PPWR is in force: the packaging paperwork you owe since 12 August 2026
The EU Packaging and Packaging Waste Regulation - Regulation (EU) 2025/40, better known as PPWR - has applied since 12 August 2026. Most coverage focuses on recyclability targets and the coming harmonised label. But the obligation that already binds every producer today is quieter: paperwork. Since that date, every packaging type placed on the EU market needs a signed Declaration of Conformity backed by technical documentation - even when the packaged product needs no Digital Product Passport.
What is required right now
Two documents, per packaging type:
- The EU Declaration of Conformity (DoC) - Article 39. A signed statement, following the model in Annex VIII, that the packaging meets the requirements of Articles 5 to 12 that apply to it at the time. Today that is mainly the substances-of-concern rules (Article 5) and, where reusability is claimed, the reusable-packaging conditions (Article 11); the recyclability-design, recycled-content and minimisation duties phase in from 2030.
- Technical documentation - Annex VII. The evidence file behind the signature: what the packaging is, its materials and weights, and how each applicable requirement is met. The DoC is the one-page claim; the technical file is the proof.
Both must exist before the packaging is placed on the market, and both must be kept - 5 years for single-use packaging, 10 years for reusable packaging, counted from the date the packaging was placed on the market (Article 15). For a packaging type you keep selling, that means the file stays alive for as long as you sell it, plus the retention period. Manufacturers draw the documents up. Importers must check that the assessment was done and the technical file exists (Article 18); distributors check labelling, producer registration and the identification details (Article 19). A national authority can demand the file on reasoned request (Article 15(10)), with market surveillance under Regulation (EU) 2019/1020.
What is NOT required yet - the part most companies get wrong
- The harmonised material-composition label (Article 12) is not in force. It depends on Commission implementing acts that were due by 12 August 2026 and have not been adopted; a draft has circulated since January 2026, and adoption is now expected in late 2026 or 2027. The label then applies 24 months after the acts enter into force, and never before 12 August 2028 - in practice late 2028 at the earliest, more likely 2029. Anyone selling you a “PPWR-compliant label” today is selling a guess at a specification that is not yet final.
- PPWR does not require a Digital Product Passport. Where a product already has a DPP under other EU law, the regulation’s preamble says that passport “should also be used” for the packaging information - but packaging alone never triggers a passport. Even the first mandatory DPP, the battery passport arriving 18 February 2027, will not carry packaging data when it launches: its content list has no packaging fields.
The dates that matter
| Obligation | Applies from |
|---|---|
| DoC + technical documentation (Arts. 15, 38, 39; Annexes VII and VIII) | 12 August 2026 - in force |
| Harmonised material-composition label (Art. 12(1)) | 12 August 2028 or 24 months after the implementing acts, whichever is later - realistically 2029 |
| Reusable-packaging label + QR code (Art. 12(2)) | 12 February 2029 or 30 months after the implementing act, whichever is later |
| Substances-of-concern digital marking (Art. 12(1) and (7)) | after the Commission’s methodology, itself due by 1 January 2030 |
Five things to do this quarter
- Inventory your packaging types. The duty is per type, not per shipment.
- Compile the Annex VII file for each type - materials, weights, recycled content, the evidence for each applicable Article 5-12 requirement.
- Draw up and sign the Annex VIII DoC for each type.
- Set up retention - 5 or 10 years from placing on the market; for packaging still in production the clock keeps moving while you sell.
- Be ready to hand it over as one bundle when an authority asks.
Where a platform helps
This is document discipline at scale - dozens of packaging types, each with a version history and an audit trail. The Soverio DPP Platform keeps a packaging conformity record per type: your Declaration of Conformity and Annex VII documentation, versioned, retained, and exportable as a single bundle when a market-surveillance authority asks. And where your product does require a DPP, the packaging information lives alongside it - as the regulation intends.
Frequently asked questions
Does PPWR require a Digital Product Passport?
No. Packaging data goes into a DPP only where the product already has one under other EU law.
Do I need the new packaging label yet?
No - the implementing acts are not yet adopted. Expect late 2028 at the earliest, more likely 2029, and watch the acts.
Which packaging needs a DoC?
Every packaging type placed on the EU market since 12 August 2026.
How long must I keep the documents?
5 years (single-use) or 10 years (reusable), counted from when the packaging was placed on the market.
Source: Regulation (EU) 2025/40. This article reflects the state of the implementing acts as of September 2026.
Need help with your packaging paperwork? Talk to us - or start on the free plan on the DPP Platform pricing page.