The EU packaging rules — and the proof you need
PPWR, without the jargon
The Packaging and Packaging Waste Regulation (PPWR) applies across the EU from 12 August 2026. Every packaging you place on the market has to meet the rules — and you have to be able to prove it with documents. Here is what that means for a webshop, in plain terms.
What PPWR actually is
PPWR is the EU's new packaging law. From 12 August 2026, every packaging you place on the market must meet the design rules — and you must be able to prove it with a Declaration of Conformity. Separately, in each country where you sell you pay towards the waste processing of your packaging (that is EPR) and report on it. PPWR is about the packaging itself; EPR is about what it costs and where you file.
Two hats you can't mix up
The "may this go on the market?" side. Whoever sells packaging under their own brand — even when a supplier physically makes it. That is you. Your duty: the packaging meets the design rules, and you draw up the Declaration of Conformity and keep the proof. There is one manufacturer per packaging type, across the whole EU. Fixed.
The "who pays for waste processing?" side. Whoever first makes the packaging available in a specific country. Your duty there: register, report volumes, pay the fee — that is EPR. This is variable: you are a producer in every country where you sell.
One manufacturer (EU-wide, fixed), multiple producers (per country).
The trap webshops don't see
Under PPWR, "selling in a country" means where your customer lives — not where you are. Webshops fall squarely under this. Send one parcel to a consumer in another EU country and you become a producer of that packaging there — from the first box, no threshold, no small-business exemption.
The exception: sell to an EU business (a distributor or retailer) instead of directly to the consumer, and that business becomes the producer. The heavy load lands mainly on direct-to-consumer sales — which is exactly what a webshop is.
Under the threshold isn't off the hook
Below the reporting threshold you pay no regular fee — but you still have to prove you're under it. No bill doesn't mean no paperwork, and that proof is exactly what a dossier gives you. And single-use plastic — your caps and pumps — has no threshold at all: from the first unit, it counts.
What August 2026 actually asks of you now
- Per component
- material category, weight, and proof on heavy metals (Pb+Cd+Hg+Cr VI together ≤ 100 mg/kg) and PFAS.
- Per packaging
- the composition, a minimisation justification, a unique identifier and a signed Declaration of Conformity.
- Per delivery
- the supplier's documents.
Recyclability and recycled content: set the fields up now, fill them in toward 2030.
The timeline
| Date | What |
|---|---|
| 12 Aug 2026 | PPWR applies. Declaration of Conformity required. Substances: heavy metals ≤ 100 mg/kg, PFAS (food contact). Minimisation. Reusable-packaging requirements. |
| 12 Feb 2027 | EPR digital compliance identifier (a flag that says "EPR-compliant"; no composition data). National producer registers (phasing in). |
| 12 Aug 2028 | Harmonised sorting and material label. |
| 12 Feb 2029 | Label for reusable packaging (QR to the reuse system). |
| 1 Jan 2030 | Recyclability grade (minimum C) becomes binding. Recycled-content requirements. Annex V bans on certain single-use formats. |
| 2040 | Higher recycled-content targets. |
Where Effinity fits
The AR (Authorised Representative) does the legal, per-country registration. The brand decides which countries are still worth selling in, given the load. The Effinity platform delivers the data and proof layer: the complete packaging dossier — the Declaration of Conformity plus the supporting documents — and the insight (margin per country) to make that call.
We never fill in data we don't have. A missing weight becomes a visible gap, not a guess — you always know what's proven and what isn't.
To be clear: Effinity is not your AR and does not register or file EPR on your behalf. It gives you the dossier your AR needs.
Compliance blows away when you treat it as a separate project. The answer is keeping it up while you work — the tooling is the easy part.
Start your packaging dossier
Take the PPWR starter guide with you — what to collect per component, per packaging and per delivery.
The PPWR guide (PDF) will be available here soon.
Not sure where you stand? Take the free "Are you ready for PPWR?" scan.
Honest limits
This is a workable summary of the regulation, not legal advice. Many details — the recyclability method, the recycled-content calculation, the exact category breakdown and threshold dates — still wait on delegated acts and national implementation (in the Netherlands, Verpact). Set the structure up now; the rules for filling it in follow.
Definitive legal source: Annex VII and VIII of Regulation (EU) 2025/40 (CELEX 32025R0040), eur-lex.europa.eu.