PPWR at a Glance: New EU Packaging Regulations. What Do They Mean for Your Business?

Retailers and businesses operating in the European Union are once again facing new legal obligations. As of August 12, 2026, most of the key provisions of the new PPWR regulation will take effect. Failure to comply with these requirements may result not only in substantial financial penalties but also in a complete sales ban and the seizure of goods. In this article, you’ll learn exactly who is covered by the PPWR, what documents you need, and how to avoid the most common mistakes.  

What is the PPWR, and what is the main purpose of the regulation?

• The PPWR (Packaging and Packaging Waste Regulation) is the new Regulation (EU) 2025/40 of the European Parliament and of the Council of December 19, 2024.
• It replaces the previous directive from 1994 (94/62/EC).
• As an EU regulation, these provisions are directly applicable in every Member State, which means that companies cannot wait for amendments to national laws.
• The regulations cover the entire life cycle of packaging: from its design and the materials used to the moment it becomes waste.
• The main goal of PPWR is to drastically reduce the amount of packaging waste entering the market.
• The regulation is intended to require companies to design packaging with the environment, ease of recycling, and reusability in mind, rather than focusing solely on visual appeal.

Who is affected by the new law? (No exceptions for small businesses!)

• The PPWR regulations apply to virtually any entity that places packaging on the EU market in any way.
• Important: The regulation does not provide for a general exemption for micro and small businesses from basic reporting and documentation requirements.
• This law applies regardless of whether the packaging is made of cardboard, plastic, glass, paper, or wood, and regardless of the industry (medical, food, cosmetics, or e-commerce).

The regulation identifies several key roles. Keep in mind that your company may fulfill several of them at the same time:

• Manufacturer: This is an entity that owns the packaging designed or manufactured under its own brand (its logo appears on the packaging). If you import a product from outside the EU and sell it under your own brand, you are considered a manufacturer under the regulations.  
• Producer (as defined by the EPR): The entity that first places a given package on the market in a specific country. Among other things, it is responsible for registration in the relevant systems (such as Poland’s BDO).  
• Importer: A company that imports finished, pre-packaged products from countries outside the European Union (e.g., from China).  
• Distributor: Anyone who resells a finished product without modifying it, including online stores and e-commerce platforms.  

PPWR Schedule: What Do You Need to Have Ready by August 12, 2026?

• The regulation officially took effect on February 11, 2025.
• However, August 12, 2026, is the most important date for businesses, as most of the requirements take effect on that date.
• By that time, companies must prepare complete technical documentation and issue declarations of conformity for all types of packaging used.
• Packaging will have to comply with strict limits on the content of harmful substances—this applies to heavy metals in all packaging and PFAS chemicals in packaging that comes into contact with food.
• Every company must be registered in the national waste management system (e.g., BDO in Poland) in every EU country to which it sells.
• In the case of cross-border sales to countries where the company does not have a registered office, it is necessary to appoint a so-called authorized representative.

Watch out for a common mistake! Many companies believe they have until 2028 to comply. In 2028, the rules regarding labeling and QR codes will take effect, but the full technical documentation, registrations, and substance limits have been in effect since August 12, 2026. Starting in 2030, additional requirements will be introduced, such as minimum recycled content thresholds for plastics.  

Changes for E-commerce – No More "Packing Air"

• For e-commerce, shipping packaging (e.g., boxes, envelopes) is a very important aspect of PPWR.
• Starting in 2030, a strict limit on empty space in e-commerce packages—capped at 50%—will take effect.
• Distributors and retailers will be required to carefully select the size of cartons or plastic bags to match the actual dimensions of the product.
• Furthermore, online marketplaces will be required to verify that sellers have fulfilled their obligations under extended producer responsibility (EPR).

Technical Documentation vs. the EU Declaration of Conformity—What's the Difference?

• A common mistake made by business owners is preparing a single, general document for the entire company.
• According to the PPWR, two separate types of documents must be maintained for each type of packaging used.
• Technical documentation: This is a comprehensive, internal company record. It contains detailed information on specifications, drawings, dimensions, and reliable test results confirming that the packaging meets the requirements.  
• EU Declaration of Conformity: This, in turn, is a concise, formal, and official statement. It confirms that the packaging complies with the standards and must be signed by company representatives.  
• Please note that documentation must be based on evidence and test results from accredited laboratories—generating statements using artificial intelligence is not permitted by law.

Penalties, Customs Inspections, and Business Risks

• Failure to comply with regulations poses a significant risk to the operation of the entire business.
• Failure to provide a declaration of conformity or technical documentation may result in an order to withdraw the product from the market and the inability to legally place it on the EU market.
• Your products may be inspected and detained as early as the customs clearance stage.
• Distributors are also subject to a “due diligence” obligation—if they notice that the necessary documents or manufacturer’s markings are missing, they are required to suspend further sales of such goods.
• Although the implementing regulations specifying the amount of fines in Poland are still under consideration, experts estimate that fines for violations could be as high as two million zlotys.

How do you properly begin implementing the PPWR?

• Don't wait—start by conducting a thorough audit (inventory) of all the packaging your company uses—from master cartons to plastic wrap and staples.
• Determine who the supplier is for each material, what its specifications are, and whether your company acts as a manufacturer, distributor, or producer in this supply chain.
• Contact your packaging suppliers now and request that they provide certified test results and technical documentation.
• Given the complexity of the regulations and the tight deadline, a good option is to seek professional support from external consultants (such as Selium or Ekosfera) who can help you navigate the maze of paperwork, obtain data from suppliers, and prepare accurate declarations of conformity.

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