What applies from 12 August 2026 (PPWR)
PPWR applies from 12 August 2026, but that does not mean every obligation starts on that day. Most requirements phase in through 2028, 2030 and beyond. For a typical online shop or small retailer, only two things genuinely take effect on the application date. Several obligations often attributed to 2026 actually arrive much later.
What genuinely applies from 12 August 2026
For a retailer placing packaging on the market, from the application date:
- Restrictions on substances (Article 5). The sum of heavy metals (lead, cadmium, mercury, hexavalent chromium) in packaging must not exceed 100 mg/kg, and PFAS is banned in food-contact packaging above very low limits. These restrictions have no transition period.
- The EU Declaration of Conformity and technical documentation. If you are the manufacturer, the packaging you place on the market needs a declaration under Annex VIII and the accompanying technical documentation (Annex VII).
In addition, if you import or resell packaging, the verification duties of importers and distributors apply from the same date (that a declaration exists, that markings and information are in place). For most small retailers, that is the entire "for now" list.
What comes later (and exactly when)
None of the following applies on 12 August 2026; each starts from the date written into its own article:
| Obligation | Article | Applies from |
|---|---|---|
| Design for recycling (grades A/B/C) | Art. 6 | 1 January 2030 |
| Minimum recycled content in plastic | Art. 7 | 1 January 2030 |
| Compostable packaging requirements | Art. 9 | 12 February 2028 |
| Packaging minimisation | Art. 10 | 1 January 2030 |
| Packaging labelling (sorting label) | Art. 12 | 12 August 2028 |
| Empty space of no more than 50% (grouped/transport/e-commerce) | Art. 24 | 1 January 2030 |
| Restrictions on packaging formats (Annex V) | Art. 25 | 1 January 2030 |
| Reuse targets | Art. 29 | 1 January 2030 |
The empty-space calculation methodology has yet to be adopted (by 12 February 2028), so even that rule starts no earlier than 2030.
Three common misconceptions
- "Recyclability applies immediately." No. On the application date, packaging does not have to meet recyclability grades. The design-for-recycling obligation starts in 2030, with stricter grades later still.
- "PFAS has an extra grace period." It does not. Article 5 says explicitly "from 12 August 2026": the food-packaging ban applies from the application date, with no delay.
- "The sorting label must be on packaging immediately." No. The harmonised label is mandatory only from 12 August 2028.
The regulation's application article (Art. 71) contains exactly one deferral. A single technical provision, irrelevant to retailers, applies from 2029; every other later date is written into its own article, not carved out as a general exception.
What this means for you
A declaration of conformity drawn up on the application date attests conformity with Article 5 and the technical documentation, and is updated over time as further requirements switch on from 2028 and 2030. That is why it is worth setting up an orderly packaging record now: the same documentation will serve you for every step that follows.
For a detailed overview see the guide to Regulation (EU) 2025/40; if you sell online, see also PPWR for online shops, and for substances in food packaging, the PFAS ban.
This guide is informational, helps you prepare documentation, and is not legal advice. For an assessment of your situation, consult a professional.