Mandatory Enforcement in Less Than 2 Months! Is Your Packaging Ready to Pass the "PPWR Checkpoint"?

If your company exports goods to the EU – whether electronics, daily necessities, food products, or cross-border e-commerce parcels – please pay close attention to this:

On 12 August 2026, the EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) will become fully mandatory.

This is not a "recommendatory" guidance document. It is a regulation with direct legal force, uniformly applicable to all EU Member States. From that date onwards, packaging that fails to meet requirements, covering:

• excessive heavy metals,
• non-compliant PFAS levels,
• incomplete EPR registration, or
• missing mandatory labels.

may face product delisting, customs detention, heavy fines, or even exclusion from the EU market.

Earlier on 5 June, 2026, the European Commission published the Guidance Document on the Packaging and Packaging Waste Regulation (PPWR), providing interpretation for the new EU packaging regulation that will generally apply from 12 August 2026.

The compliance window for exporters is now extremely tight. CIRS has therefore summarised the core provisions of this regulation to help you quickly assess risks and take early action.

I. What is PPWR, and why is it "different" this time?

PPWR stands for Packaging and Packaging Waste Regulation, designated as EU (EU) 2025/40, published in the Official Journal of the EU on 22 January 2025. It formally replaces the 30‑year‑old Directive 94/62/EC (PPWD).

A critical change is: Upgrade from a "Directive" to a "Regulation".

• Directive: Requires transposition into national law by each Member State, resulting in divergent timelines and interpretations across countries, creating "fragmented" compliance requirements.
• Regulation: Takes direct effect in all Member States, with uniform standards and unified enforcement – no room for "each country doing its own thing".

This means that the old strategy of "wait and see how each Member State implements it" no longer works under PPWR. The regulation provides a single unified benchmark that applies equally to all packaging placed on the EU market.

Who is affected? PPWR has a very broad scope, covering virtually the entire packaging supply chain:

• Manufacturers (of packaging and of packaged products);
• Importers and distributors;
• E‑commerce platforms and online sellers; and
• Non‑EU sellers: must appoint an authorised representative (EU‑based) – otherwise they cannot legally sell in the EU.

In short – if you sell packaged products into the EU, you fall within the scope of PPWR.

II. Compliance timeline: five stages – your "action checklist"

The implementation of PPWR is phased across five stages. Companies should benchmark their products against each:

Stage 1: Transition period (11 Feb 2025 – 11 Aug 2026)

The critical window for compliance preparation. Key actions include: comprehensive packaging self‑audit (materials, structure, hazardous substance screening), basic material labelling, identifying material substitutes, initiating EPR registration, and reserving label space.

Stage 2: Full implementation phase (12 Aug 2026 – 11 Feb 2028) – [Current priority]

12 August 2026 is the effective date for the first set of mandatory requirements:

• Hazardous substance compliance (heavy metals, PFAS)
• Complete conformity assessment, draft EU Declaration of Conformity (DoC) and technical documentation
• EPR (Extended Producer Responsibility) system registration
• Restrictions on single‑use plastic packaging

Stage 3: Specification refinement period (12 Feb 2028 – 31 Dec 2029)

Focus on compostable packaging, harmonised labelling systems, DRS (Deposit Return System) alignment, and packaging minimisation.

Stage 4: Quantitative target period (1 Jan 2030 – 10 Jan 2038)

Introduction of binding quantitative targets: recycled content, recyclability grading, and packaging reduction ratios – all must be met.

Stage 5: Ultimate compliance phase (from 11 Jan 2038 onwards)

Higher‑standard long‑term objectives to drive the full green transformation of the packaging system.

III. The top priorities – core requirements effective 12 August 2026

The following limit values are the most urgent items for self‑assessment. CIRS has broken them down for you:

1. Total heavy metal content (applicable to ALL packaging)

Sum of lead (Pb), cadmium (Cd), mercury (Hg) and hexavalent chromium (Cr(VI)) ≤ 100 mg/kg (0.01%)

Effective date: 12 August 2026

2. PFAS restrictions (applicable to FOOD CONTACT packaging)

• Individual PFAS (non‑polymeric): ≤ 25 ppb
• Sum of individual PFAS (non‑polymeric): ≤ 250 ppb
• Total fluorine for polymeric PFAS: ≤ 50 ppm
• Total fluorine (total F): ≤ 50 mg/kg (if exceeded, proof of fluorine source must be provided upon request)

Effective date: 12 August 2026

Companies producing food‑contact packaging (e.g. food‑grade plastic containers, paper cups, food boxes, resealable bags) should pay particular attention. PFAS – known as "forever chemicals" – are subject to extremely stringent EU limits. Conventional materials may not readily comply, so early testing is critical.

3. Conformity assessment + Declaration of Conformity (DoC) + Technical documentation

Effective date: 12 August 2026

Companies must:

• Complete third‑party conformity assessment (testing)
• Prepare and sign an EU Declaration of Conformity (DoC)
• Maintain complete technical documentation for inspection (packaging design descriptions, drawings, material lists, test reports, etc.)

4. EPR registration (Extended Producer Responsibility)

Effective date: 12 August 2026 or later; EPR‑related labelling from 12 February 2027

Non‑EU companies must complete EPR registration in their target Member States (e.g. Germany's LUCID, France's ADEME, Italy's CONAI, etc.), and fulfil declaration and fee payment obligations through an EU‑based authorised representative.

5. Key requirements that will take effect in subsequent phases (plan ahead now)

Special note: Although some requirements do not take effect until 2028–2030, the lead times for material substitution, recyclability redesign, and recycled material supply chain development are considerable. Waiting until the regulation is in force to adjust is often too late. Integrating these requirements into product planning now is the most cost‑effective path to compliance.

IV. What CIRS can do for you

CIRS owns a professional third‑party testing institution, thus has built a one‑stop PPWR compliance service matrix to help companies achieve efficient, cost‑effective compliance:

1. Core testing services

2. Declaration of Conformity (DoC) services

• Compliance review: review of product technical documentation, supporting DoC preparation
• DoC drafting: preparation of formal Declaration of Conformity documents

3. EPR registration services

Fee structure based on target Member State – please contact us for details

4. Technical documentation and declaration services

• Technical dossier preparation: compilation of packaging design descriptions
• Reusability declaration: drafting of packaging reusability declaration documents

5. Our advantages:

End‑to‑end service coverage from testing, declaration, registration to technical documentation; in‑depth knowledge of EU regulatory requirements; reports are accepted as technical evidence for DoC – helping you face regulatory scrutiny with confidence.

V. Act now – compliance leaves no room for "wait and see"

With less than two months until the first PPWR mandatory deadlines (12 August 2026), now is the time to act – not to hesitate.

• Review your product packaging inventory
• Initiate testing for high‑risk items (heavy metals, PFAS)
• Simultaneously advance EPR registration and DoC preparation
• Plan ahead for material substitution and recyclability upgrades

CIRS is ready to be your compliance partner on the road to the EU market. For PPWR compliance assessments, testing quotations, or EPR registration consultations, please feel free to contact us for a one‑on‑one solution.

If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.