PPWR: Associated Packaging Obligations

Yes — if you sell into the EU or Northern Ireland. The PPWR is an EU regulation, so it doesn't apply to sales purely within Great Britain (England, Scotland, Wales). But it does apply the moment your packaging reaches an EU customer or the Northern Ireland market.

From that date, non-compliant packaging can be refused entry, withdrawn, or recalled from the EU or NI market — regardless of where it was manufactured. What's legal under UK packaging rules may not automatically satisfy the PPWR, so it's worth checking your packaging against both frameworks separately.

The retention period depends on the type of packaging: for single-use packaging it is 5 years, and for reusable packaging 10 years – in each case calculated from the date on which the packaging was first placed on the market.

Both the declaration of conformity itself and the underlying technical documentation must be retained so that they can be presented to the market surveillance authorities upon request.

If your brand is on the packaging and you place it on the EU or NI market, you're the manufacturer/producer under the PPWR. In that case, you are obligated to have a Declaration of Conformity per packaging type, product labelling with identification and contact details, and meet the compliance with substance limits.

You'll also specifically need to register as a manufacturer under the PPWR if you use DDP (Delivered Duty Paid) shipping terms, making you the importer of record in the EU, or if you sell directly to EU end customers rather than through an EU-based business.

Yes. The Declaration of Conformity is not a one-off, static document – it must be updated as soon as the product (the packaging) or the underlying legal requirements change.

As the declaration always refers to a specific, clearly identifiable package or a particular type of packaging, a new DoC is required for any change that may affect conformity. This could be the use of a different material or a change to a different packaging format.

However, if you change your print design, you generally do not need a new Declaration of Conformity.

Article 12 of the PPWR (Regulation (EU) 2025/40) already sets out which information packaging must carry, but not yet technical details such as font size or pictogram dimensions. Since 12 August 2026, every piece of packaging must carry an identification feature (e.g. a batch or serial number) along with the manufacturer's name/brand, postal address and contact details – in every language of the markets where the products are sold. This information must be permanently affixed, clearly visible and not easily removable.

From 12 August 2028 at the latest, an EU-wide, harmonised, pictogram-based label for material composition will be added, which must also be understandable for people with disabilities. The exact technical specifications for this – such as size, colours or minimum dimensions – will only be set out by the European Commission in separate implementing acts, expected to be published in 2026/2027.

From 12 August 2026, food contact packaging may no longer be placed on the market if it contains or comes into contact with PFAS (per- and polyfluoroalkyl substances). Packaging not intended for use with food is not, for the time being, affected by the PFAS limit values.

PFAS are classified as ‘forever chemicals’ and hardly degrade naturally at all. They are therefore considered harmful to the environment, as well as to human health.

The following limit values apply:

• 25 ppb for a single PFAS compound

• 250 ppb for the sum of all detected PFAS compounds

• 50 ppm for the total fluorine content of the packaging

If the total fluorine content exceeds 50 ppm, further evidence must be provided as to the origin of the fluorine – in other words, whether it is actually PFAS or a harmless source of fluorine.