Regulatory Update
PPWR 2026: What EU Sellers Must Know Before August 12
The EU Packaging and Packaging Waste Regulation (Regulation EU 2025/40) becomes enforceable on August 12, 2026. Unlike a Directive, it applies directly across all 27 member states — no transposition delay. Here's what you need to prepare.
What is PPWR?
The Packaging and Packaging Waste Regulation (PPWR)— formally Regulation (EU) 2025/40 — is the most significant overhaul of packaging regulation in a generation. It replaces the 1994 Packaging Directive (94/62/EC) with a directly applicable Regulation that covers:
- Recyclability requirements graded A through E — with D and E banned from 2030
- Mandatory recycled content in plastic packaging, starting 2030
- PFAS restrictions in food-contact packaging from August 2026
- Empty-space ratio cap of 40% for grouped, transport, and e-commerce packaging
- Declaration of Conformity requirement for all packaging
- Reuse and refill targets for specific packaging formats
- Marketplace verification obligations — platforms must check seller compliance
Who Is Affected?
PPWR applies to any economic operator placing packaged products on the EU market. This includes:
- EU-based manufacturers and brand owners
- Non-EU manufacturers and exporters selling into the EU
- Importers bringing packaged goods into the EU
- Distributors and fulfilment service providers
- Online marketplaces (Amazon, eBay, Zalando, etc.) — and by extension, their third-party sellers
- Retailers and hospitality businesses using service packaging
If you sell physical products on Amazon, eBay, Shopify, or any other channel that reaches EU consumers — PPWR applies to you. There are no small-volume exemptions.
Key Deadlines
The August 12, 2026 date is the immediate priority. After this date, non-compliant packaging cannot legally be placed on the EU market. Marketplaces will begin enforcement, and regulators can issue penalties.
Recyclability Grades Explained (A–E)
PPWR introduces a five-tier recyclability grading system. Each packaging unit is assessed on the percentage of material (by weight) that is recyclable at scale:
Grade A — recyclable ≥ ≥95% by weight
Permitted permanently
Grade B — recyclable ≥ ≥90% by weight
Permitted permanently
Grade C — recyclable ≥ ≥80% by weight
Permitted until 2038
Grade D — recyclable ≥ ≥70% by weight
Banned from 2030
Grade E — recyclable ≥ <70% by weight
Banned from 2030
Multi-material laminates, dark-coloured plastics (undetectable by NIR sorters), PVC, and oxo-degradable plastics are all at high risk of falling below the C-grade threshold. Every percentage point matters.
Declaration of Conformity
Starting August 12, 2026, every packaged product on the EU market requires a Declaration of Conformity covering the packaging. This is separate from any CE marking or product-safety declaration — it is packaging-specific.
The Declaration must confirm:
- Recyclability grade of each packaging component (A–E)
- Recycled content percentages where applicable
- Compliance with substance restrictions (PFAS, heavy metals)
- Empty-space ratio compliance (<40%)
Marketplaces will require this documentation. Without it, your listings may be blocked or de-listed. Amazon has already begun rolling out packaging compliance fields in Seller Central for specific categories.
Recycled Content Targets
For plastic packaging, PPWR sets mandatory recycled content minimums:
| Packaging Type | 2030 Target | 2040 Target |
|---|---|---|
| PET bottles | 30% | 50–65% |
| Contact-sensitive (non-PET) | 10–35% | 25–50% |
| Other plastic packaging | 35% | 65% |
| Single-use beverage bottles | 30% | 65% |
These targets will create significant demand pressure on food-grade recycled plastics. Supply chains should begin planning now — 2030 is closer than it seems.
PFAS Restrictions (August 2026)
From August 2026, PFAS (per- and polyfluoroalkyl substances) in food-contact packaging are restricted above defined threshold limits. PFAS are used in:
- Greaseproof paper and cardboard (fast-food wrappers, bakery bags)
- Pizza boxes
- Microwave popcorn bags
- Moulded-fibre takeaway containers
- Compostable food-service packaging (some formulations)
If your product uses any food-contact packaging material, verify with your packaging supplier that PFAS levels are below the thresholds. Non-compliance = product withdrawal from the market.
Empty-Space Ratio Cap
PPWR caps the empty-space ratio at 40% for:
- Grouped packaging (multi-packs)
- Transport packaging (pallets, outer cartons)
- E-commerce packaging (the box that arrives at the consumer's door)
This affects subscription boxes with excessive filler, Amazon standard oversized boxes for small items, and gift sets with oversized presentation packaging. Right-sizing your packaging is now a compliance requirement, not just a cost-saving measure.
Marketplace Verification
PPWR requires online marketplaces to verify seller packaging compliance. In practice, expect:
- Documentation requests via Seller Central / account health dashboards
- Packaging declarations as a new compliance field in product listings
- Potential listing suppression for non-compliant ASINs
- Integration with national EPR registers (LUCID, ADEME, RPE, etc.)
- Increased scrutiny of packaging claims and recyclability labels
Your PPWR Action Checklist
Prepare for PPWR — before August 12
DutyScope's PPWR tracker shows your recyclability grades, recycled content status, and Declaration of Conformity readiness — all in one place.