PPWR Timeline

The entire PPWR legislation will be implemented in phases. Here is a brief overview of the various deadlines:

August 12, 2026 (already in effect)
The first deadline under the PPWR. As of this date, manufacturers must be able to comply with the basic rules. These basic rules stipulate that packaging material requirements will apply and that a dossier must be maintained for each type of packaging, detailing the exact composition of the materials.

February 12, 2027
This is the first reporting year for the producer registry. This also means that enforcement actions may take place.

August 12, 2028
As of this deadline, packaging must include a uniform material label that includes, among other things, recycling icons and information on material composition.

February 12, 2029
Reusable packaging must include a reuse label and, in many cases, a QR code containing information about use, maintenance, and reuse cycles. Packaging must also be reused whenever appropriate.

Starting in 2030
Even stricter requirements for reusable packaging, a cap on empty volumes, and a mandate that packaging must meet minimum recycling criteria.

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What are the rules effective as of August 12, 2026?

The PPWR has been in effect since August 12, 2026. From that date forward, all packaging placed on the market in the EU must meet the following requirements:

• lead, cadmium, mercury, and hexavalent chromium, with a combined maximum of 100 mg/kg;
• There are strict limit values for PFAS in packaging that comes into contact with food;
• Manufacturers maintain a technical dossier detailing the material composition of each package;
• A signed EU Declaration of Conformity (DoC) can be prepared in which the manufacturer declares that the packaging meets the requirements.

For the purposes of the law, “manufacturer” refers to the company that markets the packaging under its own name or brand. If you supply packaging to a Dutch micro-enterprise (fewer than 10 employees and a maximum of 2 million euros in revenue), you may be considered the manufacturer yourself.

A DoC belongs with a package, not with a product. If you use the same box for screws in five different lengths, a single declaration is sufficient, provided you document which items go into which package.

A wholesaler with thousands of SKUs and dozens of packaging suppliers quickly realizes that this is a data challenge. Packaging data is often scattered across ERP systems, PIM systems, Excel spreadsheets, and email correspondence with suppliers. Recording every packaging component by supplier and SKU is therefore essential to substantiate a DoC when requested.

Haven't started yet?

Start by taking stock of all the packaging you use, by supplier and by level in the supply chain. At the companies we speak with, this overview usually doesn’t exist. The data is scattered across departments and teams—and that, in turn, is scattered across systems such as the ERP, supplier portals, Excel spreadsheets, and product files that have never been consolidated. That makes sense. Until this summer, no one was required to keep track of this centrally.

Next, consider ownership. Does packaging information fall under purchasing, product development, or quality control? Often, everyone has a piece of it, but no one has the whole picture. If you clarify this now, you’ll also know who ends up with the technical file and who signs the DoC.

Curious to know where your organization stands? Take the PPWR Quick Scan, and together we’ll identify which packaging data you already have in order and where there’s still work to be done.