When does the PPWR apply and which obligations take effect on 12 August 2026?

Regulation (EU) 2025/40 (PPWR) applies from 12 August 2026. From that date the requirements include: an EU declaration of conformity for each packaging type, PFAS declarations for food packaging, a limit of 100 mg/kg on the sum of heavy metals, the manufacturer’s details on the packaging, and EPR registrations in the countries of sale. There is no transition period.

What is the difference between PIR and PCR recyclate under the PPWR?

PIR is post-industrial regranulate, which does not count towards the recycled content targets in Article 7 of the PPWR. PCR is post-consumer recyclate with proof of origin (e.g. ISCC Plus mass balance certification). Only PCR meets the minimum recycled content requirement: 35% for typical films and 10% for packaging in contact with food from 2030.

Which PPWR requirements take effect from 1 January 2030?

From 1 January 2030 packaging must be recyclable to at least grade C, contain a minimum share of post-consumer recyclate (35% for typical films, 10% for food contact other than PET) and meet the limit of max. 50% empty space, and Annex V formats are banned.

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18 July 2026

Who are you under the PPWR?

On 12 August the PPWR starts to apply, the biggest change in packaging law in 30 years. There is plenty of noise around the subject, but our experience points to one thing: 90% of your PPWR obligations can be worked out by answering a single question. What role do you play in the packaging chain?

Why all the noise, and why not wait?

Regulation (EU) 2025/40 entered into force in February 2025, but it applies from 12 August 2026. The strictest requirements (recycled content levels, recyclability performance grades, bans on specific formats) take effect on 1 January 2030. On top of that come delegated acts, which the European Commission is still working on. Interpretations can shift. One example: in February 2026 the Commission excluded pallet wrappings from the 100% reuse target. Anyone who invested “just in case” spent money on a requirement that ultimately disappeared.

The obligations taking effect on 12 August are certain and come with no transition period. Redesigning a film for the 2030 requirements, on the other hand, takes 12 to 24 months on average.

4 company types, 4 lists of obligations: find your profile

The PPWR assigns obligations by role, not by industry. One company can hold several roles at once, and in that case the requirements for each of them apply.

You pack your own products

Role: manufacturer of packaged products · the widest set of obligations

Sacks, stretch hood, tapes, printed film: the packaging of the goods you sell.

From 12 August 2026

EU declaration of conformity (kept for 5 years), PFAS declarations for food packaging, heavy metals ≤ 100 mg/kg, company details on the packaging, registration in EPR systems

By 1 January 2030

Recyclability of at least grade C, 35% PCR in typical films (10% for food contact), empty space ratio ≤ 50%, phase-out of Annex V formats.

Risk · Gaps in the documentation on 12 August, and the use of multi-material laminates that will not achieve grade C.

You make packaging, and film is your semi-finished product

Role: packaging manufacturer · you issue the Declaration of Conformity (DoC)

The quality of your declaration of conformity depends directly on the data from your film supplier: composition, substances used, and the share and origin of the recyclate. By 2030 the design for recycling requirement is added. In practice this will mainly mean PE/PP mono-materials instead of PET/PE laminates and structures containing aluminium.

Risk · No recyclate under contract. Demand for high-quality feedstock already exceeds supply.

You distribute or buy for resale

Role: distributor · with two traps

Formally the lightest set of obligations: you check the DoC and the labelling before sale. However, launching a private label makes you a manufacturer (the full set of obligations from point 1), and importing products from outside the EU makes you an importer. In our experience this is the most frequently overlooked detail in the whole regulation.

Film is a component in your production

Role: depends on the scenario

Does the film end up in packaging? The obligations are those of a packaging manufacturer (type 2). Is it part of a non-packaging product? Then the product itself is outside the PPWR (but the packaging of your own products is always covered by it). Borderline cases are clarified in the European Commission guidelines of 30 March 2026. It is worth analysing your case formally.

The trap that costs the most: PIR is not PCR

The most expensive mistake in preparing for 2030 is the assumption: “We have recyclate, so we are safe.” It often turns out to be post-industrial regranulate, simply sold as “recyclate”. One word of difference in the specification changes everything:

✕ PIR, post-industrial

Waste from the production process that never reached a consumer. It does not count towards the Article 7 targets.

✓ PCR, post-consumer

Waste generated by consumers, with proof of origin (mass balance, e.g. ISCC Plus). Only PCR meets the 35% / 10% requirement.

Contracting PCR feedstock in 2026-2027 means a higher cost today, but it guarantees stable supply and a choice of terms. Starting in 2029 will mean picking from what is left on the market.

How do we solve this?

We run our own Closed Loop programme, based on our in-house POD ECO regranulation. We collect film waste directly from the customer and return it to their own film, with full documentation of the material flow.

Reality check: 3 questions for today

Who are you under the PPWR for each of your markets and products? Roles can overlap.
Do you have all the documents ready for 12 August? DoC, PFAS for food contact, heavy metals, details on the packaging, EPR.
Which of your formats will not meet the 2030 requirements? Laminates below grade C, Annex V formats, films without guaranteed access to PCR.

ProblemYour answer to one of the questions above is “I don’t know”, and on 12 August the declarations must be in your documentation.

SolutionDownload the guide “The PPWR in practice. Roadmap 2026-2040” (PDF in Polish) for your type of company, or write to us using the form below the article. Tell us what you use our films for.

ResultYou will receive a personalised list: the requirements for your role, an overview of the ready-made documents we supply, and an action plan up to 2030.

Guide “The PPWR in practice. Roadmap 2026-2040”

9 pages of concrete knowledge: separate chapters cover each company type, with an action schedule and a 2025-2040 calendar.

Download the guide (PDF in Polish)

This material is for information only and does not constitute legal advice. Dates and thresholds come from Regulation (EU) 2025/40 and the European Commission’s guidelines and FAQ (as of July 2026); some deadlines depend on delegated acts and may change.

See what this looks like in your industry: Printers and converters and FMCG and food processing. On each page: what goes wrong, what we calculate instead of price per kg, and implementations with figures.

Read more about the PPWR in practice: Pallet wrap stays: what still applies from 2030 and The packaging fee from 2027: what a kilogram of film costs.

About the author

Radosław Koperski

R&D, Kablonex

Designs formulations and structures of multilayer PE films for specific industrial applications: stretch hood (including with PCR content), films for automatic FFS lines and shrink films. He validates every solution on customers’ packaging lines. He has worked in the film and packaging industry for almost 20 years, previously as Packaging Development Manager at PDO (Pałucka Drukarnia Opakowań). His starting point is always the real application: the product, the machine, transport and storage.

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