PPWR from 12 August 2026 - what changes in working with packaging data

The PPWR entered into force on 11 February 2025 and applies in principle from 12 August 2026. This does not mean, however, that all detailed obligations and targets begin to apply on exactly the same day. Many provisions have their own deadlines, require implementing acts or depend on the type of packaging and the role of the business.

What the PPWR is

The PPWR is Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste. It replaces the earlier directive-based model and introduces directly applicable rules for packaging in the European Union.

The regulation covers the entire life cycle of packaging. It addresses, among other things, substances present in packaging, recyclability, recyclate content, packaging minimisation, reuse, labelling, technical documentation and the obligations of economic operators.

The scope is broad, so a company should not start with a single 'PPWR compliant' field. First, you need to build an accurate picture of the packaging and determine which requirements apply to its specific configuration.

12 August 2026 is the start of application, not one date for everything

In its 2026 guidelines, the European Commission confirmed that the PPWR entered into force on 11 February 2025 and applies from 12 August 2026. At the same time, the regulation contains transitional provisions and requirements with separate deadlines.

In practice, for each obligation you need to record:

• the legal basis,
• the date of application,
• the type of packaging and the entity concerned,
• any exceptions or thresholds,
• the delegated acts, implementing acts or standards needed,
• the source of the current interpretation,
• the person responsible for review.

This approach limits two errors: postponing all preparation until later and assigning every packaging item requirements that do not yet apply.

Start with a packaging map

A company should know what packaging it actually places on the market and how it is linked to products.

For each SKU, it is worth describing:

• unit packaging,
• grouped packaging,
• transport packaging,
• the components of each level,
• additional elements such as closures, labels, inserts and fillers,
• the supplier and the place where the data is obtained,
• variants depending on the market, sales channel or batch size.

Do not assume that one packaging item corresponds to one record. A bottle, cap, label, grouping film and transport carton may require separate data, while at the same time forming a configuration assigned to a specific product.

What material data to organise

The scope depends on the requirements applying to a given packaging item, but a sensible data model should allow you to record:

• the type of material of each component,
• the mass of the component and of the entire packaging level,
• the source of the value and the measurement method,
• the share of recycled material, where relevant,
• information on substances of concern and other material restrictions,
• the ability to separate individual elements,
• suitability for contact with sensitive products, where applicable,
• characteristics related to reuse or refilling,
• the date and version of the specification.

Not every value has to be available immediately. It is important that a gap is visible and distinguished from zero or a 'not applicable' answer. Every field should have a source: a supplier specification, an in-house measurement, a test report or another documented finding.

Technical documentation and declaration of conformity

The PPWR provides for technical documentation for packaging and an EU declaration of conformity. Annex VII describes the elements of the technical documentation, and Annex VIII sets out the model declaration.

The documentation should make it possible to assess the conformity of the packaging with the applicable requirements. Depending on the case, it may include:

• a description of the packaging and its intended use,
• drawings, specifications and the manufacturing process,
• a description of the solutions applied,
• a list of standards or other specifications,
• the results of calculations, tests and assessments,
• evidence concerning materials and parameters,
• documentation of the required markings and information.

The manufacturer draws up the declaration for the packaging type and keeps it together with the documentation for the periods specified in the PPWR. The regulation provides, as a general rule, for 5 years for single-use packaging and 10 years for reusable packaging after they are placed on the market.

A draft generated on the basis of unverified fields should not automatically become an approved declaration. A review of the scope, evidence and the person authorised to sign the document is needed.

Data from packaging and material suppliers

Article 16 of the PPWR obliges suppliers of packaging or packaging materials to provide the manufacturer with the information and documentation needed to demonstrate conformity. This is an important basis for organising cooperation in the supply chain.

In a request to a supplier, specify the specific component, material code, variant, plant and delivery period. Ask for:

• the material specification,
• mass and tolerances,
• composition and the required information on substances,
• data on recyclate content, where needed,
• reports, certificates or calculation methods together with their scope,
• information required for packaging in contact with sensitive products,
• the document version number,
• the obligation to inform about a change in material or process.

The file received should undergo assessment. Check whether it concerns the correct component, whether its scope covers the value needed and whether it has not been replaced by a newer version.

Minimisation and 'empty space' require design data

The PPWR develops requirements for reducing packaging to the necessary minimum. For a company, this means retaining the basis for the design decision, not only the final box dimension.

Useful information may include:

• the dimensions of the product and packaging,
• the mass of each element,
• the protective function of the component,
• transport and storage requirements,
• justification for the space needed to protect the product,
• tests or experience confirming that the reduction does not increase damage,
• differences between single-unit sales and shipping sales.

Minimisation should not lead to a loss of safety, hygiene or functionality. Reducing material therefore requires a controlled decision and an update of the relevant evidence.

Recyclability, recyclate and reuse - do not confuse the concepts

A single 'eco' field often appears in company spreadsheets. It is too general to support work with the PPWR.

Separate at least:

• design for recycling,
• recyclability at scale in accordance with the relevant timetable,
• the percentage content of plastic from recycling,
• the suitability of the packaging for reuse,
• the actual reuse or refilling system,
• the sortability and identification of the material.

Each of these properties has a different meaning, basis and method of demonstration. A marketing claim should not replace the technical source of the value.

Labelling and digital data

The PPWR provides for the development of harmonised labelling and the use of data carriers. Detailed formats and deadlines may depend on further acts.

Even now, it is worth preparing a model that separates:

• the content of the mandatory information,
• the language and market,
• the placement location,
• the graphic version,
• the data source,
• the date of approval,
• the associated component or packaging level.

A QR code or other data carrier should not be treated as a way to hide the lack of basic information. First determine what is required for a specific packaging item and in what form.

How to build a PPWR preparation process

• Inventory - link SKUs to packaging levels and their components.
• Sources - assign the manufacturer or supplier of each value.
• Gaps - flag missing masses, materials, evidence and versions.
• Requirements - assign the basis, deadline and scope to a specific packaging type.
• Assessment - check the adequacy of evidence instead of accepting the mere fact that a file was received.
• Documentation - prepare a controlled technical revision and the required declarations.
• Changes - trigger a review after a change in product, packaging, supplier or law.
• Approval - retain the person, date and basis for the decision.

Most common mistakes

• treating 12 August 2026 as the only deadline for every requirement,
• one packaging record without distinguishing levels and components,
• mass without information on the method and source,
• automatically copying data between similar SKUs,
• accepting a marketing '100% recyclable' claim without assessing its scope,
• not versioning supplier specifications,
• confusing product packaging with shipping packaging,
• preparing a declaration before checking the technical documentation.

What can be done straight away

Choose the five best-selling SKUs and set out their full packaging structure. Weigh the components, collect specifications, record the sources and mark the gaps. Then assign the person responsible for assessing the requirements and the deadlines arising from the PPWR.

GPSR / PPWR can help maintain the relationships between product, packaging, supplier, evidence and the next revision of the document. However, the system does not decide on its own whether the packaging meets all applicable requirements. Such a conclusion requires the current legal position, complete data and responsible approval.