PPWR Status Update | June 2026
*The content of this news update is intended for informational purposes only.
No rights or claims can be derived from it. For the most up-to-date, complete, and legally binding provisions,
we always refer to the final Regulation and the officially published documents.
Legislation of this scale involves many complexities. Although the legislation was already published by the European Commission on 11 February 2025 and the transition period is relatively generous, its impact remains significant and will be felt throughout the entire packaging value chain. Naturally, we are receiving an increasing number of questions from our customers. That is why we consider it important to keep them actively informed, as the legislation itself also requires.
We aim to provide more concrete information by mid July.
Roles and Responsibilities
As the conformity date of 12 August 2026 approaches, the level of involvement and urgency surrounding compliance with the required obligations continues to increase. This is accompanied by uncertainty and confusion regarding various roles, articles, and guidance documents. Below, you will find an explanation of the key roles, an overview of the timeline so far, and the topics we, as a packaging supplier, are actively working on.
The Supplier
Within the PPWR value chain, we are the supplier.
The supplier provides packaging or packaging components to other parties within the packaging value chain. Under the PPWR, the supplier’s primary responsibility is to provide the information and documentation necessary to demonstrate the conformity of the packaging.
The Producer
In most cases, our customer is the producer of the packaging.
The producer is the party responsible for Extended Producer Responsibility (EPR), including registration, reporting, and financing the collection and treatment of packaging waste. This is typically the party that first places the packaged product on the market in the Member State where the packaging is ultimately expected to become waste.
The Manufacturer
In most cases, our customer is also the manufacturer within the meaning of the PPWR.
The manufacturer is the party responsible for ensuring that the packaging complies with the requirements of the PPWR. The manufacturer prepares the technical documentation and draws up the EU Declaration of Conformity (DoC). For sales packaging, this is typically the party that fills the packaging and places the packaged product on the market under its own name or trademark. According to the European Commission, the manufacturer of sales packaging will normally be the filler or the brand owner.
The Timeline
11 February 2025
The Regulation was published and officially entered into force.
- An 18-month transition period applies, allowing authorities and businesses to prepare. In addition, various articles and guidance documents still need to be further developed.
30 March 2026
The European Commission published the long-awaited Guidance Document, providing clarification on several PPWR provisions that had previously raised many questions. These guidelines are not legally binding, but they offer important interpretations from the European Commission regarding the application of the legislation.
12 August 2026
The first obligations become applicable, including requirements concerning substances of concern in packaging, such as heavy metals and PFAS restrictions (Article 5: Substances of Concern).
From that date onwards, manufacturers must possess a Declaration of Conformity and supporting technical documentation demonstrating compliance with the applicable requirements. As a supplier, we have an obligation to provide relevant information to our customers (Article 16).
12 August 2028
Harmonised packaging labelling requirements are expected to become mandatory throughout the European Union (Article 12).
The objective is to create a universal European approach for communicating packaging composition and the correct method of waste separation. Through the use of uniform symbols and disposal instructions, it should become easier for consumers to correctly sort and recycle packaging.
In addition, work is underway on a system that will make supplementary information digitally available, for example through QR codes.
1 January 2030
This marks the next major PPWR milestone. From that date, several sustainability requirements will become applicable, including:
- Design for Recycling (Article 6): packaging must comply with European recyclability design criteria.
- Minimum Recycled Plastic Content (Article 7): certain plastic packaging formats will be required to contain minimum percentages of post-consumer recycled content.
- Packaging Minimisation (Article 10): packaging may not contain more material than necessary to fulfil its function.
- Recyclability Performance Grades: packaging will be assessed according to harmonised European recyclability criteria.
This is not the complete timeline, but it does cover the legal obligations that will become relevant for us and our customers in the shorter term. The exact and most up-to-date intermediate steps can be found in the official legislation: Regulation (EU) 2025/40.
We Support Where We Can
As prescribed in Article 16, our responsibility is to provide the information and documentation that manufacturers require to demonstrate packaging conformity and to prepare the corresponding Declaration of Conformity.
For us, this is also a process of determining and validating what will be workable in practice. Many aspects of the PPWR remain unclear and are still being further developed through additional guidance and secondary legislation.
In preparation for 12 August 2026, we are currently working on the following:
POINT 1
We are currently collecting all necessary supplier information relating to substances of concern as defined in the legislation. This includes:
- PP virgin raw materials
- PCR raw materials
- Masterbatches
- IML labels
We will document this information in such a way that our customers can use it as input when preparing their own Declaration of Conformity.
POINT 2
We will continue to update and explain the complete timeline, relevant articles, and upcoming obligations through our website. This ensures that our customers always have access to the latest available information.
POINT 3
We will expand the product information and technical data available in our Technical Datasheets. This will include specific information relating to buckets and lids, as well as certificates concerning recyclability and other relevant certifications. Additional information will also be made available through dedicated interactive landing pages.
Important Context Regarding PPWR Compliance Requests
One of the most common misconceptions at the moment is that we are required to provide a Declaration of Conformity for every packaging type or packaging family. This is not how the legislation is structured.
So how does it work?
- The SUPPLIER is required to provide the manufacturer with the necessary information that serves as input for the Declaration of Conformity (Article 16).
- The MANUFACTURER prepares the Declaration of Conformity for each packaging type (Article 15 and Annexes VII and VIII).
We hope for your understanding that it is not feasible for us to prepare extensive tailor-made compliance documentation for every individual customer. While we are committed to supporting our customers as effectively as possible, we must do so through a practical and uniform approach.
At present, the primary focus is on the obligations that will apply from 12 August 2026, but many additional requirements will follow in the years ahead.
Through our sustainability page, you can find information about the PPWR and the relevant articles that will be phased in between now and 2030/2040. We will keep this page continuously updated.
