What Is PPWR? What Changed for Packaging in 2026

PPWR is Regulation (EU) 2025/40 on packaging and packaging waste. It has applied since 12 August 2026, and on the same date Directive 94/62/EC — in force for three decades — was repealed.

This article explains what the regulation is and what it changes in practice for a producer supplying packaging into the EU. It is not legal advice; where the obligation sits depends on the product and on your role in the transaction.

Why does it matter that PPWR is a regulation, not a directive?

A directive sets objectives that each member state transposes into national law; a regulation applies directly. Because PPWR is a regulation, the same text applies in all twenty-seven member states at the same time.

For a supplier this cuts both ways. Checking one text instead of twenty-seven is simpler. But it also removes the possibility that a practice accepted in one market quietly passes in another.

What does PPWR regulate?

PPWR treats packaging as a product and governs it end to end: the substances it contains, its recyclability, its recycled content, the avoidance of unnecessary volume, reusability and labelling.

The articles that bear most directly on a packaging producer are:

• Substances in packaging (Art. 5). The sum of lead, cadmium, mercury and hexavalent chromium concentrations is limited to 100 mg/kg. This is a content limit and is not the same thing as a migration measurement — the two are frequently confused.
• Recyclability (Art. 6). Packaging is expected to be designed for recycling.
• Recycled content (Art. 7). Targets are defined for recycled material in plastic packaging, and those shares are expected to be traceable.
• Minimisation (Art. 10). Layers with no functional purpose, double walls and false bottoms are not accepted.
• Reusability (Art. 11). A separate regime is defined for certain packaging formats.

Two things that get confused: recyclable and recycled content

Recyclable packaging is designed so that it can enter a recycling stream after use. Packaging with recycled content was made using recycled material. These are independent properties, and PPWR governs them in separate articles.

Packaging can be recyclable and carry no recycled content at all; the reverse is equally possible. Using the two terms interchangeably is a common source of confusion in supplier conversations, and it leads to the wrong document being requested.

Content limits and migration are likewise different things. A content limit measures how much of a substance is present in the material; migration measures how much of it transfers into the packed product. The heavy-metals limit PPWR sets is a content limit and does not replace migration limits under food-contact legislation — both apply.

When do the obligations start?

12 August 2026 is a start date, not an end date. Part of the regulation applies from then; labelling, extended producer responsibility and several other headings phase in later, on a timetable running to 2040.

That phasing turns compliance from a one-off exercise into an ongoing one. A requirement met today cannot be assumed to be met the same way next year — the relevant steps in the timetable need to be tracked.

What changed for a supplier outside the EU?

The most visible change is that your customer can now ask you for documents. The party placing packaging on the EU market must be able to demonstrate conformity, and to do that it needs information from the producer in its supply chain.

The request does not come from market habit but from the regulation itself: to issue a declaration of conformity, the material composition and any recycled content share must be known, and Article 16 separately governs information along the supply chain. What the customer asks for and what the declaration requires are therefore the same thing.

For a non-EU producer the real issue is lead time. The difference between preparing documentation when the order arrives and having it ready beforehand is often the order itself.

What is not settled yet?

The recyclability performance grades have not been published. The regulation provides that packaging recyclability will be classified, but the criteria for that classification are to be set separately by the European Commission — by 1 January 2028.

The practical consequence: today no producer can claim a performance grade for its packaging. If you are shown one, ask what it rests on — a grade assigned before the criteria exist is a claim without a basis.

Where DEKA Plastik stands

DEKA Plastik’s PPWR technical file is drawn up under Annex VII, Module A (internal production control), and an EU Declaration of Conformity is in place. The material composition and recycled content declaration sits under Articles 6 and 7 of the regulation.

The declaration covers PE bags only; it does not cover polypropylene (CPP, OPP) or polyamide/PE products. Within that scope the structure is mono-material: no lamination, no coextruded barrier layer, no metallised layer and no non-PE component such as paper, aluminium or polyamide. In PA/PE products the barrier function requires a multilayer structure.

This limit reflects the regime the declaration rests on, not a gap in evidence. The technical file is drawn up under Annex VII, Module A — internal production control, which covers production under the manufacturer’s own control. We extrude polyethylene film in our own facilities. We do not produce polypropylene film (CPP, OPP) — it is sourced as ready rolls from approved suppliers, and we carry out printing, slitting, cutting and sealing ourselves. We therefore cannot declare the material composition of those films on the basis of our own internal production control.

We state explicitly that not all of our catalogue falls within this declaration, because overstating scope weakens the compliance file itself. A declaration is worth as much for what it excludes as for what it covers.

On request, 20% to 100% post-consumer or pre-consumer recycled polyethylene can be used; traceability rests on our GRS 4.0 and RCS 2.0 scope certificates (what a GRS certificate is, in a separate article; our GRS product is here). One distinction matters here, and the declaration states it in its own text: a scope certificate is not proof that the goods delivered are certified. Proof for a specific shipment is the Transaction Certificate; the scope certificate evidences that our production facilities are audited within the system.

One point worth stating because it is often assumed the other way round: ink is a surface coating and does not change how the film is classified in the recycling stream. Printed and unprinted products have the same material composition.

The limit described above applies to us as well — we do not claim a recyclability performance grade. If you want to see how each article is addressed, our PPWR compliance page sets it out article by article.

What to ask your supplier

Knowing to ask for documents is not enough; you need to know what each document proves. Three misreadings come up most often:

• A scope certificate does not prove a shipment. It shows the facility is audited; that a given batch is certified is shown by a Transaction Certificate.
• A declaration is read together with its scope. Which product group does it cover, and which does it exclude — that sentence sits inside the declaration and is worth asking for.
• A test report and a declaration are not the same thing. A report documents a measurement; a declaration documents an undertaking.

If the answer is a general statement such as “our products are environmentally friendly”, it substitutes for none of them. That is precisely the change PPWR introduces: records rather than claims.