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PPWR - what applies now and what comes next

Anthony Buckley
CEO, Anthony Buckley Consulting Ltd., Ireland
Published 07 Sep 2026

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The Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, applies across the EU from 12 August 2026, and it reaches further than packaging manufacturers: an importer or distributor who first makes packaged products available in the EU is a 'producer', and 'packaging' covers almost anything sold with an item that is not part of it. This recording separates what applies now from what is still to come. In force today are the Article 5 substance limits (lead, cadmium, mercury and hexavalent chromium, and PFAS in food-contact packaging) and the duty to keep records of packaging placed on the market. The rest, from recyclability and minimum recycled content to labelling, the empty-space ratio and declarations of conformity, depends on Commission implementing acts scheduled from December 2026 to February 2030, of which none has been adopted and two are already late. Member states must set penalties by 12 February 2027. For importers the impact may come first, since evidence of conformity may be demanded at the time of import, and packaging redesign cannot be done overnight. Watch the video to find out whether your goods are caught, what to check with suppliers now, and where derogations must be sought before it is too late.

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