12 Aug 2026
Date of application
The regulation has applied since this day, with no transition period for packaging newly placed on the market.
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Book a free consultationPPWR · Regulation (EU) 2025/40
Since 12 August 2026 the EU Packaging Regulation applies directly in all 27 member states. Anyone placing packaging on the market must issue a declaration of conformity and hold technical documentation that stands up to scrutiny. This page explains which requirements apply when, who is accountable and which evidence actually holds.
Recyclability · Recycled content · PFAS in food contact · Technical documentation · International supply chains
At a glance
12 Aug 2026
The regulation has applied since this day, with no transition period for packaging newly placed on the market.
27 states
As a regulation it takes effect directly, with no national transposition. The same requirement in every member state.
2 annexes
Technical documentation under Annex VII and the EU declaration of conformity under Annex VIII are mandatory, not optional.
1 Jan 2030
Recyclability and minimum recycled content become a condition for market access.
PPWR · Regulation (EU) 2025/40
On 12 August 2026 the EU Packaging Regulation became applicable. Substance restrictions, PFAS limits, the declaration of conformity and technical documentation apply with no transition period.
Fundamentals
The PPWR is Regulation (EU) 2025/40 on packaging and packaging waste. It has applied since 12 August 2026 and replaces Packaging Directive 94/62/EC. The decisive difference lies in its legal form. A directive had to be transposed by every member state, which produced 27 interpretations. A regulation applies directly, so the same requirement holds in Berlin, Barcelona and Bucharest. For companies this shifts the work from national adaptation to providing evidence. No longer “What does this market require?” but “What do I prove it with?”. That is where it is decided whether a supplier declaration is enough or independent evidence is needed. And it does not arrive in one step. Since 12 August 2026 the formal duties have applied, the substantive requirements only from 2030.
Timeline
Five dates that packaging decisions have to be aligned with. Since 12 August 2026 the formal duties and the substance restrictions apply; the substantive requirements on recyclability and recycled content follow from 2030. Several of the later dates are lower limits: if the corresponding legal act comes later, the date moves with it.
12 Aug 2026
Date of application
Art. 5, 39, Annex VII/VIII
1 Jan 2030
Design for recycling
Art. 6, Art. 7(1)
1 Jan 2035
Recycled at scale
Art. 6
1 Jan 2038
Grade C dropped
Art. 6(3)
1 Jan 2040
Second quota stage
Art. 7(2)
Immediately effective
These four requirements have applied since 12 August 2026 without a grace period, regardless of company size or volume.
Substance restrictions
The sum of the concentrations of lead, cadmium, mercury and hexavalent chromium in packaging and packaging components must not exceed 100 mg/kg. The value applies to all packaging, regardless of material and volume. The regulation provides no volume thresholds and no exemptions for small companies.
Food contact
Food contact packaging may no longer be placed on the market if it reaches or exceeds the following values: 25 ppb for individual PFAS in targeted analysis, 250 ppb for the sum of PFAS and 50 ppm for PFAS including polymeric compounds, determined via total fluorine content. What counts is the packaging in its final form, including label, adhesive and printing ink.
Declaration
Anyone placing packaging on the market must be able to issue an EU declaration of conformity following the template in Annex VIII. There is no grace period for this duty. The declaration rests on the technical documentation under Annex VII, in which the basis for every declared property must be traceably recorded.
Third countries
Anyone making packaging or packaged products available for the first time in an EU member state without being established there generally needs an authorised representative in that country. For international supply chains this means an additional structure, and for the suppliers behind them a far more concrete demand for documented product properties.
Evidence
Four requirements of the regulation cannot be settled with an internal statement, because they rest on material properties that are measurable or auditable. For these four fields flustix supplies independently verified evidence that feeds into your technical documentation and holds up towards customers, retail and authorities.
| PPWR requirement | Legal basis | flustix evidence |
|---|---|---|
| Recyclability | Article 6 | To RECYCLABLE certification |
| Recycled content | Article 7 | To RECYCLED certification |
| PFAS in food contact | Article 5(5) | To PFAS-FREE certification |
| Plastic content below 5% | Article 7(5) | To LESS PLASTICS certification |
What the PPWR requires
From 1 January 2030, packaging must meet design-for-recycling criteria and is classified into performance grades: grade A from 95%, grade B from 80%, grade C from 70% recyclability. Anyone not reaching the grade C threshold may no longer place it on the market. From 2035 the requirement is added that the packaging is actually recycled at scale. From 2038 grade C is dropped, only A and B remain permissible.
Why it matters now
The performance grade becomes a cost issue before it becomes a market access issue: producers’ EPR contributions are modulated in line with the performance grades. Poorly recyclable packaging pays more. Packaging development runs in cycles of three to five years, so the material decision for 2030 is being taken today.
The flustix evidence
flustix RECYCLABLE assesses recyclability via RecycleMe against the minimum standard under Section 21(3) of the German Packaging Act, DIN EN 13430, ISO 15270 and the PPWR criteria with performance levels A to C. TÜV SÜD confirms the result through an independent conformity assessment and an audit of your production chains. The trustmark states the verified percentage and is traceable via the licence number in the public database.
What the PPWR requires
From 1 January 2030, plastic packaging must contain minimum shares of post-consumer recyclate, calculated as an average per manufacturing plant and year.
Why it matters now
Only post-consumer recyclate counts towards the quota. Post-industrial recyclate does not meet the requirement, even though many suppliers report both as “recycled content”. Packaging with 30% PIR and 10% PCR does not meet a 30 percent quota, but sits at 10%. Anyone unable to document the origin of their recyclate cannot declare the quota.
The flustix evidence
flustix RECYCLED verifies recycled content by chain-of-custody audit along the supply chain, on the basis of DIN EN ISO 14021, DIN EN 15343, DIN EN ISO 22095 and DIN 6120. Alongside the percentage, the trustmark explicitly states the type of recyclate: PCR, PIR or MIX. This makes it immediately visible which share counts towards the PPWR quota and which does not.
| Packaging category | from 2030 | from 2040 |
|---|---|---|
| Contact-sensitive packaging with PET as the main component (excluding single-use beverage bottles) | 30 % | 50 % |
| Contact-sensitive packaging made of plastics other than PET (excluding single-use beverage bottles) | 10 % | 25 % |
| Single-use plastic beverage bottles | 30 % | 65 % |
| All other plastic packaging | 35 % | 65 % |
What the PPWR requires
The three limits of 25 ppb, 250 ppb and 50 ppm apply directly. Coated paper and board packaging is affected above all, wherever grease, water or dirt repellency is required.
Why it matters now
In practice, total fluorine content is often determined first, because not all PFAS can currently be reliably detected individually. This order helps with prioritisation, but has no legal effect: a total fluorine value below 50 ppm does not rule out that an individual substance exceeds the 25 ppb threshold. It becomes particularly relevant with recycled board, where PFAS can occur as unintentional carry-over from earlier applications.
The flustix evidence
For food contact packaging, the flustix PFAS-FREE certification programme takes the requirements of Regulation (EU) 2025/40 as the regulatory minimum and goes beyond them in several respects, among others in documentation, analytics and overall assessment. Testing takes place in laboratories accredited to ISO/IEC 17025, the conformity assessment follows ISO/IEC 17065.
What the PPWR requires
Plastic components accounting for less than 5% of the total weight of the packaging unit are exempt from the minimum recycled content quotas. Further exemptions apply among others to compostable plastic packaging and certain packaging for medicinal products and medical devices.
Why it matters now
This threshold is decisive for paper, board and fibre-based packaging with a thin plastic coating. Anyone below 5% does not have to meet a recycled content quota from 2030. Anyone just above it does. The difference is decided in tenths of a percent, and it can only be argued with a documented material balance.
The flustix evidence
flustix LESS PLASTICS Packaging certifies a plastic content below 5%, that is packaging at least 95% free of plastic, independently verified. This provides evidence for the threshold in Article 7 that does not rest on your own calculation.
Roles and duties
The producer is responsible, that is whoever first places the packaging on the Union market under its own name or brand. Importers and distributors have their own verification and due diligence obligations; under Article 16, suppliers must provide the documents.
| Role | Duty under the PPWR | What that means in practice |
|---|---|---|
| Producer / brand owner | Ensure conformity, keep technical documentation, issue the EU declaration of conformity | Carries the risk, even where it does not manufacture the packaging itself |
| Importer | Verify that the conformity procedure has been carried out and the documentation exists | Shares liability if it places goods on the market without checking |
| Distributor / retail | Due diligence before making available | Demands evidence before listing |
| Supplier / packaging manufacturer | Provision of the documents required for the conformity assessment | Becomes the bottleneck when the data is not structured |
| Authorised representative | Representation of non-established producers in the respective member state | Additional structure for supply chains from third countries |
The most common gap: the brand owner has to declare what the supplier knows. Material data today mostly arrives as a supplier declaration, that is self-disclosure, and that does not shift the risk.
Suppliers outside the EU will find the requirements for their role gathered on our page on EU market access.
Quality of evidence
A test report confirms a measurement result on a sample. A certification additionally assesses conformity with a programme, monitors it continuously and governs which claim it permits. For internal documentation a test report can be enough. As soon as it becomes a claim towards customers or retail, generally not.
The two levels interlock. In the flustix programmes, laboratories accredited to ISO/IEC 17025 carry out the testing, and the conformity assessment is made independently to ISO/IEC 17065. Existing test reports and prior certifications are recognised where they meet the programme requirements. Anyone who has already tested does not start from scratch. How this works in detail is set out on our page on the testing process.
For advertising claims towards consumers, the EmpCo Directive additionally applies from 27 September 2026. What applies there is set out on our page on green claims.
Sub-licence
Evidence held by the supplier is not enough.
A technical certification ends with the finished packaging. What the brand owner may print on it and record in its documentation is a different question. For that it needs evidence in its own name. This is what the flustix sub-licence system provides. The supplier has the material tested once, downstream customers receive their own licence number and their own entry in the public database. Without repeat testing, without duplicated audit costs and without disclosing the supply chain.
In its PPWR guidance the European Commission makes clear who is meant: the “manufacturer” is not necessarily the company that physically produces the packaging. Where it is placed on the market under a company’s own name or brand, the brand owner is the manufacturer, and along a supply chain there is in principle only one. A pre-certification held by the supplier is therefore a valuable building block, but it does not move the responsibility.
Our promise
Every certificate issued appears with its licence number in the public database, where anyone can verify it.
Practice
Six steps you can take without outside help, and which considerably shorten the later work on evidence.
1
Record every SKU with material, weight, plastic content and supplier. Without this basis no gap analysis is possible, and in many companies the specifications are spread across PDFs, spreadsheets and ERP exports.
2
Assign each packaging item to a PPWR category: contact-sensitive PET, contact-sensitive non-PET, single-use beverage bottle, other plastic packaging. Mark exemptions such as plastic content below 5% separately.
3
For packaging with food contact the PFAS limits apply immediately. Test coated paper and board packaging and recyclate-containing materials first.
4
Obtain the distinction between PCR and PIR in writing from every supplier. Figures without this distinction cannot be used for Article 7.
5
Where supplier declarations are the only basis, apply independent testing or certification. Existing test reports are taken into account.
6
Anyone structuring their technical documentation today only has to attach the evidence for 2030, instead of building it from scratch.
Application
Food & beverages
Contact-sensitive packaging carries the highest recycled content quotas and the PFAS limits at the same time. Both requirements hit the same packaging.
Cosmetics & personal care
Cosmetics packaging counts as contact-sensitive packaging. The 30% quota for PET applies from 2030.
Retail & private label
Retailers are the brand owners of their own labels and therefore producers under the PPWR. The duty to provide evidence sits with them, the data sits with the supplier.
Packaging manufacturers
Customers increasingly demand documented material properties instead of supplier declarations. Certified evidence shortens qualification processes.
Recyclers & material producers
The distinction between PCR and PIR decides usability for Article 7. Anyone able to document it sells into regulated demand.
E-commerce & shipping
Shipping packaging is subject to packaging minimisation and the rules on empty space. Fulfilment service providers are expressly named in the regulation as well.
Frequently asked
We answer fourteen questions on the PPWR together in the questions section under “Regulations”, where the questions on the other pieces of legislation come together as well.
Let’s talk
Kathrin Schaumann goes through your packaging portfolio with you and works out which PPWR requirements apply to which products and where evidence is missing. Without obligation, without preparation on your side and with a clear assessment at the end.
Prefer to write? Send us a message
Kathrin Schaumann
Sales & Certification Development
Program & Partnerships
k.schaumann@flustix.com+49 179 616 27 98
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