The PPWR is the EU's packaging law: Regulation (EU) 2025/40 on packaging and packaging waste. It replaced the 1994 Packaging Directive and, as a regulation, applies directly and in the same way in every EU country. It covers all packaging placed on the EU market, whatever its material and wherever it was made.
What the PPWR covers
- Substances (Article 5): heavy metals at most 100 mg/kg, PFAS limits for food-contact packaging, and minimizing substances of concern.
- Recyclability (Article 6): packaging designed for recycling, graded by criteria in later EU acts, and recycled at scale from 2035.
- Recycled content (Article 7): minimum recycled content in plastic packaging from 2030, rising in 2040.
- Labelling (Article 12): a harmonized label on material composition to help consumers sort packaging.
- Minimization (Articles 10 and 24): weight and volume reduced to what's needed, and at most 50% empty space in grouped, transport and e-commerce packaging.
- Re-use (Articles 11 and 29): design rules for reusable packaging and re-use targets for transport, grouped and some beverage packaging.
- Extended producer responsibility: harmonized registration and producer obligations across the EU.
The declaration of conformity
Every packaging type needs an EU declaration of conformity under Article 39, following the model in Annex VIII. The manufacturer assesses the packaging itself (Module A, internal production control, with no notified body), keeps the technical documentation set out in Annex VII and signs the declaration. Both are kept for 5 years, or 10 years for reusable packaging, and must be given to an authority within 10 days of a request.
Who is the manufacturer
Under Article 3(1)(13), the manufacturer is whoever makes packaging or a packaged product, or has it designed or made under its own name or trademark. The Commission's guidance says there is only one manufacturer per packaging. For branded packaging, that is usually the brand, not the factory. Importers and distributors who sell packaging under their own name take on the same obligations.
PPWR and Digital Product Passports
The PPWR and the ESPR are separate laws, but they draw on the same supplier data: materials, weights, recycled content and test results. Brands preparing Digital Product Passports can collect packaging data from the same suppliers in the same process. For dates and requirements in detail, see the PPWR guide.
How Veribl helps
Veribl lets brands describe each packaging type, collect component data and test results from packaging suppliers, check the PPWR requirements that apply today and sign the EU declaration of conformity in all 24 EU languages, next to their product passports.
See PPWR compliance in VeriblOfficial sources
Frequently asked questions
When does the PPWR apply?
The PPWR entered into force on 11 February 2025 and applies since 12 August 2026. Some obligations follow later: the harmonized sorting label from 12 August 2028 at the earliest, and minimization, empty-space limits, format restrictions and re-use targets from 1 January 2030.
Has the PPWR been delayed?
No. No act postpones the regulation. The Commission's December 2025 simplification package proposed suspending only the rule on appointing an authorized representative for extended producer responsibility, and some implementing acts are late, which moves the dates that depend on them.
Who must sign a PPWR declaration of conformity?
The manufacturer of the packaging: the company that manufactures it or has it designed or manufactured under its own name or trademark. For branded packaging that is usually the brand, even when a supplier makes it. A micro-enterprise whose packaging supplier is in the same EU country can leave this to the supplier.
What are the PPWR PFAS limits?
Packaging intended to come into contact with food must not contain PFAS at or above 25 ppb for any single PFAS, 250 ppb for the sum of PFAS, or 50 ppm total fluorine (Article 5(5)), since 12 August 2026.
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