The Aug. 12, 2026 deadline for PPWR compliance is eight weeks out. For companies placing packaging on the EU market, the stakes are real. The EU’s Packaging and Packaging Waste Regulation (PPWR) entered into force in February 2025 and represents the most significant overhaul of EU packaging law in 30 years.
In our June 3 webinar, 3R Sustainability’s Frazier Opel and Cesar Carreno walked through what the regulation requires, how to define your company’s role, and how to approach the deadline strategically.
Key dates and thresholds at a glance:
- Aug. 12, 2026: PPWR broadly applies; Declaration of Conformity (DoC) required for all packaging
- January 2030: Packaging below recyclability grade C (~75-80%) restricted from EU market
- January 2038: Only grade B (80%+) or higher permitted on the EU market
- DoC validity: five years for single-use packaging, 10 years for reusable formats
Watch the webinar on PPWR compliance
Frazier Opel and Cesar Carreno cover what the regulation requires, how to define your company’s role, and how to approach the deadline strategically.
What PPWR covers
- PPWR replaces the EU’s 1994 Packaging Directive and applies to all packaging and packaging waste regardless of material or origin. Its three headline goals:
- Make all EU packaging recyclable in an economically viable way by 2030
- Increase the use of recycled plastics in packaging
- Reduce dependence on virgin materials, with the sector on a path to climate neutrality by 2050
New restrictions include limits on certain single-use plastics, a requirement for take-away businesses to accept customer-owned containers, and PFAS thresholds for food contact packaging.
How to define your PPWR role
PPWR compliance obligations depend on a company’s position in the packaging supply chain. The Manufacturer carries the heaviest burden. PPWR defines the Manufacturer by whose name or brand appears on the packaging, regardless of who physically produces it. That company must prepare the DoC.
Start with these six questions to define your role:
- Do we manufacture packaging or place packaged products under our name or brand?
- Do we place packaged products on the EU market?
- Do we import products into the EU?
- Do we distribute or sell packaged products?
- Do we manage reusable packaging systems?
- Do we influence or design the packaging, even when a third party produces it?
Many companies hold more than one role simultaneously. A retailer importing private-label products may be both an Importer and a Producer. Securing your role definition requires a supply chain mapping exercise, a packaging flow analysis, and a legal entity review by country to determine who holds compliance obligations in each market.
The Declaration of Conformity: what it requires
The DoC is a formal declaration that packaging meets PPWR’s requirements. It is supported by two annexes:
- Annex VII: the technical documentation package, including LCA outputs, recyclability assessments, and lab results for PFAS and heavy metals
- Annex VIII: the signed declaration itself, in legally required format with the minimum required information set
The DoC is held internally and made available on request from market surveillance authorities, customers, and supply chain partners. Importers and Distributors must verify that a DoC exists and is current; they do not produce one independently.
What needs to be ready by Aug. 12, 2026
- Module A conformity assessment for all packaging
- Technical documentation file (Annex VII)
- Signed Declaration of Conformity (Annex VIII)
- Compliance with heavy metals and PFAS substance limits
- Packaging weight and volume minimization documentation
- Packaging traceability systems
- Importers and Distributors: records verifying the DoC exists and is current
Start with your suppliers
PPWR reaches across your whole supply chain. Manufacturers need material data, recyclability documentation, and PFAS information from suppliers, who may need to engage their own suppliers. Proactive dissemination, capacity building, and updated procurement policies are the difference between collecting data in time and scrambling at the deadline.
A practical approach: organize a single, well-documented capacity-building effort with materials that can be reshared and reused across future compliance cycles.
One effort, multiple returns
PPWR preparation can feed the rest of your compliance and reporting program at once. The bill of materials required for the DoC is the same data foundation needed for:
- Lifecycle assessments (LCAs) for package minimization documentation and Scope 3 Category 12 (end-of-life of sold products)
- Scope 3 Category 1 (purchased goods and services) in GHG inventories
- EcoVadis, CDP, and B Corp disclosures at product level
- EU Deforestation Regulation (EUDR) traceability for carton-based packaging
Grouping products with the same function and materials under a single DoC reduces the documentation burden further. The goal is one organized data collection effort that covers multiple compliance fronts.
Where to start
With Aug. 12 eight weeks out, the highest-priority steps are:
- Confirm your PPWR role(s) through supply chain mapping and legal entity review
- Complete a packaging inventory across primary, secondary, and tertiary formats
- Engage suppliers now on data and documentation requirements
- Begin recyclability assessments and identify prohibited materials (PFAS, dark pigments, multi-material laminates)
- Begin drafting your Annex VII technical file and Annex VIII DoC
For organizations further along in the process, finalizing Annex VII documentation and completing the DoC should be the focus. 3R Sustainability’s product and packaging team supports organizations through each of these steps, from role definition and supply chain mapping to LCAs, DoC preparation, and EcoVadis and CDP readiness.
Ready to talk through your PPWR compliance obligations? Contact the 3R team or watch the full webinar recording.
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