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EU Packaging Regulation (PPWR) — guide

What is PPWR?

PPWR is Regulation (EU) 2025/40 on packaging and packaging waste. It replaces the earlier Packaging Directive 94/62/EC, entered into force on 11 February 2025, and applies from 12 August 2026.

The key difference from the old directive is that PPWR is a regulation. That means it applies directly and identically in every member state, Croatia included, with no transposition into national law. The same rules govern your online shop as any retailer in any other EU country, and packaging that conforms to the Regulation can be sold freely across the entire EU market.

Who it binds

The Regulation covers every economic operator involved in placing packaging on the EU market. That is a far wider set of businesses than most people assume:

  • Manufacturers make packaging, or pack goods under their own name or brand
  • Importers bring packaged goods in from outside the EU
  • Distributors resell packaged goods

Your role is not a choice. It follows from what you do with the packaging, and the same online shop can be in several roles at once for different products. One point matters in particular: if you pack or sell a product under your own brand, or modify packaging in a way that affects its conformity, you generally take on the manufacturer's obligations.

What applies from 12 August 2026

Some obligations start on the application date; others phase in through 2030 and beyond. For retailers, two things matter most from 12 August 2026:

  • Restrictions on substances of concern in packaging (Article 5)
  • The EU Declaration of Conformity obligation for the packaging you place on the market

By contrast, the obligation to design packaging for recyclability does not apply on the application date. It starts only in 2030, with stricter recyclability grades later still (see below). The date-by-date breakdown is in What applies from 12 August 2026.

Restrictions on substances (Article 5)

Two restrictions matter most to retailers:

  • Heavy metals. The sum of the concentrations of lead, cadmium, mercury and hexavalent chromium in packaging must not exceed 100 mg/kg.
  • PFAS in food-contact packaging. PFAS ("forever chemicals") are banned in packaging in direct contact with food above very low limits (25 ppb for any single PFAS, 250 ppb for the sum of all PFAS, and 50 mg/kg of total fluorine).

There is no transition period for these restrictions: from the application date, packaging that does not meet them may not be placed on the EU market, regardless of when it was produced.

The EU Declaration of Conformity (Annex VIII)

The EU Declaration of Conformity is the document in which the manufacturer confirms, under its sole responsibility, that the packaging meets the applicable requirements of the Regulation (Articles 5–12). It is not a certificate issued by a third party (it is a self-declaration), but it must be backed by technical documentation.

The contents are prescribed by Annex VIII. Among other things, the declaration must contain:

  • a unique identification number for the declaration,
  • the manufacturer's name and address (and the authorised representative's, if any),
  • an identification of the packaging the declaration covers (type, materials),
  • a statement that the manufacturer takes sole responsibility for conformity,
  • a reference to Regulation (EU) 2025/40 and to the standards or technical specifications applied,
  • the place and date of issue, and a signature.

Technical documentation. Conformity is assessed by internal production control (Annex VII). The manufacturer carries it out itself, with no notified body. The technical documentation and the declaration must be kept for 5 years for single-use packaging, or 10 years for reusable packaging.

Roles differ. The manufacturer draws up the declaration. The importer must obtain and keep a copy of it and verify that the conformity assessment was carried out. The distributor checks that the packaging bears the required markings and information.

We're preparing a free EU Declaration of Conformity template for packaging following Annex VIII. Leave your email and we'll send it the moment it's ready.

What comes later

PPWR is more than a single date. After 2026, the following phase in, among others:

  • recyclability grades and a minimum share of recycled content in plastic packaging (from 2030),
  • a limit on empty space in grouped, transport and e-commerce packaging (no more than 50%),
  • mandatory packaging labelling to make sorting and recycling easier,
  • targets for reusable packaging and deposit-return systems for single-use beverage packaging.

That is why it is worth setting up a record of your packaging now. The same documentation will serve you for every step that follows.

Next steps

  1. Establish which role you are in (manufacturer, importer, distributor) for each type of packaging.
  2. Collect data on materials and substances from your suppliers.
  3. Check that your packaging meets the substance restrictions (heavy metals, PFAS).
  4. Prepare the EU Declaration of Conformity under Annex VIII and the accompanying technical documentation.
  5. Retain the documentation for the prescribed period (5 or 10 years).

Related guides

This guide is informational, helps you prepare documentation, and is not legal advice. For an assessment of your specific situation, consult a professional.