What is the PPWR and when does it apply?

An EU regulation, directly applicable since 12 August 2026

The PPWR is the European Packaging Regulation (Regulation (EU) 2025/40), which sets rules for the design of packaging and the management of packaging waste. Because it is a regulation, it applies directly in each Member State — no national law is needed to transpose it, as would be the case with a directive. The regulation has been applicable since 12 August 2026, with no transition period for packaging produced after that date.

The core obligations are the same throughout the EU. Every package requires an EU declaration of conformity according to the model in Annex VIII, with technical documentation retained for five years. The name and postal address of the responsible party appear on or with the package. A threshold of 100 mg/kg applies for heavy metals and a PFAS ban for packages that come into contact with food. Whoever places packages on a market for the first time registers in the producer register of each country where this occurs — packages from an unregistered producer may not be traded there. When selling at a distance to a Member State where there is no establishment, a written authorised representative must be appointed.

The registration obligation does, however, vary by country. The Netherlands has a threshold of 50,000 kg per year via Verpact, below which registration is not yet required (though record-keeping is). Verpact expects this threshold to be removed once the PPWR producer register becomes operational, at the earliest 12 August 2027, with a first reporting year of 2028 and notification before 1 June 2029. Germany has no such threshold: registration in LUCID is required from the first package on the German market, and marketplaces actively monitor this. For Belgium, France and Austria, the registers have not yet been checked.

What this is based on: Article 1 and the RVO guidance

Article 1 of Regulation (EU) 2025/40 describes the subject and scope of the regulation; the RVO page on EU legislation on packaging requirements (PPWR) provides the Dutch guidance on entry into force and application.