The EU Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40, PPWR) started to apply on 12 August 2026. The first tranche of obligations is no longer a deadline to prepare for - it is the law that governs every packaging unit placed on the EU market today.

The market spent two years arguing about what was actually due at that first date. That argument is over. This post sets out what became enforceable on 12 August, what did not change, and what to do if you find yourself on the wrong side of the line.

Declaration of Conformity

Since 12 August 2026, every packaging unit placed on the EU market must have a Declaration of Conformity (DoC) prepared and held on file. The DoC is not submitted to a portal or registry - it must simply exist and be available to market surveillance authorities on request.

The Declaration must confirm that the packaging meets the applicable PPWR requirements and must include: identification of the packaging (product reference, type), the name and address of the manufacturer or authorised representative, a statement that the declaration is issued under the sole responsibility of the manufacturer, identification of the packaging to which it refers, and references to the relevant harmonised standards or technical specifications applied.

In practical terms, this means you need structured data covering material composition, recyclability assessment, recycled content, and compliance with substance restrictions for every packaging unit. If your data is scattered across spreadsheets or locked in supplier emails, assembling a DoC for each packaging unit is a manual, error-prone exercise - and it is one you now have to complete before the goods move, not afterwards.

PP01-PP12 material identification

PPWR Annex VI introduces 12 standardised material identification codes - PP01 through PP12 - that must be applied to packaging components. These codes cover the major material families: PP01 (PET), PP02 (HDPE), PP03 (PVC), PP04 (LDPE), PP05 (PP), PP06 (PS), PP07 (other plastics), PP08 (paper and cardboard), PP09 (metals - steel), PP10 (metals - aluminium), PP11 (wood, including cork), and PP12 (glass).

It is important to understand that PP01-PP12 codes are separate from national EPR material categories. Germany reports against its own ZSVR material types - glass, PPK, ferrous metals, aluminium, plastics, beverage carton composites, other composites and other materials. France uses CITEO categories that split materials differently again. A packaging component gets a PP code under PPWR and a national material code depending on which EPR scheme you are reporting to. These are parallel classification systems, not replacements for each other.

The system needs to hold both - the EU-level PP code and the scheme-specific national code - and map between them correctly when generating exports.

Recycled content tracking

Recycled content must now be recorded at the component level. The mandatory recycled content targets (from 1 January 2030: 30% for contact-sensitive PET packaging, 10% for contact-sensitive packaging in plastics other than PET, 30% for single-use plastic beverage bottles, 35% for other plastic packaging) do not bite until later, but the data capture obligation is live, and the 2030 targets are only assessable if the underlying record has been kept consistently from now on.

There is an important data modelling point here that many systems get wrong: the distinction between "not recorded" and "confirmed zero." A component where recycled content data has not yet been provided (null) is different from a component where the supplier has confirmed that recycled content is 0% (zero). This matters for regulatory accuracy, EPR fee calculations, and audit trail. If your system collapses both states into "0%", you cannot distinguish between missing data and genuine zero content, which creates compliance risk.

PFAS limits in food-contact packaging

This is the requirement that caught the most people out, because it is a hard product restriction rather than a paperwork obligation. Since 12 August 2026, food-contact packaging cannot be placed on the EU market if it contains PFAS at or above 25 ppb for any individual PFAS measured by targeted analysis, 250 ppb for the sum of PFAS measured by targeted analysis, or 50 ppm for total PFAS including polymeric PFAS.

The restriction applies to packaging placed on the market after 12 August, including stock manufactured before that date. There is no sell-through period for existing inventory. Grease-resistant paper and board, moulded fibre trays and certain coated films are the usual sources, and the evidence has to come from your supplier chain rather than from your own records.

We have covered the thresholds, the total fluorine screening step and the supplier evidence you need in a separate article on PFAS restrictions in food-contact packaging.

Authorised representatives for EPR

Article 45 also started applying on 12 August. A producer not established in a member state must appoint an authorised representative for extended producer responsibility in each member state where it makes packaging or packaged products available for the first time. There is no single EU-wide appointment.

The Commission had proposed suspending part of this obligation, but negotiations were discontinued in Council in June 2026 in the face of objections from a large majority of member states, and the proposed suspension never covered non-EU producers in any case. The obligation is in force. This is covered in detail in a separate article.

Packaging minimisation

PPWR introduces packaging minimisation requirements with a focus on empty space. For e-commerce and parcel packaging, the empty space ratio must not exceed 50%. For grouped and transport packaging, the limit is 40%. These limits now apply.

The detailed calculation methodology for empty space measurement is not finalised until a delegated act expected in February 2028. The obligation exists while the precise measurement rules are still being developed, which is uncomfortable but does not suspend the obligation. Record packaging dimensions and fill ratios now, and accept that the final methodology may adjust how the ratio is calculated.

What did not change on 12 August

Several major PPWR requirements are frequently conflated with the August 2026 date but are still ahead:

  • Harmonised sorting labels (Article 12) - mandatory from August 2028, not 2026. The JRC has published its technical proposal (JRC141706) defining 20 labels across 10 groups, but formal label identifiers will be assigned in the implementing act
  • The Article 12 data carrier - the QR code behind the harmonised label - from 12 August 2028 alongside the label itself. The Digital Product Passport is a separate instrument under the Ecodesign Regulation (EU) 2024/1781, and packaging is not a product group in its scope
  • Recyclability performance grades (A, B, C) - not applied until 2030. Grade E packaging will be banned from 2038
  • Mandatory recycled content targets - from 1 January 2030: 30% for contact-sensitive PET packaging, 10% for contact-sensitive packaging in plastics other than PET, 30% for single-use plastic beverage bottles, 35% for other plastic packaging

If you are not compliant today

The obligations landed all at once, and enforcement will not. Market surveillance authorities are resourced differently in every member state, and the first months will be uneven. That is a reprieve, not a defence: a DoC that did not exist when the packaging was placed on the market cannot be back-dated, and PFAS-bearing stock does not become compliant by sitting in a warehouse.

The practical order of work is: stop the hard breaches first, then close the paperwork. PFAS in food-contact packaging is a placing-on-the-market prohibition, so identify the affected lines and quarantine or reformulate before anything else. Appointing authorised representatives is next, because it is a fixed, finite task with a clear done state. Declarations of Conformity come third - they are the largest volume of work, but they are assembled from data you either have or can chase, and the gap closes as the data lands.

How Merchant Packaging supports this

Merchant Packaging supports the requirements that are now in force. The platform generates the Declaration of Conformity document from structured component data, maps every component to its correct PP01-PP12 code, tracks recycled content with full null-versus-zero distinction, records substance restriction evidence against components, and records a recyclability grade per component. The data you hold now feeds directly into the sorting label, DPP and recyclability grade requirements that follow in 2027, 2028 and 2030.