Update: 27 July — What actually changes in two weeks

Applies from 12 August 2026 · Arts. 5–12, 44, 45

The Packaging and Packaging Waste Regulation was published in the Official Journal on 22 January 2025 and entered into force on 11 February 2025. The 18-month transition ends on 12 August 2026, at which point most of it becomes binding across the EU.

Two things make this different from the directive it replaces. First, it is a regulation, so there is no national transposition and no waiting for local law — the same text applies from Lisbon to Helsinki. Second, it introduces conformity assessment and documentation duties that simply did not exist under the old packaging regime. This is net new work, not a relabelling of what you already do.

From 12 August, packaging placed on the EU market must meet the following, and you must be able to prove it:

• A technical file and an EU Declaration of Conformity for each packaging type. The manufacturer draws these up. EU importers must obtain and hold a copy of the DoC and make the technical documentation available to market surveillance authorities on request.
• Substances of concern minimised in the packaging's design and composition.
• Heavy metals capped at 100 mg/kg combined for lead, cadmium, mercury and hexavalent chromium.
• PFAS restricted in food-contact packaging — 25 ppb for any individual PFAS by targeted analysis, and 250 ppb for the sum of targeted PFAS. These thresholds bite well before ECHA's wider PFAS restriction is expected to land.
• Identification marking on or accompanying the packaging: the manufacturer's or importer's name, trademark and contact details, plus a type, batch or serial identifier for the packaging itself.

Packaging that does not meet these requirements cannot lawfully be placed on the EU market after 12 August. Later phases — recyclability performance grades, minimum recycled content, reuse targets and packaging minimisation limits — arrive between 2030 and 2040, but they are not this year's problem. The documentation is.

Update: 27 July — Article 44: there is no single EU registration

Applies from 12 August 2026 · Art. 44

Article 44 requires a producer to register in the national packaging register of every member state where it first makes packaging or packaged products available. There is no EU-wide licence. A Spanish registration covers Spain. It does nothing for Germany, France or Italy.

Most national registers operate on a zero-tonnage threshold: one unit sold triggers registration. The regulation offers a lighter annual reporting dataset for producers placing under 10 tonnes on a given national market, but that is a reduced data burden, not an exemption — you are still in the register. Micro-enterprises get relief from some PPWR obligations, including technical documentation in certain supply arrangements, but there is no micro-enterprise exemption from EPR.

Enforcement is not left to inspectors alone. Online marketplaces are required to verify that a trader is registered in the member state the customer is in before listing — the same gatekeeping model the Digital Services Act already applies to seller information. In practice this means Amazon, Zalando and similar platforms become the enforcement layer, at scale and automatically. Penalties are set nationally and vary sharply, from immediate sales suspension in some member states to substantial fines in others.

Update: 27 July — Article 45: a representative in every country you sell into

Applies from 12 August 2026 · Art. 45(3)

This is the provision most likely to catch non-EU sellers cold. Article 45(3) requires a producer to appoint, by written mandate, an authorised representative for extended producer responsibility in each member state where it makes packaging or packaged products available for the first time, other than the member state in which it is established.

Read that from outside the EU and the arithmetic is unforgiving. A company in the UK, US, China or Turkey is established in no member state. If it sells into eight, it needs an EPR authorised representative established in each of those eight — each with a written mandate, each registered locally, each handling data reporting and eco-contributions to a national producer responsibility organisation.

PPWR uses two similar-sounding roles, and conflating them is the most common mistake we see:

Role	Established where	Does what
Authorised representative	Anywhere in the Union	Product compliance. Holds the DoC and technical documentation, responds to market surveillance authorities, cooperates on corrective action and recalls.
Authorised representative for EPR	In that specific member state	Extended producer responsibility. Registers you in the national packaging register, reports volumes placed on the market, pays the eco-contribution.

One appointment does not cover both jobs, and the EPR representative cannot be a mailbox in another country. Germany is a useful illustration: the EPR representative takes over LUCID registration with the ZSVR and reports the volumes. The national framework there is also mid-change — the Verpackungsgesetz is being replaced by the Verpackungsrecht-Durchführungsgesetz, with the cabinet draft adopted in February 2026 and parliamentary passage still to complete.

Who is what under PPWR

Reference · Art. 3(1)

The obligations follow the role, and one company frequently holds several at once. The definitions do not always match the terms used in existing national packaging law, which is a recurring source of confusion — the German text in particular uses terms that appear inverted against everyday usage.

You are the…	If…
Manufacturer	Packaging is designed or made under your name or trademark, wherever it is physically produced.
Importer	You are established in the EU and place packaging from a third country on the EU market.
Producer	You make packaging or packaged products available on a member state's market for the first time — including selling directly to end users in that state from outside it.
Distributor	You supply packaging onward in the chain without being manufacturer or importer.

The producer definition is the one that reaches across borders. Selling directly to consumers in a member state makes you the producer in that member state, which is what pulls Article 44 registration and Article 45 representation into play.

What to do before 12 August

Action list

1. Catalogue every packaging format you place on the EU market — primary, secondary and transport, including e-commerce shipping materials.
2. Establish your role per format and per country. Where an EU-established importer already takes the producer role in a given member state, your obligations there may sit with them. Where you sell direct, they do not.
3. Get substance and material data from suppliers now. You cannot draw up a Declaration of Conformity without it, and upstream response times are the binding constraint at this point.
4. Draw up technical files and DoCs for each packaging type, and make sure EU importers in your chain hold copies.
5. Check your artwork. Manufacturer or importer identification and a packaging identifier must be on or with the packaging.
6. List every member state you sell into and confirm registration status in each national register.
7. Appoint EPR authorised representatives under written mandate in each of those states, and join the relevant producer responsibility organisation.
8. Check your marketplace seller accounts. Platforms will be verifying registration numbers per country; a gap shows up as a delisting, not a warning letter.