11 have been carried out; and
- f test reports.
The formats Annex V restricts
From 1 January 2030, Article 25(1) restricts these packaging formats for the uses Annex V names. The format and the Annex's example, in its words:
- 1. Single-use plastic grouped packaging: Collation films, shrink wrap
- 2. Single-use plastic packaging for unprocessed fresh fruit and vegetables: Nets, bags, trays, containers
- 3. Single-use plastic packaging: Trays, disposable plates and cups, bags, boxes
- 4. Single-use plastic packaging for condiments, preserves, sauces, coffee creamer, sugar, and seasoning in HORECA sector: Sachets, tubs, trays, boxes
- 5. Single-use accommodation sector packaging intended for an individual booking: Shampoo bottles, hand and body lotion bottles, sachets around bar soap
- 6. Very lightweight plastic carrier bags: Very thin bags provided for bulk groceries
Registration, in each Member State
Each Member State keeps its own register of producers, and a producer registers in each one where it first makes packaging available. The application carries Annex IX, Part A:
- a) name and brand names (if available) under which the producer makes its packaging, including packaging of packaged products, available on the territory of the Member State and address of the producer, including postal code and place, street and number, country, telephone, if any, web address and e-mail address, indicating a single contact point;
- b) where a producer has authorised an authorised representative with carrying out the extended producer responsibility obligations on its behalf, in addition to the information referred in point (a): name and address including postal code and place, street and number, country, telephone and e-mail address of the authorised representative;
- c) national identification code of the producer, including its trade register number or equivalent official registration number and the European or national tax identification number;
- d) a declaration on how the producer meets its responsibilities under Article 45, including a certificate issued by the producer responsibility organisation where Article 46(1) applies.
A regulation, with national registers
Regulation (EU) 2025/40 applies directly in every Member State, with nothing transposed. The register of producers and the producer responsibility scheme are still each Member State's, under Articles 44 and 45. We have not yet read the national registers, so this page names none.
Read from Regulation (EU) 2025/40 in the Official Journal on 17 October 2026, in six languages, with its corrigenda applied to the language each corrects. No act has amended it. EUR-Lex
Questions people ask
- We only sell online. Does the PPWR reach us?
- Yes. The boxes you ship are e-commerce packaging, Article 3(1), point (8). Selling directly to end users in another Member State makes you a producer there, point (15)(c) and (d), and Article 45(3) has you appoint a representative in each one.
- Our boxes are made by a supplier. Who is the manufacturer?
- You are, if they are made under your name or trademark, point (13)(a). A micro-enterprise whose supplier is in the same Member State is not: the supplier is, point (13)(b).
- Do we register once for the whole EU?
- No. Each Member State keeps its own register of producers, Article 44(1), and you register in each one where you first make packaging available, Article 44(2).
- When does the material label apply?
- From 12 August 2028 at the earliest, Article 12(1). If the Commission's implementing acts come late, it applies two years after them instead, whichever is later.
- Does the PPWR replace the Packaging Directive?
- Yes. It repeals Directive 94/62/EC from 12 August 2026, Article 70(1), keeping a few of its provisions for a transition. As a regulation it applies directly, without national transposition.
Keep the packaging files and the registers in one place
StandardOS holds your PPWR duties and the evidence for each. It drafts the declaration and the technical documentation per packaging type and the Annex IX register sheet per Member State, next to the other frameworks you run.
What it asks of you
55 requirements in 3 groups
Obligations
29- 6(3) Assess each packaging's recyclability grade, A to C
- 12(8) Use no labels that mislead on sustainability
- 15(1) Place only conforming packaging on the market
and 26 more
Controls
24- 5(1) Minimise substances of concern in your packaging
- 5(4) Keep packaging within the heavy metal limit
- 5(5) Keep PFAS out of food-contact packaging
and 21 more
Clauses
2- 21 Under your own brand, you take the manufacturer's duties
- 39(3) Draw up one declaration for every act requiring one
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