PPWR Since 12 August 2026: What Applies Now and What Comes Next

What has applied since 12 August 2026?

The Regulation itself, and three blocks of obligations that matter for exports. Regulation (EU) 2025/40, which entered into force on 11 February 2025, has applied since 12 August 2026 to all packaging placed on the EU market, whether made there or imported. For a product packed in Morocco, the moment that counts is its release for free circulation in the EU.

What already applies, according to the Commission’s guidance document C(2026) 3702:

• PFAS limits for food-contact packaging (Article 5): 25 ppb for any PFAS measured by targeted analysis, 250 ppb for the sum of PFAS measured by targeted analysis, 50 ppm for PFAS including polymeric PFAS. No transitional period for the exhaustion of stocks, no exception for recycled materials.
• General recyclability obligation (Article 6(1)): the Commission considers it applicable from 12 August 2026, as the provision sets no specific deadline of its own. Until the harmonised criteria apply, manufacturers follow the requirements of the former Directive and its standards, such as EN 13430:2004.
• Criteria for reusable packaging (Article 11): they apply to packaging placed on the market from 11 February 2025, but the competent authorities can only check compliance after 12 August 2026. Reusable packaging placed on the market before 11 February 2025 does not have to be brought into conformity (Article 15(9)).

What does not apply yet: the harmonised sorting label, minimisation under Article 10, the design-for-recycling criteria, the empty space ratio, the Annex V bans and the reuse targets. The minimisation requirements of the former Directive, with EN 13428:2004, remain in effect until the end of 2029 (Article 70).

The full table of obligations and roles is on our page on the PPWR for non-EU exporters.

What has the Commission clarified since the date of application?

It has published its interpretation and announced its acts. The guidance document C(2026) 3702, dated 5 June 2026, answers some thirty questions, from the definition of the manufacturer to deposit and return systems for bottles. An FAQ followed in August 2026. Both may be updated.

Five points in that document matter directly to a Moroccan exporter:

1. One manufacturer per packaging item, normally the brand owner or the filler; it draws up the EU declaration of conformity, based on information from its suppliers.
2. A branch is not enough to be an importer: an entity established in the EU is required, with a registered address in a Member State.
3. A stepwise PFAS testing approach, as there is no harmonised method: total fluorine first, then the nature of the fluorine, then total oxidisable precursor (TOP) analysis.
4. Reuse of transport packaging only applies within the EU, from the first warehouse for imported goods.
5. The sorting label was to be specified by an implementing act by 12 August 2026.

On that last point, the Commission’s implementation page still stated on 6 November 2026 that the implementing act on labelling for waste sorting was in preparation, together with the other labels (reusable packaging, recycled or bio-based content). The Commission is also working on the package of measures on recycled content in plastic packaging: the method for calculating and verifying it, sustainability criteria for recycling processes, and equivalence rules for plastic collected or recycled in a third country. Two acts, on the other hand, have been adopted: a delegated act exempting users of pallet wrappings and straps from the 100% reuse targets for transport packaging (February 2026), and a delegated decision on crystal glass packaging (August 2026).

Which deadlines fall in 2027 and 2028?

Mostly Commission deadlines, which will set the content of your 2030 obligations. Only one touches your packaging directly in 2028: labelling.

For labelling, the calculation rule matters as much as the date: the label applies from 12 August 2028 or 24 months after the entry into force of its implementing act, whichever is the latest. Transport packaging, except e-commerce packaging, and packaging subject to a deposit and return system are excluded from the sorting label. Information linked to extended producer responsibility may only be provided in digital form.

And after 2028?

1 January 2030 is the busiest date, followed by 2035 and 2040.

• 12 February 2029, or 30 months after the implementing act: end of national reuse labels alongside the EU label (Article 12(2)).
• End of 2029: end of the former Directive’s minimisation requirements; EN 13428:2004 then serves only as guidance until it is updated.
• 1 January 2030: minimisation of weight and volume (Article 10); maximum empty space ratio of 50%, or three years after the implementing act (Article 24); design-for-recycling criteria, or 24 months after the delegated acts (Article 6); ban on the formats and uses in Annex V (Article 25); at least 40% reusable transport packaging for the formats covered, within the EU (Article 29).
• 1 January 2035, or five years after the implementing acts on the method: recyclability “at scale” (Article 6).
• 1 January 2040: users of transport packaging endeavour to reach 70% reusable packaging (Article 29).

Recycled content in plastic packaging (Article 7) follows the same calendar. From 1 January 2030, or three years after the entry into force of the implementing act on the calculation method if that is later, every plastic part must contain a minimum share of post-consumer recycled plastic: 30% for contact-sensitive packaging with PET as the major component, 10% for contact-sensitive packaging in other plastics, 30% for single-use plastic beverage bottles and 35% for other plastic packaging. From 1 January 2040, these rates rise to 50%, 25%, 65% and 65%. They are calculated as an average per manufacturing plant and year; a plastic part weighing less than 5% of the packaging unit is not covered.

What should you do in the first half of 2027?

Consolidate what already applies, and prepare the long projects without waiting for the acts. An artwork overhaul or a change of material takes several months of development, testing and customer approval.

• Check that each food-contact packaging item shipped to the EU has PFAS evidence, at least a total fluorine test.
  
• Confirm in writing with each customer who the manufacturer of each packaging item is.
  
• Update the information sheets sent to customers for their EU declaration of conformity.
  
• List the artwork to redo for harmonised labelling and the abbreviations to remove.
  
• Identify the multilayer structures and material combinations that might fail future recyclability criteria.
  
• Identify grouped and transport packaging whose empty space looks high.
  
• Appoint someone to follow the Commission’s implementation page.
  

The detailed method is in our PPWR compliance checklist for exporters, and the full framework in our PPWR guide for non-EU exporters.