PPWR Regulation: the new European Packaging and Packaging Waste Regulation
Whether it is an Italian or German company, the new PPWR changes the rules of packaging. Protect your business from August 12, 2026.
If your company purchases, uses, packages, imports, or exports goods, semi-finished products, or agri-food products, there is a European regulatory shift that you absolutely cannot ignore: the entry into force of the new European Packaging and Packaging Waste Regulation (PPWR — Regulation EU 2025/40).
Unlike the old directives, the PPWR is a directly applicable Regulation. From August 12, 2026, it will become the single law throughout the EU, repealing Directive 94/62/EC and thus breaking down old national fragmentations, while introducing very strict standards and heavy legal responsibilities for those placing goods on the European market. (Germany, which already monitored strictly through the LUCID register, is already adapting its control systems.)
What changes concretely compared to the past and what are the main risks?
- The Declaration of Conformity becomes mandatory: Simple generic technical data sheets will no longer be enough. Every package must be accompanied by a formal Declaration of Conformity issued by the manufacturer, based on technical documentation and laboratory tests certifying eco-design and compliance with limits on harmful substances. This declaration must be requested and checked by importers.
- The “ban” on PFAS in the food sector: From August 12, 2026, a ban (with microscopic limits) kicks in for PFAS substances (so-called “forever chemicals”) in packaging in contact with food. Many greaseproof wraps, laminated papers, or trays used in agri-food exports will have to be replaced. Importers will demand written certifications from suppliers before accepting goods.
- New obligations for “manufacturers” and e‑commerce: If you sell by applying your name or trademark, or if you sell directly to final consumers via e‑commerce, you are legally considered the “Producer.”
- Logistics and reuse quotas: For B2B shipments (pallets, crates, strapping, drums), mandatory reuse quotas are arriving. Those transporting goods between different sites or construction sites of the same company must guarantee a 100% reuse quota.
Commercial risks: If the packaging is not compliant or technical documentation is missing, the goods may be considered non-marketable, resulting in border blocks, rejected shipments, claims for damages, and heavy financial penalties.
Why do you need legal advice and a legal review of contracts?
Compliance with the PPWR is not just a technical laboratory matter, but has profound contractual and legal implications.
International supply contracts: Large companies and distributors are already updating commercial contracts by inserting unfair clauses or total indemnity clauses. They require suppliers to guarantee PPWR compliance and to bear all economic responsibility in the event of sanctions or blocks on goods. Legal advice is essential to analyze, negotiate, and secure these contracts, ensuring that responsibilities are fairly distributed and that the company is in turn covered by the guarantees of its packaging suppliers.
Mapping supply chain roles: Understanding exactly whether your company operates as a Producer, Importer, or simple Distributor under the PPWR is a delicate legal step on which the entire chain of customs and registration obligations depends.
Don’t wait until next August. The time to act, map your packaging, and review international contracts is now.
