EU Packaging and Packaging Waste Regulation (PPWR)

Who this applies to

• Anyone placing packaging on the EU market. The Declaration of Conformity obligation attaches to the packaging unit, not to a turnover band, so it reaches small producers as well as large ones.
• Producers not established in a given member state, who must appoint an authorised representative for extended producer responsibility in each member state where they make packaging available for the first time. There is no single EU wide appointment.
• Distance sellers, including businesses selling into a member state through their own website or a marketplace without holding stock or an entity there. Absence of a local establishment is what triggers the appointment obligation rather than avoiding it.
• Anyone placing food-contact packaging on the EU market, who is caught by the PFAS limits regardless of when the packaging was manufactured.

What you must do

• Prepare and hold a Declaration of Conformity for every packaging unit placed on the EU market. It is not submitted to a portal, it must exist and be available to market surveillance authorities on request.
• Apply the PP01 to PP12 material identification codes from Annex VI to packaging components, alongside, not instead of, the national EPR material codes each scheme requires.
• Record recycled content at component level, keeping "not recorded" distinct from "confirmed zero".
• Keep food-contact packaging below the PFAS limits: 25 ppb for any individual PFAS by targeted analysis, 250 ppb for the sum, and 50 ppm for total PFAS including polymeric PFAS.
• Appoint an authorised representative for extended producer responsibility in each member state where you are not established, under a written mandate.
• Keep packaging within the empty space limits: no more than 50% for e-commerce and parcel packaging, and no more than 40% for grouped and transport packaging.

Key dates

1. 12 August 2026 In force

   PPWR starts to apply. Declaration of Conformity, PP01 to PP12 identification, PFAS limits in food-contact packaging, authorised representatives and the empty space limits all take effect.

2. February 2028

   The delegated act setting the calculation methodology for empty space measurement is expected.

3. August 2028

   Harmonised sorting labels under Article 12 become mandatory. The JRC technical proposal (JRC141706) defines 20 labels across 10 material groups.

4. 2030

   Recyclability performance grades are applied to packaging, and the mandatory recycled content targets take effect.

5. 2038

   Grade E packaging is banned from the EU market.

What data you need

How fees work

PPWR is not itself a fee scheme. Fees are charged by the national EPR schemes in each member state, so the same packaging is paid for through LUCID in Germany, CITEO in France, and so on.

What PPWR changes is the basis. Recyclability performance grades apply from 2030, and fee modulation across the EU is expected to follow the grade rather than each national methodology in isolation.

What Merchant produces

• The Declaration of Conformity document, generated from structured component data rather than assembled by hand per packaging unit.
• PP01 to PP12 material codes mapped per component, held alongside the national EPR code so both classification systems stay in step.
• The derived Article 12 sorting label code and group per component, with a reference image for artwork teams.
• JSON API output covering material composition, recyclability, recycled content and sorting label.

Common mistakes

• Treating the whole PPWR timeline as though it landed on 12 August 2026. Sorting labels, recyclability grades and the recycled content targets are all later, and confusing them wastes effort on the wrong work first.
• Assuming PP01 to PP12 replaces the national material codes. They are parallel classification systems, and a component needs both.
• Reading "our coating is a fluoropolymer" as an answer to the PFAS question. The polymeric exclusion applies to the 25 ppb and 250 ppb limits, not to residual monomers, processing aids or non-polymeric impurities.
• Running down existing stock of affected food-contact lines. The PFAS limits apply to packaging placed on the market from 12 August 2026, whenever it was manufactured, so pre-existing inventory is not grandfathered.
• Assuming the proposed suspension removed the authorised representative obligation. Negotiations were discontinued in Council in June 2026, and the proposal never covered producers established outside the EU in any case.

How Merchant helps

• Generate the Declaration of Conformity from component data
• Derive the Article 12 sorting label rather than tagging it by hand
• Assess recyclability against PPWR Annex II and national methodologies
• Hold the data the Digital Product Passport will draw on

Questions

Related reading

Last reviewed 2026-08-17