and do you have your packaging data under control?

 

How to determine what role a company has under the PPWR and what obligations apply to it in relation to packaging 

What packaging data companies will need to demonstrate compliance with the new requirements 

Why PFAS, recyclability and logistics packaging need to be addressed now, as well as the changes that will come fully into effect in 2030

Regulation (EU) 2025/40 on packaging and packaging waste has been generally directly applicable since 12 August 2026. It is now crucial for companies not to wait, but to determine their own roles, map packaging flows and verify whether they have the data and documentation needed to demonstrate future compliance.

Packaging is moving from a purely operational and waste-related topic into the area of product compliance. The PPWR does not only set rules for what happens to packaging after use. It also affects its design, composition, recyclability, the amount of material used, labelling, reuse and the evidence that must be available for packaging.

This is particularly important for manufacturing and distribution companies. They often do not manufacture packaging themselves, but use it for their products, import packaged goods, work with transport packaging or sell into several EU countries. This is where it becomes clear that the biggest weakness may not be a lack of knowledge of the legislation itself, but rather an unclear role in the supply chain and insufficient data readiness.

Why it is not enough to say “we just buy packaging”

The PPWR distinguishes several roles, each with a different scope of obligations. The manufacturer of packaging or a packaged product, importer, distributor, producer for the purposes of extended producer responsibility (EPR) and final distributor are assessed differently. In addition, one company may have different roles for different packaging flows.

A typical example is a company that buys packaging from a European supplier, uses it for its own product, sells part of its production in the Czech Republic and part directly to customers in other Member States.

It therefore makes sense to start with three questions: what exactly is the packaging unit, who has which role in relation to it, and where the packaging or packaged product is first made available on the market. Without this map, it is impossible to reliably determine the specific obligations.

What companies need to address now and what comes next

The PPWR entered into force in February 2025 and, from 12 August 2026, most of its provisions became directly applicable. There is therefore no need to wait for Czech transposition before the main obligations arise. National legislation will continue to be important, for example, in relation to sanctions, registers, EPR and enforcement, but the basic regulatory framework follows directly from the European Regulation.
 

Milestone	What to take away from it
12 Aug 2026	General applicability of the PPWR. PFAS restrictions apply to food-contact packaging; depending on the role, conformity assessment, technical documentation and the EU declaration of conformity also become relevant.
2027–2028	Further operational and information requirements are introduced. In some areas, specific deadlines will depend on implementing or delegated acts adopted by the European Commission.
2030	The main wave of changes: design for recycling and recyclability performance classes, minimum recycled plastic content, packaging minimisation, selected reuse targets, restrictions on certain packaging formats and requirements relating to empty space.

Data will be a practical prerequisite for compliance

In many companies today, data is scattered across purchasing, production, warehouse operations, quality, EPR reporting and suppliers. Some data exists only in technical data sheets, other information is stored in ERP systems, and some is not systematically collected at all.

For basic data readiness, companies should know at least the type and level of packaging, the material composition and weight of individual components, the intended use, information on food contact, recycled content, reuse or compostability status, the supplier, production plant, country of delivery and the link to technical documentation and the declaration of conformity.

This is not a one-off exercise of “collecting everything into a spreadsheet”. The data must remain maintainable when there is a change of supplier, material, packaging design or distribution flow. It is therefore important to appoint an owner of the agenda and link PPWR requirements to existing change management processes, purchasing specifications and master data.

PFAS, recyclability and logistics packaging: three areas worth addressing now

1. Food-contact packaging and PFAS

From 12 August 2026, specific PFAS limits apply to packaging intended to come into contact with food. If a company manufactures, imports or uses such packaging in its portfolio, it should have a clear understanding of the material composition and the supporting documentation it can obtain from the supplier.

2. Recyclability and future redesign

Recyclability is not an issue that only becomes relevant in 2030. From 2030, however, the method of assessment will become significantly more stringent and packaging will be assessed according to specific performance classes. The practical question is therefore which packaging has a long life cycle, requires customer approval or a change in technology, and which packaging needs to be addressed well in advance.

3. Transport and grouped packaging

The PPWR does not apply only to packaging seen by the end consumer. Transport and grouped packaging, pallets, crates, boxes and other logistics formats can also be significantly affected. For selected flows, reuse targets and requirements to reduce empty space will apply from 2030. There are numerous exemptions, so the specific flow, material and method of use must always be assessed.

Digital information: the same theme across European regulation

The PPWR introduces harmonised labelling and digitally accessible information, confirming a broader trend: regulatory compliance increasingly relies on structured product data, its traceability and the ability to share it across the supply chain.

Battery regulation illustrates this trend very clearly through the digital battery passport for selected categories of batteries. For companies, this is also a useful lesson outside the battery sector: those that do not have clear product and material data today will find future requirements significantly more complex and expensive to implement.

How to get started: launch a pilot instead of a large-scale project

For most companies, rebuilding the entire packaging portfolio across the board is not the right first step. A quick diagnostic and a pilot based on a representative sample of packaging or one product line make more sense. The aim is to identify where the real gaps are and what needs to be addressed as a priority.

At first glance, 2030 may seem far away. However, in packaging, three years is not a long time if a change requires redesign, testing, material validation, changes to supplier contracts, modification of a packaging line or a new logistics solution. It is therefore worth separating the obligations that the company needs to address today from decisions where investment preparations should begin well in advance.