12 August 2026: Ready or not, here comes the PPWR!
In 37 days (from the date of publication of this newsletter), the Packaging and Packaging Waste Regulation (PPWR) will officially start to apply, turning this long-discussed file into a reality for all economic operators placing packaging or packaging products on the EU market.
That reality, however, is not yet fully defined. In spite of the deadline, important questions remain regarding how manufacturers should demonstrate compliance with several of its key sustainability requirements, notably Article 5(4) and 5(5) on substances in packaging. Nevertheless, from 12 August 2026, manufacturers will be expected to demonstrate conformity with these provisions. Time keeps running. Clarity, not so much.
PPWR Implementation: one down, only 29 to go
With the PPWR set to apply, the focus now shifts to implementation. Around 30 delegated and implementing acts are expected over the coming years to provide the detailed rules needed to put the Regulation into practice. Work is already underway on several of these measures, including those on reuse, minimisation, labelling, recycled content and recyclability.
In terms of delivery, one milestone has been reached: the adoption in May 2026 of the Delegated Decision exempting pallet wrappings and straps from the 100% reuse targets under Article 29(1) and (2). Others, however, remain delayed, notably the Implementing Act on the Register of Producers (Article 44(14)), originally due by 12 February 2026, and the implementing acts on labelling, which while initially expected for August 2026, they are now due Q4 2026.
Looking ahead, attention will turn to the next key milestones, notably the calculation rules on recycled content, which are expected in December, and if you want to stay up to date with the latest developments, don't miss our latest toolkits!
WHAT DID YOU MISS?
20 May 2026: 4th meeting of the PPWR Expert Group
1 July 2026: 5th meeting of the PPWR Expert Group
May - June 2026: publication of EUROPEN toolkits
16 May 2026: publication of the Delegated Decision exempting pallet wrappings and straps from the 100% reuse targets
WHAT'S NEXT?
12 August 2026: entry into application of the PPWR
31 December 2026: publication of the Commission report on substances of concern in packaging
31 December 2026: adoption of the implementing and delegated acts (on the calculation and verification methodology; sustainability criteria and the mirror clause methodology) on recycled content
Q4 2026: adoption of the implementing acts on labelling