Implementation of the new EU’s Packaging and Packaging Waste Regulation (PPWR) 

Implementation of the new EU’s Packaging and Packaging Waste Regulation (PPWR) 

The cross-horizontal EU’s Packaging and Packaging Waste Regulation (PPWR) has become partly applicable as of 12 August, but many challenges and questions remain. The PPWR introduces new requirements gradually like the need for authorised representative or Declaration of Conformity from the 12^th of August and minimum percentages of post-consumer recycled content from 2030. A series of implementing acts is currently being developed and issued. In addition, a simplification regulatory proposal as part of Omnibus VIII, aimed at temporarily suspending the application of the rules on the appointment of an authorised representative for EPR, has already been published. 

A few members have reported difficulties navigating the complex PPWR requirements and the additional administrative burden they may create. Discussions on practical implementation issues are ongoing within the IBCA PG.  

We would therefore like to share with you a series of publicly available resources to assist you in navigating the provisions of the Regulation. We will continue to follow this topic and explore potential ways to inform and assist you, where possible. In this context, IBMA will draft a contribution to the ongoing call for evidence reflecting the implementation challenges with the regulation and the future challenge with the proposed recycling approach.  

Regulation  

Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC: https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng 

Guidance and Frequently Asked Questions 

PPWR European Commission Guidance to support implementation of new packaging rules: https://ec.europa.eu/commission/presscorner/detail/en/ip_26_664 

PPWR European Commission Frequently Asked Questions (EU COM Website – published August 2026): https://op.europa.eu/en/publication-detail/-/publication/ad14cb8f-8d4f-11f1-9262-01aa75ed71a1 

Some points of attention: 

• Mandatory Declaration of Conformity (applicable now) 

• Nomination of an EPR representative in each Member State (applicable now) 

In a Linkedin communication on its EU environment and Climate page, the European Commission stated the following “[…] The Commission recognises that the requirement for some producers to appoint an authorised representative for EPR purposes could create unnecessary costs and complexity, particularly for smaller businesses selling across borders. The Commission has therefore proposed suspending this requirement until 2035, while a simpler and more proportionate solution is developed. What happens while this is being discussed? The proposal is now going through the legislative process. The Commission has called on national authorities to take a constructive and pragmatic approach to compliance while the proposed simplification is being negotiated” 

European Commission Proposal on suspending the application of the rules on the appointment of an authorised representative for EPR (as part of Omnibus VIII – Environment) – European Parliament legislative train, Status as of 20 June 2026 (Link) & EU COM Proposal (Link) 

Noncompliance with the new rules 

We refer to point XVI “Enforcement of the new rules” from the Commission FAQ. In this document, the Commission favors avoiding a disruption of trade flows, supply chains or consumer access to goods, and promote a progressive and supportive approach on enforcement rather than immediate sanctions (read the Commission FAQ  – Link)  

Applicable at a later stage  

Major requirements on recyclability, recycled content, packaging reduction and reuse will apply progressively, with many key requirements applying from 2030 onwards: we attract our member’s attention on some of these provisions since packaging is part of the registration dossier. See the ongoing calls for evidence:  

Free access tools to assist in the implementation of the PPWR:  

Note: the following links are provided for information purposes only, and IBMA declines any responsibility for the quality or accuracy of the resources. These resources can be considered as guides presenting educated advice and are in no way a substitute for legal advice. 

Free webinar – Understanding the PPWR. Shaping the Circular economy (by RIGK, 30 September 10:00 – 11:30 CET) https://www.rigk.de/en/rigkwebinarhub. The webinar will be conducted in German, but the organisers will make a recording of this webinar available to all participants, including English subtitles – so please feel free to register anyway to receive this afterwards. 

PPWR Survival Guide (Europen) https://www.europen-packaging.eu/publication/europens-ppwr-survival-guide/ and a PPWR Guide Book (including a questionnaire on how does PPWR applies to your business) https://www.ppwr-guidebook.eu/ and timeline for upcoming secondary legislations: https://www.ppwrtracker-europen.eu/ 

PPWR navigator (by Syncforce private company) – define your packaging level and your specific role and obligations under the regulation https://ppwr-navigator.syncforce.com/ 

Mastering PPWR Declaration of conformity – Practical Guide (by Recyda, private company, includes add for services) – https://www.recyda.com/resources/reports/ppwr-declaration-of-conformity-example#form