PPWR deadlines: the Regulation (EU) 2025/40 dates and what they change for you

Yes. Regulation (EU) 2025/40 appeared in the Official Journal on 22 January 2025. It entered into force on 11 February 2025 and applies from 12 August 2026 (Art 71). It repeals Directive 94/62/EC from that date (Art 70(1)), except for a few transitional provisions — among them the Directive's weight and volume minimisation essential requirement, which keeps applying until 31 December 2029 (Art 70(1)(b)). Three later dates follow. The recyclability grade floor applies from 1 January 2030 or 24 months after the Art 6(4) delegated acts, whichever is later (Art 6(3)). Recycled-content minima apply from 1 January 2030 or three years after the Art 7(8) implementing act, whichever is later (Art 7(1)). Re-use targets apply from 1 January 2030 (Art 29). Source: Regulation (EU) 2025/40.

From 12 August 2026, packaging you place on the EU market needs five things. First, a technical file. Second, an EU declaration of conformity. Third, a type, batch or serial number that identifies the packaging (Art 15(5)). If the size or nature of the packaging does not allow it, that information goes in a document accompanying the packaged product (Art 15(5)). Fourth, the manufacturer's name and postal address on the packaging or in a QR code or other data carrier, with an Art 12 data carrier or an accompanying document only where that is not possible (Art 15(6)). Fifth, producer registration in every market where you count as a producer under Art 3(1)(15). That is the manufacturer's list. It is yours if you sell under your own name or brand, or modify the packaging in a way that could affect its compliance (Art 21). An importer instead checks that the manufacturer did the first four and keeps a copy of the declaration (Art 18(2)(a), (d), 18(7)). It also puts its own name and postal address on the packaging, or in a data carrier or an accompanying document where that is not possible (Art 18(3)). A distributor holds neither (Art 19(2)). Tukes, the Finnish market surveillance authority, puts it this way: before placing packaging on the market the manufacturer must carry out the conformity assessment and draw up the technical documents and the EU declaration of conformity. You cannot produce any of that afterwards for stock already on shelves. Sources: Regulation (EU) 2025/40, Tukes.

Article 5(4) of Regulation (EU) 2025/40 limits lead, cadmium, mercury and hexavalent chromium to 100 mg/kg summed. The sum applies to the packaging or the packaging component, whatever the pack contains. For food-contact packaging, Article 5(5) adds a stepwise PFAS (per- and polyfluorinated alkyl substances, often called forever chemicals) screen from 12 August 2026. The limits are 25 µg/kg for a single targeted PFAS, 250 µg/kg for the sum of targeted PFAS, and 50 mg/kg for PFAS including polymeric. Total fluorine above 50 mg/kg is a separate trigger. That triggers a duty for the manufacturer, importer or downstream user as defined in REACH (Regulation (EC) No 1907/2006). On request, they must give the packaging manufacturer or importer proof of the quantity of fluorine. That proof states how much of the fluorine is PFAS and how much is not, so they can draw up the Annex VII technical documentation. The three PFAS limits bite at the limit value itself. The 100 mg/kg heavy-metals sum and the 50 mg/kg fluorine trigger bite only above the value. Source: Regulation (EU) 2025/40.

Article 6(3) of Regulation (EU) 2025/40 expresses recyclability in the performance grades A, B or C. Table 3 of Annex II describes them. Article 6(2) has two conditions, and they start on different dates. Point (a) is design for recycling. It applies from 1 January 2030, or 24 months after the delegated acts under Article 6(4) enter into force, whichever is later. Point (b) is that the packaging is collected separately, sorted and recycled at scale. It applies from 1 January 2035. For the "recycled at scale" part alone, the date is 1 January 2035 or five years after the Article 6(5) implementing acts enter into force, whichever is later. From the 2030 date packaging may not be placed on the market unless it is graded A, B or C. From 1 January 2038 it needs grade A or B. Source: Regulation (EU) 2025/40.

Yes, for packaging placed on the EU market from 12 August 2026. Tukes states that the manufacturer must carry out the conformity assessment and draw up the technical documents and the EU declaration of conformity. That happens before placing the packaging on the market. The declaration follows the model in Annex VIII and rests on the Annex VII technical documentation. The manufacturer draws it up in, or translates it into, the language or languages required by each Member State where the packaging is placed or made available on the market (Art 39(2)). If you import, you do not draw it up. You make sure the manufacturer did, and keep a copy for five years, ten for reusable packaging (Art 18(2)(a), 18(7)). If you only resell, you check the producer's register entry, the labelling and the identification and name-and-address markings on the pack (Art 19(2)). Selling under your own brand, or modifying the packaging in a way that could affect its compliance, makes you the manufacturer (Art 21). Sources: Tukes, Regulation (EU) 2025/40.

The declaration follows the model in Annex VIII, which has eight numbered points and a signature block. The declaration carries its own number in its title. 1: the unique identification of the packaging. 2: the name and address of the manufacturer and, where applicable, its authorised representative. 3: the statement that the declaration is issued under the sole responsibility of the manufacturer. 4: the object of the declaration, an identification that allows the packaging to be traced. 5: the statement that the object is in conformity with the relevant Union harmonisation legislation, with a reference to the other Union acts applied. 6: the harmonised standards, common specifications or other technical specifications used (Arts 36-37). If none exist yet, say so. 7: the notified body, where applicable. It is not applicable under the Annex VII Module A procedure. 8: additional information. Then "signed for and on behalf of", place and date, name, function and signature. One declaration per packaging type, kept for 5 years or 10 for reusable packaging (Annex VII point 4, Art 15(3)). Keep it up to date, and draw it up in, or translate it into, the language or languages required by each Member State where the packaging is placed or made available on the market (Art 39(2)). It rests on the Annex VII technical documentation (Annex VII point 2(a)-(f)). That file describes the packaging and its use, and gives the design and material details. It also holds the assessments made under Articles 6, 10 and 11, the standards used and the test reports. The manufacturer draws it up, including an own-brand importer or distributor, or one that modifies the packaging in a way that could affect its compliance, under Art 21. An importer keeps a copy (Art 18(7)) and a distributor needs none (Art 19(2)). The toolkit generates this document from the dossier. The declaration in it is yours to check and sign. Source: Regulation (EU) 2025/40, Annexes VII and VIII.

Marking with the Commission Decision 97/129/EC code is voluntary at EU level, so national law decides. The market dataset behind this site records on-pack marking as mandatory in Italy, Bulgaria and Malta. In Latvia marking is optional, but a marked pack must carry both the material-type code and the recyclability symbol. In Lithuania it has been voluntary since 2021. Elsewhere in the EU-27 it is voluntary. In Finland the mark is voluntary (VNA 1029/2021 § 6). That ends on 12 August 2028: Article 70(2) of Regulation (EU) 2025/40 repeals Decision 97/129/EC with effect from that date. Recital 74 says the implementing act behind the harmonised label under Art 12 is to take over its content. The codes themselves are on the material codes page. Sources: Decision 97/129/EC, VNA 1029/2021.

They are two separate appointments under Regulation (EU) 2025/40 that share a name. The Art 17 authorised representative sits in the conformity chain, next to the manufacturer, importer and distributor obligations. You appoint the Art 45(3) authorised representative for extended producer responsibility in each Member State where you supply packaging direct to end users without being established there. It carries that market's producer-responsibility duties. Appointing one does not discharge the other. You make the Art 45(3) appointment per Member State. Status on 4 September 2026. The Commission's Environmental Omnibus proposal (COM(2025) 982 of 10 December 2025) would suspend the whole of Art 45(3) until 1 January 2035, including the mandatory appointment for producers established in the EU. It is a proposal, not law. The Council did not advance that part in June 2026. The European Parliament's ENVI (Environment, Climate and Food Safety) committee is pursuing a narrower exemption. It would reach companies with up to 49 staff and EUR 10 million turnover. A first reading is not expected before October 2026. For producers established outside the EU it would let each Member State either require an EPR authorised representative or ensure traceability and enforcement by other means. Until anything is adopted, Art 45(3) applies as written. This status is compiled from secondary reporting and is re-checked against EUR-Lex before each republish. Sources: Regulation (EU) 2025/40, COM(2025) 982.