PPWR Requirements 2026: What Must Be in Place Now

Laboratory testing takes weeks from sampling to report. Packaging you place on the market from now on needs that evidence in hand, so testing gaps are the first thing to close.

What does EPR registration require?

Extended producer responsibility runs per Member State: the producer registers, reports packaging volumes, and pays fees in each country where it places packaging on the market. Non-EU distance sellers must appoint an authorized representative. Your role determines whether this obligation is yours; see who must comply. Our EPR registration service handles registration and reporting setup per market.

What documentation must you hold?

Two documents, held and shown on request rather than submitted in advance:

• Technical file (Annex VII): the evidence that your packaging meets the applicable requirements: test reports, design assessments, and supporting data.
• Declaration of Conformity (Annex VIII): the signed statement based on that file, following conformity procedure Module A, retained for the required period.

We create the technical file and DoC with you, or independently review documentation you drafted in-house.

What evidence is required in 2026?

The technical file must demonstrate that your packaging meets the applicable design requirements, such as recyclability, minimization, and reusability where the packaging is declared reusable, using harmonized standards or recognized guidelines. For recyclability, EN 13430 supports the self-assessment today; the A/B/C grading detail arrives via delegated acts for 2030, but the documentary demonstration is required now. Early grade evaluation shows where design changes are needed while they are less costly. Details on the later waves are on the timeline page.

What about packaging already on the market or held in stock?

• Already placed on the EU market before 12 August 2026: it can remain on the market, even if it does not meet PPWR. Keep evidence of the import or first supply date.
• Produced before 12 August 2026 but not yet placed on the market: it does not have to be destroyed, remanufactured, or re-labelled. The identification information required under Article 15(5) and 15(6), the unique identification and the manufacturer's name and address, can be provided on an accompanying document. The same applies to reusable packaging already placed on the market.
• Manufactured after 12 August 2026: that information goes on the packaging itself, with an accompanying document only where affixing it directly is not possible.

What if your evidence is not complete?

The obligations apply to packaging placed on the market from 12 August 2026, so the practical question now is sequencing rather than deadline. A gap analysis maps which packaging is affected, which evidence exists, and what to close first, based on what you are placing on the market next. Testing and documentation then follow that order rather than running everything at once.

Frequently asked questions