EU Packaging Regulation (PPWR) for Exporters: What Applies from 12 August 2026

Who the PPWR affects outside the EU

The PPWR applies to all packaging placed on the EU market, whatever its material and wherever it is made. Its obligations fall on economic operators: the manufacturer, the importer, the distributor and, for extended producer responsibility, the producer. According to the European Commission's guidance, the manufacturer is mainly identified by branding: the company whose name or trade mark appears on the packaging is the manufacturer, even if another company physically makes or fills it, when it decides the packaging's characteristics.

For EPR, the producer is whoever first makes packaging or packaged products available in a Member State. A non-EU company that sells directly to consumers in an EU country, for example through its own webshop or a marketplace, is the producer there and must register and pay EPR fees through an authorised representative. If an EU importer or distributor first makes the goods available, that company usually carries the producer role.

What applies from 12 August 2026

• Heavy metals: the sum of lead, cadmium, mercury and hexavalent chromium in packaging or its components must not exceed 100 mg/kg (Article 5(4)).
• PFAS: food-contact packaging must not contain PFAS above 25 ppb for any single PFAS or 250 ppb for the sum of PFAS measured by targeted analysis, or 50 ppm of total PFAS including polymeric PFAS (Article 5(5)); there is no general sell-off period for packaging first placed on the market after 12 August 2026.
• Conformity: manufacturers carry out the conformity assessment, draw up an EU declaration of conformity and keep the technical documentation for 5 years for single-use packaging or 10 years for reusable packaging.
• Marking: manufacturers show their name, registered trade name or trade mark, postal address and electronic contact on the packaging or, where that is not possible, in an accompanying document; stock made before 12 August 2026 does not need to be re-labelled for this.
• EPR: producers register in each Member State's producer register and, if not established there, appoint an authorised representative for EPR by written mandate (Articles 44 and 45).

What comes next: labels and the 2030 rules

Harmonised labels showing the material composition of packaging, to help consumers sort waste, apply from 12 August 2028, or 24 months after the Commission's implementing act if that is later (Article 12). From 1 January 2030, packaging must be recyclable and meet performance grade A, B or C; grouped, transport and e-commerce packaging may have at most 50% empty space; certain single-use packaging formats listed in Annex V are banned; reuse targets apply to some transport and sales packaging; and plastic packaging must contain minimum shares of recycled content, rising again in 2040.

The Commission and Member States are still adopting implementing and delegated acts, for example on recycled content calculation and design-for-recycling criteria, so check the current guidance before you change packaging designs.

What a non-EU exporter should do

Ask your EU importer which of you is the manufacturer and the producer for each product. If your brand is on the packaging, prepare the declaration of conformity and technical file, test food-contact paper and board for PFAS and coatings for heavy metals, and add your name, postal address and electronic contact to the packaging. If you sell directly to EU consumers, appoint an authorised representative for EPR in every country you sell to and register there before you ship.