The EU packaging regulation — Regulation (EU) 2025/40, generally called the PPWR — has applied since 12 August 2026. It replaces the old Packaging and Packaging Waste Directive regime. Because it is a regulation rather than a directive, it applies directly, and national transposition no longer sits between you and the text.
It was adopted on 19 December 2024, published in the Official Journal on 22 January 2025 and entered into force on 11 February 2025. General application began on 12 August 2026. That date has passed, so the question is no longer what is coming; it is what you are already subject to.
What actually started applying on 12 August 2026
- The PFAS restriction in food-contact packaging (Art. 5(5)). There is no stock-exhaustion period, so non-compliant stock could not simply be sold through
- A heavy-metal limit of 100 mg/kg for lead, cadmium, mercury and hexavalent chromium combined (Art. 5)
- New role definitions in Article 3 — manufacturer, importer, distributor, producer and fulfilment service provider — replacing the national definitions you may have worked to before
- The documentation chain: manufacturer conformity assessment, technical documentation and EU declaration of conformity (Art. 15); importer verification and contact marking (Art. 18); distributor duties (Art. 19); fulfilment service provider duties (Art. 20)
- Extended producer responsibility: the register of producers under Article 44, and Article 45, including the authorised representative obligation in Article 45(3)
Of that list, the PFAS restriction is the only item that can make existing stock unsellable overnight, because there is no sell-through period. It bites hardest on grease-resistant paper and board and on moulded fibre used for food. If you put anything edible into packaging you did not specify yourself, ask your supplier for written confirmation rather than assuming.
The heavy-metal limit is a combined 100 mg/kg across the four substances. Mainstream European packaging is generally well inside it, but that is an observation about typical supply, not a guarantee about yours. Printed, coloured and metallised components are where the risk concentrates, and the answer comes from your supplier's documentation, not from inspection.
What did not change in 2026
No new label became mandatory. No empty-space rule took effect. No recycled-content minimum applied. No single-use format was banned. Packaging minimisation continues to be assessed against EN 13428:2004 until 31 December 2029. If your packaging was lawful on 11 August 2026, nothing about its design made it unlawful the next day.
The most common misreading of August 2026 is that e-commerce boxes suddenly had to be at least half full. They did not. That rule sits in Article 24 and applies from 1 January 2030 at the earliest. What genuinely started in 2026 is EPR registration, and that is the obligation most small sellers are actually in breach of.
The dates that will change your packaging: 2028 and 2030
- Harmonised labelling — material pictograms and sorting information, Art. 12(1) — from 12 August 2028, or 24 months after the implementing act, whichever is later
- Reusable-packaging labelling, Art. 12(2), from 12 February 2029, or 30 months after the implementing act, whichever is later
- Maximum 50% empty space in grouped, transport and e-commerce packaging, with a ban on false bottoms and illusory volume, Art. 24, from 1 January 2030, or three years after the implementing act, whichever is later
- Design for recycling, Art. 6, from 1 January 2030 or 24 months after the delegated act; recyclable at scale from 1 January 2035; grade B minimum from 1 January 2038
- Recycled content in plastic packaging, Art. 7, from 1 January 2030: 30% for contact-sensitive PET other than beverage bottles, 10% for other contact-sensitive plastics, 30% for single-use plastic beverage bottles and 35% for all other plastic packaging, rising on 1 January 2040 to 50%, 25%, 65% and 65%
- Bans on certain single-use formats listed in Annex V, Art. 25, from 1 January 2030, including shrink-wrap grouping multipacks, plastic packaging for fresh produce under 1.5 kg, single-use plastic for on-premises consumption in hospitality, condiment, sugar and creamer sachets in hospitality, hotel miniatures and very lightweight plastic carrier bags
- Reuse targets, Art. 29, from 1 January 2030: transport packaging 40%, and 100% for movements within one operator and between operators in the same Member State; grouped packaging 10%; beverages 10%. In 2040 these become 70%, 25% and 40%
One caveat runs through that whole table. The Article 6, 12 and 24 dates are conditional on implementing or delegated acts, and we could not confirm those acts as adopted at the time of writing. Under the whichever-is-later formula, these dates can move later but never earlier. Plan for the stated date and treat slippage as a bonus, not as a strategy.
Penalties are national, and mostly not written yet
PPWR itself sets no fine amounts. Article 68 requires Member States to lay down penalty rules and notify the Commission by 12 February 2027, and breaches of Articles 24 to 29 must carry administrative fines. So the numbers that will eventually apply to you are national, and in most Member States they are still being drafted.
That is not a grace period. National packaging regimes that already exist are unaffected and are being enforced right now — Germany's is the obvious example, and it is unforgiving. The absence of a PPWR penalty schedule tells you nothing about your exposure in a country that already has one.
There was press reporting in August 2026 (Brussels Signal, citing an unnamed senior EU official quoted in Die Welt) that the Commission was encouraging Member States not to apply the new rules aggressively and to prioritise warnings over penalties in the initial period. That is a press report of an informal position. It is not a legal instrument, it suspends nothing, and it has no bearing on national regimes.
If someone else warehouses and ships for you
Article 20 applies from 12 August 2026 and covers fulfilment service providers: businesses that warehouse, pack, address or ship goods they do not own. In substance, an FSP may only offer its services where the manufacturer or importer has met its obligations under Articles 15 and 18 respectively. The duty is to verify upstream compliance, not to assess conformity independently. We could not verify the exact wording of Article 20, so treat this as the shape of the duty rather than a quotation.
A fulfilment provider is not automatically the producer. The producer is whoever first makes the packaging available in that Member State — the seller, not the warehouse. But the gatekeeping duty has teeth. Expect your 3PL to start asking for register numbers per destination country and evidence of system participation, with a documented right to refuse service if you cannot produce them. In Germany that is already the position: under section 9(5) of the VerpackG, a fulfilment provider that ships for an unregistered client commits the offence itself.
You may not need any of this
If your business sells services and never puts a physical good into a box, packaging law does not apply to you at all. No register, no report, no excise, no representative. Consulting, software, agency work, training and design generate no packaging obligations, however much EU regulatory news crosses your desk.
If you do ship goods, the obligation that actually bites in 2026 is not packaging design. It is registration. Being registered in the Estonian pakendiregister, and in the equivalent register of every country your parcels reach, is what gets checked first and is where most small sellers are genuinely exposed.
A sensible order of work
- Get written confirmation from suppliers that food-contact packaging is PFAS-free and that heavy metals are within the 100 mg/kg limit
- Collect and keep the documents: declarations of conformity from manufacturers, and your own importer verification where you bring goods in from outside the EU
- Check your EPR registration in Estonia and in every country you ship to, and treat this as the urgent item rather than the design questions
- Ask your fulfilment provider what evidence it will require, before it asks you
- Diarise 2028 and 2030 with a review a year ahead of each, by which point the implementing acts should be known
None of this needs to be done in a panic. Most of it needs to be done once, written down, and kept where the next person can find it.
Frequently asked questions
What changed in the EU packaging rules on 12 August 2026?
The PFAS restriction in food-contact packaging, the 100 mg/kg heavy-metal limit, the new Article 3 role definitions, the conformity documentation chain and the EPR obligations in Articles 44 and 45. Packaging design rules did not change on that date.
Does the 50% empty space rule apply now?
No. The maximum 50% empty space rule for grouped, transport and e-commerce packaging is in Article 24 and applies from 1 January 2030, or three years after the relevant implementing act, whichever is later.
What is the PFAS restriction in packaging?
Article 5(5) restricts PFAS in food-contact packaging and has applied since 12 August 2026. There is no stock-exhaustion period, so non-compliant stock cannot be sold through. It matters most for grease-resistant paper, board and moulded fibre.
Do I need new packaging labels in 2026?
No. Harmonised labelling under Article 12(1) applies from 12 August 2028, or 24 months after the implementing act, whichever is later. That date depends on an implementing act and can move later but not earlier.
Does the EU packaging regulation apply to a service business?
No. If you never place a physical packaged good on the market, you have no packaging obligations at all. The regulation applies to packaging, not to companies in general.
What are the penalties under the PPWR?
The regulation sets no amounts. Article 68 requires Member States to lay down penalty rules and notify the Commission by 12 February 2027. Existing national regimes, such as Germany's, apply now and are enforced independently of this.
TagsEU packaging regulationPPWRe-commerce packagingPFAS packaging
General information, not tax advice
This article reflects Estonian law as it stands on the date shown. Rules change and individual circumstances differ - confirm your own position with us before acting.