The deadline is almost here. From 12 August 2026, the EU Packaging and Packaging Waste Regulation, PPWR, starts to apply.
For companies placing packaging or packaged products on the EU market, compliance is not only about using the right materials. You must also be able to prove that your packaging meets the applicable requirements.
If your documentation is missing, incomplete or still waiting for supplier input, your packaging may be considered non-compliant. This can lead to products being blocked, withdrawn or recalled from the market.
What should be ready by now?
Your compliance file should allow someone who has never seen the packaging before to understand what it is made from, which requirements apply and how you concluded that it is compliant.
At a minimum, companies should review whether they have the following documentation ready for each packaging type:
1. Packaging specifications
The file should include a clear description of the packaging and its intended use, including:
- Packaging format and components
- Materials and material structure
- Weight and dimensions
- Coatings, adhesives, inks and other relevant substances
- Manufacturer and supplier details
- Identification or reference number for traceability
2. An analysis of the applicable PPWR requirements
Not every requirement applies to every packaging type, and several PPWR obligations have later application dates. However, companies must identify which requirements apply from 12 August 2026 and document how compliance has been assessed.
This analysis may cover substances of concern, heavy metals, PFAS limits for food-contact packaging, recyclability, recycled content, compostability, packaging minimisation, reuse and labelling, depending on the packaging concerned.
3. Supplier information and supporting evidence
Suppliers must provide manufacturers with the information and documentation needed to demonstrate compliance. This can include:
- Completed supplier questionnaires
- Material composition data
- Technical specifications
- Test reports and laboratory results
- Statements concerning restricted substances
- Food-contact documentation where relevant
- Information supporting recyclability or recycled-content claims
A completed questionnaire alone may not be enough. The answers should be reviewed and supported by reliable evidence where necessary.
4. Technical documentation
Manufacturers must prepare technical documentation in line with Annex VII of the PPWR. The file should contain sufficient information to assess whether the packaging meets the applicable requirements.
Depending on the packaging, this can include drawings, material descriptions, applied standards or technical specifications, calculations, assessments, test reports and an analysis of the risks of non-compliance.
The documentation should also explain how the conclusions were reached. A folder containing specifications without a clear compliance assessment is not a complete technical file.
5. Conformity assessment
Before placing packaging on the market, the manufacturer must carry out, or have carried out, the required conformity assessment.
The assessment should connect the applicable legal requirements with the available evidence. Any gaps, assumptions or supplier dependencies should already have been identified and resolved.
6. EU Declaration of Conformity
Once compliance has been demonstrated, the manufacturer must prepare an EU Declaration of Conformity following the structure in Annex VIII.
The declaration identifies the packaging, the responsible manufacturer, the relevant legislation and the standards or technical specifications used. By signing it, the manufacturer assumes responsibility for the packaging’s compliance.
7. Document control and retention
The technical documentation and EU Declaration of Conformity must remain available and up to date. They must generally be kept for:
- Five years for single-use packaging
- Ten years for reusable packaging
Companies should also have a process for reviewing compliance when a packaging design, material, supplier or relevant technical specification changes.
What happens if the file is incomplete?
After 12 August, saying that the documentation is being prepared will not demonstrate compliance.
Manufacturers may be required to provide the relevant information and technical documentation to a national authority within 10 days of a reasoned request. Where packaging is believed to be non-compliant, corrective action can include bringing it into compliance, withdrawing it or recalling it.
Importers must also verify that the required conformity assessment and technical documentation are in place before placing packaging on the EU market.
There is almost no time left
With only six days remaining, companies should now focus on closing critical gaps:
- Identify packaging without a complete compliance file
- Escalate unanswered supplier requests
- Review whether supplier statements are supported by evidence
- Complete the conformity assessment
- Prepare and approve the EU Declaration of Conformity
- Confirm who is responsible for maintaining each file
If you have none of these documents, or only part of them, urgent action is needed.
Contact LIRK NOR for immediate PPWR support. Six days is very little time, but entering the deadline without evidence of compliance could cost much more.
The PPWR application date and documentation obligations are set out in Regulation (EU) 2025/40. The European Commission has also published PPWR implementation guidance.