In force since 12 August 2026

Your product gets a passport. Your packaging gets the PPWR. Plan the data once.

Regulation (EU) 2025/40 — the Packaging and Packaging Waste Regulation — has applied since 12 August 2026, with no grace period. A good deal of the commentary about it describes the QR code and the sorting label, and those are real but they are 2028. What actually becomes enforceable in August 2026 is less visible and lands on more companies: registration in every market you sell into, a Declaration of Conformity for each packaging type, substance limits, and — the provision most often missed — an authorised representative in every member state where you are not established, including for companies already inside the EU.

Last updated: 16 August 2026

In one line: the parts of PPWR that bite on 12 August 2026 are registration, conformity and substance limits — not the label; and Article 45 catches EU companies selling cross-border, not just importers from outside the EU.

What is enforceable now

These have applied since 12 August 2026. There is no transition period, and they attach to whoever places the packaging or the packaged product on the market for the first time in a member state.

EPR registration in every market. Register in each member state where you make packaging available for the first time, and report quantities by material. Fees are volume- and material-based, and eco-modulation is now mandatory — packaging that is harder to recycle costs more.
An authorised representative for EPR in each member state where you are not established (Article 45). This is the provision most companies miss, because it is usually described as a rule for non-EU sellers. It is not: it catches an EU company selling cross-border too — sell into five member states from one, and you need a representative appointed in each of the other four.
An EU Declaration of Conformity for every packaging type, with a technical file retained for five to ten years.
Substance limits. PFAS restricted in food-contact packaging, and lead, cadmium, mercury and hexavalent chromium limited to 100 mg/kg combined.
Operator identification on the packaging — name or trademark, and a postal address.

Note what is not on this list: the QR code, the material-composition marking and the sorting instructions. Those are the visible part of PPWR and they are the part that is still two years away.

What waits until 2028 — and why the date is not fixed yet

The harmonised labelling under Article 12 and Annex VII — sortability pictograms, material composition codes, reuse marking, and the data carrier that links to composition, recycled content, substances of concern and sorting guidance — applies from 12 August 2028, or 24 months after the relevant Commission implementing act, whichever is later. Reusable packaging carries its own label and QR from 12 February 2029 on the same conditional basis.

The conditionality matters. The Commission's own deadline to adopt those implementing acts was 12 August 2026 — and it passed without them. As of mid-August 2026 the acts still do not exist, and the clock does not start until they do. The Joint Research Centre published a technical proposal for the label system in January 2026 and a targeted consultation followed, but adoption remains pending. The harmonised reporting format is late for the same reason — its implementing act was expected in early 2026 and still had not appeared by mid-August. What this means in practice: if the labelling act enters into force in, say, September 2026, the label obligation lands around September 2028; if it slips into 2027, the label slips into 2029. Treat any supplier who quotes you a firm 2028 label specification today with appropriate suspicion; the specification does not yet exist.

What you can do now is collect the underlying data, because the fields the label will eventually carry — material composition, recycled content, substances of concern — are the same fields your EPR declaration already needs, and the same ones the product passport asks for.

Two instruments, two agendas

The ESPR (Regulation (EU) 2024/1781) governs the sustainability of products and introduces the Digital Product Passport, rolled out group by group through delegated acts. The Packaging and Packaging Waste Regulation is a distinct EU regulation dealing with packaging across all sectors: its agenda includes harmonised labelling to help consumers sort waste, recyclability requirements for packaging design, minimum recycled-content ambitions for plastic packaging, packaging minimisation and reuse.

Because the PPWR’s detailed requirements arrive through its own timetable of implementing measures — and that timetable is still being worked through — specific dates and thresholds should be checked against the current state of the legislation for your packaging types rather than assumed. What is safe to say: packaging compliance is becoming a data exercise, just as product compliance is.

Does packaging get a Digital Product Passport?

Be careful with the confident claims circulating here. The DPP is an ESPR instrument, and ESPR passports attach to product groups selected in working plans and defined in delegated acts — the first working plan (April 2025) prioritises textiles, furniture including mattresses, tyres, iron and steel, and aluminium. Packaging as such is not one of those named priority groups, and whether or how packaging-related information ends up inside a product’s passport will be settled per product group in the delegated acts.

So the working assumption for a brand should be: your product may need a DPP under ESPR; your packaging has obligations under the PPWR — labelling, recyclability, recycled content, EPR registration — whether or not any passport is involved. Neither obligation substitutes for the other.

Where the two regimes touch

The overlap is in the data, not the legal instruments:

Material declarations — PPWR labelling and recyclability assessment require knowing exactly what the packaging is made of; ESPR passports require the same for the product. Both trace back to supplier declarations.
Recycled content — recycled-content claims for packaging and circularity data for products both need evidenced percentages from suppliers, not marketing assertions.
End-of-life and EPR — packaging EPR fees are increasingly modulated by recyclability, and DPPs are designed to carry end-of-life information for products. Both reward the same thing: structured, accurate material data.
The same suppliers — for many brands, the converter who supplies the box and the factory that supplies the product sit in one purchase-order flow. One data request can cover both.

Collect once: a practical setup for brands

Extend your DPP data model by one level: alongside each product record, hold a packaging record — components (box, insert, film, label), material per component, recycled-content share with the supplier’s evidence attached, weights, and the supplier who declared it. Ask for this in the same structured request you send for product data; packaging suppliers are used to providing material specifications and the marginal effort is small.

The payoff compounds: the same records feed PPWR labelling decisions, EPR declarations to national schemes, retailer packaging scorecards and — where a delegated act asks for packaging-related fields — your product’s passport. PassPer’s AI extraction reads packaging specs and supplier declarations the same way it reads product documents, so the packaging layer is an extension of the same pipeline, not a second project. Start with the free readiness check to see what your products — and what sits around them — will need.

Frequently asked questions

Does packaging need its own Digital Product Passport?

The DPP is created by ESPR delegated acts for selected product groups, and packaging as such is not among the first working plan’s named priority groups. Packaging obligations — labelling, recyclability, recycled content, EPR — flow primarily from the PPWR. Whether packaging information appears inside a product’s passport will be defined per product group, so watch the delegated act for yours.

Is the PPWR already in force, and when do its requirements apply?

The PPWR is a separate regulation with its own phased timetable of requirements and implementing measures, and that timetable is still being worked through. Rather than rely on second-hand dates, check the current state of the legislation for the specific requirements that touch your packaging types — and treat data readiness as the no-regrets move in the meantime.

We sell into the EU from outside. Do packaging rules hit us too?

Packaging obligations attach to packaging placed on the EU market, and as the economic operator placing packaged products on the market you should expect responsibilities — including EPR registration in the member states where you sell, which typically runs through national schemes. The practical burden is the same either way: knowing and evidencing what your packaging is made of.

Can we reuse our DPP supplier data collection for PPWR compliance?

Largely, yes — that is the point. Material composition, recycled-content evidence and supplier declarations are the raw inputs for both regimes. If your DPP data requests are structured, adding packaging components to the same request costs little and saves you running a second collection project against the same suppliers.

See where you stand — three ways, all free.

Take the 2-minute readiness check, watch the 10-minute interactive walkthrough, or download the full 2026 compliance guide. No account needed.

Free readiness check → See it in action Get the guide (PDF)