Why is August 2026 important for the PPWR?
Regulation (EU) 2025/40 – better known as the EU Packaging and Packaging Waste Regulation (PPWR) – entered into force on February 11, 2025. However, its application will be rolled out in phases. For many companies, August 12, 2026 marks the date when the PPWR becomes a fact of life.
On March 30, 2026, the European Commission published two key guidance documents: Commission Notice on PPWR (EU) 2025/40 and an accompanying FAQ.
Together, these materials provide the most authoritative interpretation of the regulation available to date, and companies should consult them alongside the regulation text itself.
Under the PPWR, there will be several waves of secondary legislation comprising Delegated Acts and Implementing Acts that will define technical rules, methodologies, and compliance. So while the application date is approaching, there are some areas that remain subject to change.
However, August is almost here and carries some very specific obligations that companies will need to fulfill in order to comply with the new rules. Some of the most notable changes coming in August involve the substances of concern (PFAS chemicals and heavy metals), registering with national Extended Producer Responsibility schemes (and Producer Responsibility Organizations where appropriate), and various administrative and information management tasks (such as creating and collecting Declarations of Conformity, information about materials from suppliers, etc.)
What roles do companies have under the PPWR?
The PPWR defines several different roles for companies, with some roles overlapping with one another. The same company can have more than one role, in which case, it’s expected to comply with multiple sets of obligations.
While all roles have obligations, requirements for manufacturers are arguably the most important.
Put simply, a manufacturer (according to the PPWR) is a company that orders and designs the packaging. Typically, they fill the packaging with a product and have their brand name visible on it.
What do manufacturers need to do?
Manufacturers are one of the most important economic operators for PPWR compliance. As mentioned above, they are basically the company “creating” the packaging for a particular product.
Below is an example of a checklist that shows what kind of steps manufacturers could take as part of their compliance efforts, and actions they can take to help meet their goals.
Note: Not all requirements need to be met for August 2026. Goals related to future requirements are indicated in brackets.
