PPWR: What You Actually Need Before 12 August 2026 (and What Can Wait)

On 12 August 2026, Regulation (EU) 2025/40, better known as the Packaging and Packaging Waste Regulation or PPWR, becomes applicable across all 27 EU member states. It replaces the 30-year-old Packaging Directive 94/62/EC, and unlike a directive it applies directly. There is no national transposition, no member-state variation to hide behind, and no grace period after the date (source: EUR-Lex, Regulation (EU) 2025/40).

We have spent the last months walking clients through what this means in practice, and one thing comes up in almost every conversation: a lot of what people think is due on 12 August is actually due in 2028, and a lot of what is genuinely due on 12 August is being overlooked. This article separates the two. If you produce retail packaging or export cartons for non-food consumer products, this is the version we would give you on a call.

The short version

If you place packaging or packaged products on the EU market, here is what actually changes on 12 August 2026:

• You need an EU Declaration of Conformity for every packaging type. 
  Signed, dated, and ready to show. This is the big one.
• You need technical documentation supporting that declaration. 
  Per Annex VII of the regulation.
• Your packaging must meet the design requirements. 
  Including the empty-space rule for e-commerce and transport packaging.
• You must keep the documentation. 
  Five years for single-use packaging, ten for reusable.

And here is what does NOT change on 12 August 2026, despite what a lot of articles suggest:

• The harmonised material-composition pictograms are not mandatory until 2028. 
  The Commission still has to publish the implementing act specifying what the labels look like. You cannot fully comply with something that has not been specified yet.
• Recycled-content minimums, reuse targets and digital labelling phase in between 2027 and 2030.

So if your plan for the summer was "redesign all our packaging artwork before August", you can probably relax on the artwork and put that energy into your documentation instead. That is where the real deadline sits.

Are you the producer? Probably yes, even if you never touch a machine

This trips up more businesses than any other part of PPWR, so it is worth being precise.

Under the regulation, the producer is the party that manufactures packaging or has packaging manufactured under its own name or trademark. That second half is the important one. If you design your retail boxes and export cartons, put your brand on them, and have them produced by a factory in China, Vietnam or anywhere else, you are the producer under PPWR. Your factory is not. Your factory is your supplier.

This means the conformity assessment, the technical documentation, the Declaration of Conformity and the record-keeping are all your legal responsibility. You can ask your factory to provide test data and material specifications, and a good factory will, but you sign the declaration and you carry the liability.

We say this bluntly because we regularly meet businesses who assume their Chinese packaging supplier "handles the CE side of things". PPWR does not work that way, and neither does GPSR. If you want the fuller version of that argument, we wrote about it in GPSR for Importers from Asia.

What the Declaration of Conformity actually requires

The EU Declaration of Conformity for packaging follows Annex VIII of the regulation. It is a short document, usually one page, but it can only be signed once the work behind it is done.

Your DoC must contain:

1. A statement that the declaration is issued under your sole responsibility as producer.
2. A description of the packaging that allows it to be traced, typically the packaging type, dimensions, materials and an internal reference or SKU code.
3. The legal reference to Regulation (EU) 2025/40, plus any other Union legislation that applies to that packaging.
4. References to the harmonised standards, common specifications or other technical specifications you used to demonstrate conformity.
5. Place, date, name and function of the person signing on behalf of the producer.

The declaration is signed and dated, and retained for five years for single-use packaging or ten years for reusable packaging (source: EUR-Lex, Regulation (EU) 2025/40, Article 39 and Annex VIII).

One practical note: you need a Declaration of Conformity per packaging type, not per product SKU. If you sell forty products that all ship in the same three carton sizes and the same retail box format, you are looking at a handful of declarations, not forty. This is usually the point in the conversation where clients visibly relax.

What goes into the technical documentation

The technical documentation sits behind the declaration and is defined in Annex VII. You do not submit it anywhere, but you must be able to produce it if a market surveillance authority asks. In the Netherlands that would be the ILT or the NVWA depending on the product context.

The file should contain, where applicable:

• A general description of the packaging and what it is intended for.
• The conceptual design, manufacturing drawings, and the materials used for each component.
• The explanations needed to understand those drawings and specifications.
• A list of the harmonised standards or common specifications you applied, in full or in part, and any other technical specifications you used.
• A qualitative description of how you carried out the assessments required under Articles 6, 10 and 11 (recyclability, substances of concern, minimisation).
• Test reports where relevant.
• An analysis and assessment of the risks of non-conformity.

For a typical non-food retail box plus export carton setup, this is realistically a 10 to 20 page file per packaging type, most of which your packaging supplier can help populate if you ask the right questions.

The design requirements that bite on day one

Two design rules apply from 12 August 2026 and are worth checking now, because fixing them takes lead time with a factory.

Minimisation. Packaging must be reduced to the minimum weight and volume necessary to ensure functionality, taking into account the material and its intended use. In practice this means you should be able to justify why your packaging is the size it is. Oversized retail boxes with large void areas are exactly what this rule targets.

Empty space in e-commerce and transport packaging. The empty space ratio in grouped, transport and e-commerce packaging must not exceed 40%, unless it is technically unavoidable. If you ship products in cartons that are half air, that is a compliance problem from day one, not just a shipping-cost problem.

If your export cartons were designed around what your factory had in stock rather than around your product dimensions, this is the point to revisit that. Ordering a right-sized carton takes weeks; being non-compliant on a container that has already sailed takes considerably longer to fix.

Labelling: what is real and what is being oversold

Here is where we differ from a lot of the advice circulating right now.

You will read that packaging must carry harmonised material-composition pictograms. That is true, but the obligation applies from 2028, not from August 2026. The Commission is required to publish an implementing act specifying the labelling methodology and the visual form of those pictograms, and until that lands, nobody can produce a compliant harmonised label because the specification does not exist yet (source: European Commission, packaging and packaging waste).

What this means for you practically:

Do not reprint all your packaging artwork this summer on the assumption that you need new pictograms in August. You will likely have to reprint again in 2027 when the actual specification is published.

Do plan for it in your next artwork cycle. If you are already redesigning packaging for other reasons, leave physical space in the layout for the material-composition label and a possible QR code. Retrofitting space into a crowded design is harder than reserving it now.

Do keep an eye on existing national schemes. Until the EU-harmonised system fully replaces them, national labelling requirements such as the French Triman logo and the Italian environmental labelling rules still apply where relevant. The harmonised system supersedes these, but on the 2028 timeline, not this August.

Do check that your current labels are actually correct today. This is the part that gets lost in the PPWR conversation. Your existing GPSR labelling obligations do not pause while you wait for PPWR: product identification, manufacturer and EU Responsible Person details, traceability codes, warnings and language requirements all apply right now. If a label is wrong today, PPWR is not your most urgent problem. In our experience most label issues we find are GPSR issues, not PPWR ones.

Your practical checklist for the next weeks

This is the order we work through it with clients.

1. Inventory your packaging types. Not SKUs, packaging types. Retail box formats, export carton sizes, any inner packaging, any reusable items. Most businesses land on somewhere between three and twelve types.
2. For each type, collect the material specification from your supplier. Composition by weight, any coatings, adhesives, inks, and confirmation on substances of concern. Ask specifically, do not accept "it is standard cardboard".
3. Check the two design rules. Is the packaging minimised? Is the empty space in your transport and e-commerce packaging under 40%? Measure, do not estimate.
4. Build the technical file per packaging type. Using the Annex VII list above as your table of contents.
5. Draw up and sign the Declaration of Conformity per packaging type. Following Annex VIII.
6. File everything with a retention date. Five years single-use, ten years reusable, counted from when the packaging is placed on the market.
7. Add packaging documentation to your supplier onboarding. So the next factory you work with delivers this material as standard rather than as a favour.

If you already maintain a technical file for GPSR, the good news is that PPWR documentation slots alongside it rather than duplicating it. Different regulation, different annexes, but the same discipline and often the same supplier contacts.

What happens if you are not ready on 12 August

PPWR is enforced by national market surveillance authorities, and the enforcement toolkit is the familiar one: requests for documentation, orders to bring packaging into conformity, withdrawal from the market, and fines set at member-state level. Marketplaces are also increasingly asking for compliance evidence proactively, in the same way they did with GPSR in early 2025.

Realistically, an authority is unlikely to knock on 13 August. But the request, when it comes, gives you days rather than months, and "we are working on it" is not a defence. The businesses that got through the GPSR transition comfortably were the ones with the file already built when the letter arrived.

Conclusion: documentation first, artwork later

If you take one thing from this article: the 12 August 2026 deadline is a documentation deadline, not a labelling deadline. Declaration of Conformity per packaging type, technical file behind it, design rules checked, records retained. The harmonised pictograms that everyone is talking about arrive in 2028, and the specification for them does not even exist yet.

If you produce retail packaging or export cartons under your own brand and have them made abroad, you are the producer under PPWR and this is your file to build. Your supplier can help populate it, but the signature and the liability are yours.

Sources

• European Union. Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste (PPWR). EUR-Lex. eur-lex.europa.eu/eli/reg/2025/40
• European Commission. Packaging and packaging waste. environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste_en
• Gleiss Lutz. The new EU Packaging Regulation: Key requirements from August 2026. gleisslutz.com/en/know-how/new-eu-packaging-regulation-key-requirements-august-2026
• Intertek. EU PPWR requirements effective from August. intertek.com/products-retail/insight-bulletins/2026/1536-eu-ppwr-requirements-effective-from-august/
• Inspectie Leefomgeving en Transport (ILT). ilent.nl