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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Get free advicePPWR · 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.
PPWR starter offer
The PPWR has applied since 12 August 2026, and many companies are still at the beginning. Request a certification now and receive 25% off the first year.
Offer valid until 27 September 2026
Discount code
PPWR-26
Just add the code to your message when you send us the completed questionnaire at contact@flustix.com.
The code applies once per customer and to one product certification. The discount covers the first contract year and requires a certification term of six years. It cannot be combined with other discounts and applies to enquiries received by 27 September 2026.
To the questionnaire
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 first substantive and formal requirements have applied. Further central requirements, in particular on recyclability and minimum recycled content, take effect from 2030. The wording of the regulation is published in the Official Journal of the EU.
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 requirements have applied in principle since 12 August 2026. Which duties actually fall on a company depends on its role and on the packaging in question.
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 summed limit applies in principle to packaging and packaging components. Article 5 provides no general exemption based on low volumes or company size.
Food contact
Food contact packaging may no longer be placed on the market if it reaches or exceeds any of the following limits: 25 ppb for individual PFAS in targeted analysis, 250 ppb for the sum of PFAS analysed in a targeted manner and 50 ppm for PFAS including polymeric PFAS. Where total fluorine content exceeds 50 mg/kg, it must be demonstrated on request which share of the measured fluorine is attributable to PFAS and which is not.
Conformity
Before placing packaging on the market, the producer must carry out the conformity assessment procedure and draw up the technical documentation under Annex VII. Once conformity is demonstrated, it issues the EU declaration of conformity under Article 39 and Annex VIII. By issuing it, the producer takes on responsibility for the conformity of the packaging.
Supply chain
Suppliers must provide the producer with all information and documents it needs to demonstrate the conformity of the packaging. This includes the technical documentation required for the requirements of Articles 5 to 11.
Evidence
For central requirements of the regulation, material properties have to be documented in a traceable way. For these four fields flustix supplies independently verified evidence that secures your technical documentation and makes it hold 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) and (6) | To PFAS-FREE certification |
| Plastic content below 5% | Article 3(1)(24) · Article 7(5)(b) | To LESS PLASTICS certification |
What the PPWR requires
From 1 January 2030 at the earliest, 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 a documentation-based audit. 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 15343 and DIN EN ISO 22095. 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 is carried out by laboratories accredited to ISO/IEC 17025, the conformity assessment by certification bodies accredited to ISO/IEC 17065.
What the PPWR requires
Across Europe the PPWR sets a clear 95/5 threshold: where the plastic content of paper-based packaging accounts for no more than 5% of total mass, it counts as a minor material component. The packaging therefore does not fall under the definition of composite packaging. In addition, this plastic content is exempt from the minimum recycled content quotas.
Why it matters now
For paper, board and fibre-based packaging the 95/5 threshold is decisive. Staying below 5% plastic creates the regulatory basis for classification as paper-based packaging and, in practice, supports allocation to the paper stream. It can also ease access to lower EPR fees and create a direct financial benefit.
The flustix evidence
flustix LESS PLASTICS Packaging independently verifies a plastic content below 5%. The certification thereby documents the relevant PPWR threshold and creates a robust basis for classification as paper-based packaging, for the paper stream and for possible EPR benefits. National recyclability requirements are taken into account as well.
Roles and duties
The PPWR distinguishes between responsibility for the conformity of a packaging and the duties arising from registration and extended producer responsibility. One company can hold several roles at the same time.
The question here is: who has to ensure and demonstrate that the packaging meets the PPWR requirements?
| Role | Duty under the PPWR | What that means in practice |
|---|---|---|
| Producer / where applicable brand owner | Ensure conformity, carry out the conformity assessment, draw up the technical documentation and issue the EU declaration of conformity. Art. 15, 38, 39 | Carries the central responsibility for conformity, even where the packaging or product is developed or manufactured by third parties. |
| Supplier | Provide all information and documents the producer needs to demonstrate conformity. Art. 16 | Supplies the material data and technical evidence on which the producer builds its documentation. |
| Importer | Before placing on the market, verify in particular that the conformity assessment procedure has been carried out and the technical documentation drawn up. Art. 18 | May only place packaging on the market where the PPWR requirements are met. |
| Distributor / retail | Verify certain mandatory details and refrain from making available where conformity is in doubt. Art. 19 | Has verification and due diligence duties of its own, without taking over the producer’s conformity assessment. |
| Authorised representative of the producer | Takes on certain tasks of the producer under written mandate. Art. 17 | Can in particular keep documentation available for authorities and pass it on. Responsibility for conformity stays with the producer. |
The question here is: who is responsible for registration, EPR and financing packaging waste?
| Role | Duty under the PPWR | What that means in practice |
|---|---|---|
| Producer under EPR | Registration and fulfilment of extended producer responsibility for the packaging it first makes available in a member state. Art. 3(1)(15), Art. 44 et seq. | Responsible in particular for registration and EPR duties in the respective member state. One company can be both producer and EPR producer. |
| Authorised representative for extended producer responsibility | Takes on the EPR duties of the producer in the respective member state under the conditions of the PPWR. Art. 45 | Particularly relevant for cross-border supply. Depending on the constellation, appointing one is mandatory. |
A brand owner can therefore be both producer and EPR producer under the PPWR: as producer it is responsible for conformity, technical documentation and the EU declaration of conformity. As EPR producer it fulfils the registration and EPR duties in the respective member state.
The most common gap: where the brand owner is the producer under the PPWR, it carries responsibility for conformity while essential material data sits with the supplier. Those documents form the basis for the conformity evidence, but they do not transfer the responsibility.
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 from a supplier alone does not replace the brand owner's own PPWR conformity evidence.
Under the PPWR guidance (30 March 2026, C(2026) 2151) the brand owner is the manufacturer and therefore carries the responsibility for the conformity of its packaging. Evidence from suppliers can provide the technical basis for this, but it does not replace the brand owner’s own, clearly attributable evidence. This is exactly where the flustix sub-licence system comes in. The supplier, for example a white-label manufacturer, has the pallet goods tested once; downstream brand owners receive their own sub-certificate, their own licence number and their own entry in the public flustix database. Without repeat testing, without duplicated audit costs and without having to disclose the supply chain to the B2B customer.
In its PPWR guidance the European Commission makes clear: the manufacturer is not necessarily the company that physically produces the packaging. Where the packaging or the packaged product is manufactured or placed on the market under a company’s own name or brand, the brand owner is the responsible party and has to hold the evidence. Along a supply chain the PPWR recognises in principle only one manufacturer: the brand owner. A pre-certification held by the supplier is therefore a valuable technical building block, but it does not replace the responsible brand owner’s own evidence.
Free EmpCo Claim Check
From 27 September 2026, every environmental claim on a product or its packaging must be substantiated. Send us up to five of your claims and we will set out which of them hold, which need specifying and where independent evidence is required. You receive a signed assessment report as a PDF within two to three working days. Free of charge and without obligation.
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 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.
Editorial responsibility: Malte Biss, CEO & Founder of flustix
Our documents on this
Our own studies, briefing papers and talks on the subject of this page. Each page sums up the key points; the full document is available there as a download.
Let’s talk
We go through your packaging portfolio with you and work 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.
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