One Regulation for the Whole EU
The PPWR, officially Regulation (EU) 2025/40, replaces the old European packaging directives. That difference matters. A directive had to be translated into national law by each member state, which led to a patchwork of local variations. A regulation applies directly and in exactly the same way in every EU country.
The goal is clear: less packaging waste and a stronger circular economy. To get there, the regulation sets new requirements for the collection, reuse and recycling of packaging. It also aligns the rules for how packaging is designed and labelled, so a company selling in several EU countries no longer has to deal with completely different standards for the same box or pallet wrap.
Important to know: this applies to all businesses operating in the EU, not just those that trade internationally. A company that only sells within the Netherlands has to comply just as much as a company exporting across the continent.
No Declaration, No Market Access
One of the most concrete changes is the EU Declaration of Conformity, or EU DoC. Since 12 August 2026, packaging may only be placed on the EU market when a valid EU DoC is in place. And it is required for every packaging type you use.
The EU DoC is a self-declaration. You draw it up yourself and state that your packaging meets all PPWR requirements. It contains, among other things, a unique declaration number, a description of the packaging type, the name and address of the responsible party, a statement of compliance, a reference to the technical file, and a date and signature.
That technical file is just as important as the declaration itself. It provides the evidence behind your claims on recyclability, weight, reusability and the use of recycled material. Without a technical file, an EU DoC has no value. National authorities can ask to see both, so they need to be complete, up to date and easy to find.
How to reduce the impact for your business? Please contact team Trasegro.
Traceability Becomes the Standard
The PPWR also raises the bar on traceability. Every packaging must carry a type, batch or serial number, so it can always be traced back. These details need to be kept in your own records.
On top of that, businesses must check whether they meet the new registration requirements, whether they have reporting obligations and whether their current packaging designs need to be adjusted. Some companies will find they already tick several boxes. Even so, it pays to review the full process, because non-compliance can lead to penalties such as fines.
Know Your Role in the Packaging Chain
To make clear who is responsible for what, the PPWR works with defined roles. Each role comes with its own set of obligations. The regulation distinguishes between the manufacturer, supplier, importer, distributor, authorised representative, producer, final distributor, fulfilment service provider and packaging waste operator.
This is where things can get complicated. Your role is determined per product, and one company can hold several roles at the same time. A business might be the manufacturer of one product line and the importer of another, for example. Mapping these roles carefully is the first step towards building the right obligations into your daily processes.
For supply chains with multiple partners, this also means clear agreements are essential. Who drafts the declaration, who keeps the technical file and who handles the registration? Gaps between partners quickly become compliance risks.
Not sure which role applies to your business? Please contact team Trasegro.
National Rules Still Apply
Although the PPWR is the same everywhere, member states can still add national rules. These focus on implementation, enforcement and organisation, such as registration, supervision and waste infrastructure. That means the details can still differ from country to country.
Germany is a good example. Companies selling packaged products there must sign a contract with a so-called dual system, a party that takes over the return and recycling of packaging in exchange for a fee. In addition, EU countries may set their own language requirements for product labels, packaging and user instructions. Selling in several markets can therefore still mean several sets of local requirements.
More Rules on the Way
The regulation already applies, but the story is far from finished. The European Commission is working out several provisions step by step over the coming years, and more implementing rules are expected. Companies that set up a solid compliance process now will find it much easier to absorb those updates later.
What This Means for Our Customers
The PPWR touches far more than packaging design. It affects documentation, record keeping, partner agreements and the way goods are prepared for the EU market. For businesses with complex supply chains, multiple product lines or sales in several EU countries, the impact can be significant. A careful review today prevents delays, rejected shipments or fines tomorrow.
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