Regulation (EU) 2025/40
PPWR — what applies now and what waits until 2030
This is where the industry carries the most misinformation. Some of the requirements you hear about at seminars only start to bite in a few years — and declaring them today, with nothing behind them, lands on you.
In short
Regulation (EU) 2025/40 applies from 12 August 2026. From that date the documentation obligations and substance limits are in force. Design and recycled-content requirements come later and are no basis today for anything you write on a document.
- From 12 Aug 2026: technical documentation, EU declaration of conformity and the heavy-metals limit.
- The PFAS limit from 12 Aug 2026, but only for food-contact packaging.
- Material labelling and EPR identification — 2027–2028, depending on implementing acts.
- Recyclability class and recycled-content targets — from 2030.
What actually took effect on 12 August 2026
Two things at once: documentation obligations and hard substance limits. The first take organisational work, the second take a document from your material supplier.
The sum of four heavy metals — lead, cadmium, mercury and hexavalent chromium — must not exceed one hundred milligrams per kilogram. A board packaging manufacturer usually has no way to test this in-house and does not need to: a supplier statement for the specific material index is enough.
The PFAS limit applies from the same date, but only to food-contact packaging. An ordinary B2B transport box is not food-contact packaging, so the field is moot — and it is better left marked „not applicable” than filled in with „Yes”.
What comes later and why not to run ahead of it
Design-for-recycling criteria and the classes that follow from them take effect on 1 January 2030. Recycled-content targets concern plastics above all and also aim at 2030. Material labelling and the QR code fall across 2027–2028 and depend on implementing acts.
Running ahead of those dates on your documents looks like diligence and is a risk. Writing „recyclability class A” or „recycled content 100%” with no supplier document is a claim with no basis — and that is not a formality, it is an unfair commercial practice.
There is also a purely practical reason. The criteria will be refined by delegated acts. Documents issued today on today's idea of the classes will have to be redone anyway, only by then there will be hundreds of them.
Penalties and enforcement practice
Member states set the level of sanctions, and enforcement practice is only taking shape. The figures circulating in industry conversations differ by an order of magnitude and are a poor basis for decisions.
A more useful question is a different one: what happens when a B2B customer asks for a declaration and you do not have it. The consequence there is immediate and involves no authority — the delivery stalls and purchasing starts looking elsewhere.
So the honest order of work is: first the documents the market demands, then optimisation for future design requirements.
What to do this quarter
A minimum list for a plant that is only starting. The order matters, because the first item is the longest critical path and it is not on your side.
- Email every material supplier for a declaration of conformity or material sheet for the indexes you buy, a statement on heavy metals, and the process by which they will notify parameter changes.
- Establish for which products you are the manufacturer and for which a distributor — roles are decided per product, not per company.
- Count your packaging types: material grades times the construction classes you actually run. That is the number of declarations you owe.
- Settle who signs the documents, how numbering works, and how the five- and ten-year archive is kept.
- Strip out every field you cannot back with a document — an empty field is safer than an optimistic „Yes”.
Timeline of obligations
A working overview for a packaging manufacturer. Labelling dates depend on implementing acts and are worth confirming with a legal adviser.
| Requirement | From | Note |
|---|---|---|
| Technical documentation | 12 Aug 2026 | Stays with the manufacturer, shown to market surveillance. The basis for everything else. |
| EU declaration of conformity | 12 Aug 2026 | Issued to customers, per packaging type. Template per Annex VIII. |
| Heavy metals: sum of Pb, Cd, Hg and Cr(VI) up to 100 mg/kg | 12 Aug 2026 | Applies to every packaging. Needs a statement from the material supplier. |
| PFAS limit | 12 Aug 2026 | Food-contact packaging only. For B2B transport packaging the field does not apply. |
| Identification for extended producer responsibility | 2027 | Date depends on implementing legislation — confirm with an adviser. |
| Harmonised material labelling and QR code | 2028 | As above. Scope and format are set by implementing acts. |
| Recyclability class A–C | 1 Jan 2030 | Design-for-recycling criteria from art. 6 and Annex II. Delegated acts expected earlier. |
| Recycled-content targets | 2030 | Concern plastic packaging above all. |
State of knowledge as of August 2026. This overview is not legal advice.
Frequently asked questions
When does PPWR start to apply?+
Regulation (EU) 2025/40 applies from 12 August 2026. From that date the documentation obligations and the substance limits in article 5 are in force.
Does the recyclability class apply already?+
No. Design-for-recycling criteria and the classes that follow take effect on 1 January 2030. Delegated acts refining the criteria are expected earlier.
Does the PFAS limit apply to B2B transport packaging?+
Not if the packaging has no food contact. Filling in that field on an ordinary transport box means declaring something that does not apply.
When do material labelling and the QR code arrive?+
Labelling requirements fall across 2027–2028 and depend on implementing acts. Confirm the exact date for your packaging type with a legal adviser.
Can all this be caught up after the deadline?+
The documents cannot be produced in a week, because the longest wait is for data from material suppliers. What you can do is start with the packaging types actually going to the customers who are asking, and widen the scope in stages.
Related topics
EU declaration of conformity
What the Annex VIII template must contain, who signs it, and how many you actually need.
Technical documentation
The file that stays with you and that market surveillance asks for. Annex VII and module A.
Packaging datasheet
A commercial document PPWR does not require — and one the other two do not replace.
Let us establish what applies to you and what does not
Thirty minutes online. We check for which products you are the manufacturer, which fields you can back with a document, and which have to stay empty today.
Reference material written during a real rollout, based on Regulation (EU) 2025/40. It is not legal advice or a conformity assessment. Confirm labelling deadlines with your legal adviser.