As of August 12, 2026, an EU Declaration of Conformity (DoC) must be available for every packaging type placed on the EU market, supported by technical documentation. If this documentation is missing, it can lead to enforcement measures by market supervisors, including sales bans, withdrawal from the market, and administrative sanctions. Operational disruptions in the supply chain may also occur.
Regulation (EU) 2025/40 on packaging and packaging waste (the PPWR) entered into force on February 11, 2025, and will apply from August 12, 2026, with some requirements being phased in until 2030.
If your company places packaged goods on the EU market, your packaging must comply with the PPWR, even when packaging or logistics activities are outsourced. You are responsible for ensuring your packaging complies with the PPWR.
Roles and responsibilities
One company can have multiple roles, and each role brings its own obligations:
- Do you manufacture packaging or place it on the market under your own brand name? Then you are a manufacturer, and you must be able to demonstrate that your packaging complies (technical file + Declaration of Conformity). The manufacturer is the party that places the packaging on the market under its own name or brand. This party is responsible for drawing up the Declaration of Conformity and the technical documentation. Other market participants, such as importers and distributors, also have their own legal obligations.
- Do you import packaged products from outside the EU and place them on the EU market? Placing on the market occurs when there is an offer or agreement to transfer ownership, possession, or another property right. Then you are an importer, and potentially even a manufacturer if you modify the packaging or sell it under your own name.
- Do you sell or supply packaging/products that are already on the EU market? Then you are a distributor, responsible for checking compliance, ensuring correct labeling and documentation, and passing on relevant information within the supply chain.
- Are you the first to place packaging on the market in a member state (as a manufacturer, importer, or distributor)? Then you are also the producer, responsible for the costs of collection and recycling of packaging waste in that country.
- Do you handle the storage or shipping of packaged products? Then you must ensure that your process does not damage the packaging or make it unsuitable.
Documentation and compliance from 2026
From August 12, 2026, all packaging placed on the EU market must be supported by a Declaration of Conformity. In this Declaration of Conformity, the packaging is described and assessed using supporting technical documentation.
In principle, one declaration is required per type of packaging. Similar packaging, such as different sizes using the same materials, can be grouped together as long as this does not affect conformity. Companies must also ensure that packaging continues to comply with the rules and update documentation when changes occur.
Transport packaging
Transport packaging falls fully under the PPWR. This includes pallets, pallet collars, film, strapping materials, and e-commerce packaging.
In principle, transport packaging falls entirely under the PPWR and must also meet the relevant requirements. Depending on the type of packaging, specific obligations and exceptions may apply.
A Declaration of Conformity must be available for every packaging type. Similar packaging can be grouped within a single conformity assessment under certain conditions, provided that conformity is not affected.
Transitional rules
Packaging lawfully placed on the EU market before August 12, 2026, may remain in use without being recalled or modified. For reusable packaging, an earlier deadline applies, namely February 11, 2025.
What should you do now?
To be well-prepared for the PPWR, timely action is important. We advise you to:
- assess your current packaging and determine your role within the regulations;
- check whether your packaging meets future requirements;
- make preparations for EPR registration and reporting;
- ensure that all necessary data and documentation are available;
- collaborate with suppliers and logistics partners.
Impact on your organization
The PPWR affects logistical and operational processes. Packaging requirements regarding documentation, traceability, and reporting are increasing. In the future, regulations will become even stricter, requiring packaging volume and empty space to be reduced as well.
Legal responsibility for compliance with these regulations remains with the customer. Van der Helm can provide support in optimizing packaging processes. Timely preparation is essential to comply with the regulations and prevent business disruptions.