EU PPWR for non-EU packaging exporters
The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, replaced the old packaging directive. It applies directly in every Member State, and your EU buyer cannot place your packaging on the market without your evidence.
Does PPWR apply to my packaging now?
Yes. PPWR has applied since 12 August 2026 to all packaging placed on the EU market, including packaging that arrives around imported goods.
It entered into force on 11 February 2025. Some obligations start later: recyclability requirements and recycled-content targets apply from 2030.
Key dates
| Date | What applies |
|---|---|
| 12 Aug 2026 | General application, including substance limits and the PFAS restriction for food-contact packaging |
| 12 Aug 2028 at the earliest | Harmonised sorting and recycled-content labels (24 months after the implementing act, which had not been adopted by October 2026) |
| 12 Feb 2029 at the earliest | Reuse label |
| 2030 | Recyclability and recycled-content targets |
What are the PFAS limits for food-contact packaging?
From 12 August 2026, food-contact packaging must not contain more than 25 ppb of any single PFAS or 250 ppb of the sum of PFAS measured by targeted analysis, plus a limit on total PFAS.
No harmonised EU test method exists yet. Commission guidance from June 2026 recommends screening for total fluorine first, then targeted analysis where needed. Food-contact packaging placed on the market after 12 August 2026 must comply, even if it was made earlier.
Who carries the obligation?
The packaging manufacturer runs the conformity assessment, keeps the technical documentation and signs the EU declaration of conformity. The EU importer must check those exist before placing packaging on the market. The producer in each Member State carries extended producer responsibility.
What a non-EU supplier gives the EU buyer
- An EU declaration of conformity covering the requirements that already apply, mainly the substance rules.
- PFAS evidence for food-contact packaging: a total-fluorine screen, targeted PFAS results, or both.
- A heavy-metals statement: lead, cadmium, mercury and hexavalent chromium together at or below 100 mg/kg.
- Technical documentation, and the material and weight data the buyer needs for producer-responsibility reporting.
Has PPWR been postponed?
No. The 12 August 2026 date stands.
The December 2025 Environmental Omnibus proposes to suspend the duty to appoint an authorised representative for packaged products sold directly to consumers in other Member States. It was still under negotiation in October 2026 and does not delay anything else.
How Truo handles PPWR
Truo's compliance agent maps PPWR requirements to each product and specification on the trade record, checks the evidence attached against them, and reopens review when a specification changes. Unknown applicability blocks release until a qualified reviewer decides. The agent proposes; a person signs off.