With less than three months to go until the PPWR starts to apply across Europe, businesses are still waiting for crucial guidance on compliance from the EU.
We spoke with Marzia Scopelliti, Senior Public Affairs Manager at The European Organisation for Packaging and the Environment (EUROPEN), to better understand how companies can make sure they are fully prepared for the big August deadline.
What are your general thoughts on where things currently stand with the PPWR especially in light of the news we recently broke regarding the letter from CEOs to the EU?
With only three months left before the PPWR begins to apply, industry is still operating without the level of clarity it needs to implement the Regulation with confidence. The risk is no longer theoretical - implementation uncertainty is already holding back investment decisions and creating concern across the packaging value chain.
What businesses need now is a structured high-level dialogue with the Commission and Member States to address the remaining implementation gaps, particularly around all obligations that will start applying in August 2026. Without greater clarity, companies are being asked to prepare for significant regulatory change without fully knowing how some requirements will operate in practice.
EUROPEN’s new PPWR toolkit gives a timeline of PPWR deadlines. What are some of the key dates that our readers should be aware of?
Some of the most important dates in the PPWR rollout begin in 2026 and continue through to 2040, with obligations phased in gradually across substances, labelling, recyclability and recycled content requirements.
A key early milestone is 12 August 2026, when new restrictions on substances in packaging begin to apply, including limits on heavy metals and PFAS in food-contact packaging.
From 2028 onwards, companies will begin seeing new requirements around compostable packaging and harmonised packaging labelling, including EU-wide labels for consumer sorting, recycled content, and deposit return systems. Reusable packaging labelling obligations follow in 2029.
The biggest shift comes in 2030, when several core requirements take effect simultaneously. These include some packaging minimisation obligations, recyclability- by-design requirements, and mandatory recycled-content targets.
Beyond that, 2035 introduces the requirement for all packaging to be recyclable “at scale”, meaning they must be collected, sorted and recycled in practice, while 2040 brings higher recycled-content targets for plastic packaging.
Regarding the new PPWR conformity assessment procedure, this will apply in August 2026 only for those requirements that are applicable at the time the packaging is placed on the market. As additional PPWR obligations enter into force over time, they will have to ensure compliance with newly applicable requirements.
The best practices section of the toolkit provides companies with a checklist of things to remember when completing their Declarations of Conformity. Please could you unpack the most important bits of advice from this section?
The toolkit’s guidance on Declarations of Conformity really comes down to preparation and traceability. One of the key messages is that companies should not treat the Declaration of Conformity as a last-minute paperwork exercise.
Businesses need to start mapping their packaging portfolios and supply chains early, so they understand which PPWR obligations apply to them and prepare internal checklists, datasets, and collect relevant technical documentation.
A major focus is supplier engagement. Much of the information needed for technical documentation will sit upstream in the value chain, so companies need processes in place to collect and verify that data well in advance.
The guidance also stresses the importance of strong internal governance. That includes building compliance checklists aligned with the PPWR annexes, preparing technical documentation alongside the DoC itself, and allowing sufficient time for review, approvals and record-keeping before products are placed on the market.
Another important point is that compliance will be ongoing rather than static. As packaging specifications evolve and implementing acts are published, businesses will need systems in place to regularly review and update their documentation.
In your discussions with EUROPEN members, what are some of the biggest concerns around compliance?
The biggest concern businesses are dealing with at the moment is the lack of implementation clarity. There are still many open questions on requirements that will start applying in August 2026, such as the PFAS ban, as well as on rules that, while applying later on, will require massive investments, such as some of the packaging bans for 2030.
Many companies are still waiting for key delegated and implementing acts that will determine how certain requirements will work in practice, particularly around recyclability, labelling and reuse.
That uncertainty makes it difficult to plan long-term investment, adapt packaging designs, or align supply-chain data collection processes with confidence. For many companies, the challenge is not a lack of willingness to comply - it is the difficulty of preparing requirements that are still evolving.
Many packaging specialists we speak to are worried about the PPWR, its timings, and its stipulations – what would your message to them be?
Our main message is: get prepared. The PPWR comes with a lot of challenges, but the direction of travel is clear and also presents opportunities. The packaging industry is uniquely positioned to lead this transition by creating new collaborations, developing innovative designs, and becoming true first movers in a changing regulatory landscape.
To support this shift, EUROPEN has developed a suite of publicly available toolkits designed to help operators across sectors better understand the PPWR requirements, including those related to conformity assessment. These resources aim to turn complexity into clarity and help businesses navigate the regulation with confidence.
And there’s more on the way. We are currently preparing a new toolkit that will help packaging specialists to keep track of all secondary legislation - a dynamic space that will continue to evolve as the PPWR is implemented.
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