EU Packaging Regulation — applying since 12 August 2026
Which of the new EU packaging rules bind you today, and which cannot be calculated yet
Regulation (EU) 2025/40 replaced the 1994 packaging directive on 12 August 2026. Some of it applies in full right now: the PFAS and heavy-metal limits, the technical file, the declaration of conformity, producer registration. Other parts — recycled content, recyclability grades, the harmonised label — name a percentage but not the method for calculating it, because the Commission has not adopted it yet. This platform keeps those two groups apart and tells you which is which, packaging by packaging.
When an authority writes to you, Article 15(10) gives you a short window to hand over the technical file, the declaration and the supporting evidence. Assembling that under time pressure is the failure most operators can already see coming — and it needs no pending EU decision to fix.
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Dashboard
Meridian Packaging BV · DE, FR · rule set 2026.08
Portfolio
Packaging configurations
34
Active
Blocking non-compliance
2
Article 4(1) — may not be made available
Action required
9
A step of yours is outstanding
Missing supplier data
6
Article 16
Declarations outstanding
4
Article 62(1)(a)
Incomplete technical files
7
Article 62(1)(d)
Registrations not made
1
Article 44(4)
Awaiting an EU method
5
A count of obligations — not a percentage
Needs attention
Anything that blocks sale is listed first, then everything else.
| State | Packaging | Obligation | Owner | Due | Action |
|---|---|---|---|---|---|
Non-compliant | CFG-1042 · 500 ml PET bottle | Article 5(5)(a) — PFAS in food-contact packaging | Packaging Specialist | Immediate | Replace the barrier coating |
Non-compliant | CFG-2210 · Single-serve sauce sachet | Article 25(1), Annex V pt. 4 — single portions in hospitality | Product Management | 1 Jan 2030 | Plan a format change |
Action required | CFG-1042 · 500 ml PET bottle | Article 44(2) — producer registration, FR | Compliance Manager | Immediate | Register with the national scheme |
Information missing | CFG-3388 · Board grouping pack | Article 16 — supplier information | Procurement | 12 Oct 2026 | Chase the material declaration |
Action required | CFG-1042 · 500 ml PET bottle | Annex VII — technical documentation incomplete | Compliance Manager | 26 Sep 2026 | Attach the heavy-metal test report |
Conditionally compliant | CFG-3388 · Board grouping pack | Article 5(4) — heavy metals | Quality | — | Confirm the supplier statement with a test |
Waiting on the Commission, not on you
These obligations apply, but the method for judging them has not been adopted. They are counted separately so they never sit in anyone's task list.
| Ref | Obligation | Expected instrument | Due | Status | Packagings |
|---|---|---|---|---|---|
| U-03 | Recycled content, Article 7(1) | Implementing act, Article 7(8) | 31 Dec 2026 | Not adopted | 18 |
| U-07 | Design for recycling, Article 6(2)(a) | Delegated acts, Article 6(4) | 1 Jan 2028 | Not adopted | 34 |
| U-11 | Empty space ratio, Article 24(1) | Implementing acts, Article 24(2) | 12 Feb 2028 | Not adopted | 12 |
| U-15 | Producer register format, Article 44(1) | Implementing act, Article 44(14) | 12 Feb 2026 | Overdue | 34 |
| U-18 | Harmonised label, Article 12(1) | Implementing acts, Articles 12(6), 12(7) | 12 Aug 2026 | Overdue | 34 |
Every packaging material, every EU market
- PET
- HDPE
- Paper and board
- Glass
- Aluminium
- Steel
- Composites
- Wood
Obligations that have applied since 12 August 2026
PFAS in food-contact packaging
Article 5(5)
25 ppb / 250 ppb / 50 ppm
Heavy metals
Article 5(4)
≤ 100 mg/kg combined
Technical documentation and declaration
Articles 38, 39, Annex VII
Required before placing on the market
Producer registration
Article 44(2), 44(4)
Per Member State
Design features that only look bigger
Article 10(2), Annex IV
Double walls, false bottoms
Environmental claims
Article 14
Only beyond the legal minimum
Operator roles and duties
Articles 15–22
Including the Article 21 brand shift
Extended producer responsibility
Article 45(1), 45(3)
Representative for cross-border producers
None of these wait on a pending Commission act.
8
Obligation headings that can be assessed today. The eight above, in full, without waiting for anything.
11
Headline dates written as formulas rather than calendar dates. None of their anchor acts had been adopted at the 1 September 2026 source review.
4
Commission acts past their own deadline: the register format and the three labelling acts.
Figures and article references reflect a source review dated 1 September 2026. Every legal statement on this page carries its article, its source and that retrieval date.
Modules
A screen for each question the Regulation asks
PPWR compliance is not one task. First the packaging has to be broken into the parts the law actually judges, then it has to be decided which rules reach those parts at all, and only then can anything be assessed. Each module below is one step in that chain, and each is a real screen in the product.
See where you are blocked, in counts rather than percentages
No score, no gauge. A packaging either meets a rule or it does not, so the dashboard counts packagings by state and puts the two kinds of blocked work side by side: what is waiting on you, and what is waiting on Brussels.
- Counts by compliance state, never averaged into a single figure
- Deadlines with a fixed date, separated from those still written as formulas
- A standing panel for obligations whose EU method has not been adopted
Dashboard
Meridian Packaging BV · DE, FR · rule set 2026.08
Portfolio
Packaging configurations
34
Active
Blocking non-compliance
2
Article 4(1) — may not be made available
Action required
9
A step of yours is outstanding
Missing supplier data
6
Article 16
Declarations outstanding
4
Article 62(1)(a)
Incomplete technical files
7
Article 62(1)(d)
Registrations not made
1
Article 44(4)
Awaiting an EU method
5
A count of obligations — not a percentage
Needs attention
Anything that blocks sale is listed first, then everything else.
| State | Packaging | Obligation | Owner | Due | Action |
|---|---|---|---|---|---|
Non-compliant | CFG-1042 · 500 ml PET bottle | Article 5(5)(a) — PFAS in food-contact packaging | Packaging Specialist | Immediate | Replace the barrier coating |
Non-compliant | CFG-2210 · Single-serve sauce sachet | Article 25(1), Annex V pt. 4 — single portions in hospitality | Product Management | 1 Jan 2030 | Plan a format change |
Action required | CFG-1042 · 500 ml PET bottle | Article 44(2) — producer registration, FR | Compliance Manager | Immediate | Register with the national scheme |
Information missing | CFG-3388 · Board grouping pack | Article 16 — supplier information | Procurement | 12 Oct 2026 | Chase the material declaration |
Action required | CFG-1042 · 500 ml PET bottle | Annex VII — technical documentation incomplete | Compliance Manager | 26 Sep 2026 | Attach the heavy-metal test report |
Conditionally compliant | CFG-3388 · Board grouping pack | Article 5(4) — heavy metals | Quality | — | Confirm the supplier statement with a test |
Waiting on the Commission, not on you
These obligations apply, but the method for judging them has not been adopted. They are counted separately so they never sit in anyone's task list.
| Ref | Obligation | Expected instrument | Due | Status | Packagings |
|---|---|---|---|---|---|
| U-03 | Recycled content, Article 7(1) | Implementing act, Article 7(8) | 31 Dec 2026 | Not adopted | 18 |
| U-07 | Design for recycling, Article 6(2)(a) | Delegated acts, Article 6(4) | 1 Jan 2028 | Not adopted | 34 |
| U-11 | Empty space ratio, Article 24(1) | Implementing acts, Article 24(2) | 12 Feb 2028 | Not adopted | 12 |
| U-15 | Producer register format, Article 44(1) | Implementing act, Article 44(14) | 12 Feb 2026 | Overdue | 34 |
| U-18 | Harmonised label, Article 12(1) | Implementing acts, Articles 12(6), 12(7) | 12 Aug 2026 | Overdue | 34 |
Every configuration, every market it goes to
A packaging configuration is the unit the law judges — the pack as sold, in the markets it is sold in. The list carries the levels it contains, the countries it reaches and where its file and declaration stand.
- Primary, grouped and transport levels held as one configuration
- Per-market chips, because obligations follow the country
- File and declaration status visible without opening the pack
Bill of materials
CFG-1042 · 500 ml PET bottle
| Component | Attachment | Separates by hand | Weight | Share | Material |
|---|---|---|---|---|---|
| C-1 · Bottle body | Integrated | No | 19.2 g | 77.4 % | PET |
| C-2 · Closure | Integrated | Yes | 2.9 g | 11.7 % | HDPE |
| C-3 · Sleeve label | Separate | Yes | 1.8 g | 7.3 % | PET-G |
| C-4 · Barrier coating | Integrated | No | 0.9 g | 3.6 % | Fluoropolymer |
Weight roll-up
24.8 g of components against 24.8 g declared — balanced.
A bill of materials that does not balance cannot support a declaration, so the check runs before anything is assessed rather than after.
Composite resolution
Dominant material: PET, 77.4 % by weight
Annex II Table 4 assigns a composite to its heaviest material. The share is shown because the assignment changes if a component's weight changes.
Assessment modes this structure supports
- Per unit
- 24.8 g
- Per component
- 4 components
- Per material
- 4 materials
PreparatoryThe Annex II Table 4 design parameters are collected now, years before a methodology exists to evaluate them. When one lands, this becomes a re-run rather than a fresh data campaign under deadline pressure.
Unit, component, material, substance — with the weights adding up
Article 6(9) assesses packaging by its parts, so the platform holds it that way. Weights roll up and are checked against the declared total, because a bill of materials that does not balance cannot support a declaration.
- Four levels, each with its own evidence and source
- Roll-up validation against the declared unit weight
- Composite materials resolved per Annex II so the dominant material is explicit
Applicability
CFG-1042 · 500 ml PET bottle · DE, FR
Roles derived for this packaging
Manufacturer
Article 3(1)(13)(a)
You make the packaging and market it under your own name.
Producer
Article 3(1)(15)
You are the first to make it available in DE and in FR, so registration applies in both.
- Article 5(5)PFAS limits in food-contact packagingFood contact · applies since 12 Aug 2026
- Article 5(4)Heavy metals, 100 mg/kg combinedAll materials
- Articles 38, 39Conformity assessment and declarationBefore placing on the market
- Article 44(2)Producer registration in DE and FRPer Member State
- Article 25(1)Annex V format restrictions1 Jan 2030
- Article 6(3)Only recyclability grades A or B1 Jan 2038
- Article 7(2)2040 recycled-content tier1 Jan 2040
- Article 24(4)Empty space reduced to the minimum necessary12 Feb 2028
- Article 7(1)Minimum recycled contentNot before 1 Jan 2030 · awaiting Article 7(8)
- Article 6(2)(a)Design for recyclingNot before 1 Jan 2030 · awaiting Article 6(4)
- Article 24(1)Empty space ratio, 50 %Not before 1 Jan 2030 · awaiting Article 24(2)
- Article 12(1)Harmonised material-composition labelNot before 12 Aug 2028 · awaiting Article 12(6)
- Article 29(6)Beverage re-use target for final distributorsYou are not a final distributor
Would apply ifYou start selling direct to consumers. The target then attaches to you as final distributor, and 10 % of beverages would have to be in reusable packaging from 1 January 2030.
- Article 32Bring-your-own-container refillHospitality obligation
Would apply ifYou open a point of sale serving drinks for immediate consumption. The refill option would then be required from 12 February 2027, at no extra cost to the customer.
- Article 44(2)Producer registration in ItalyYou do not make packaging available there
Would apply ifYour first shipment to Italy creates the registration duty on the same day, and Article 44(4) prohibits making packaging available before it is done.
- Article 7(1)Recycled content — sleeve labelC-3, 1.8 g, 7.3 % of unit weight
Excluded byArticle 7(5)(b) excludes plastic parts lighter than 5 % of the packaging's total weight. The share is shown because the exclusion falls away if the component or the unit weight changes.
Knowing why a rule does not reach you is worth as much as knowing that it does — it is the part an inspector asks about, and the part that changes when your business does.
Which rules reach this packaging, and which do not
Before anything is judged, the platform works out what applies. Rules that do not apply are shown with the reason — and, where useful, with what would have to change for them to apply. Knowing you are outside a rule because of a role you do not hold is worth having in writing.
- Applies, applies later, conditional, does not apply, excluded, exempt
- 'Would apply if' spelled out, so scenario planning is possible
- The exclusion or exemption that produced the answer is named
Article 5(5)(a)
Subject: CFG-1042 · C-4 barrier coating
What the law says
Packaging shall not be placed on the market if it contains per- and polyfluoroalkyl substances (PFAS) in concentrations equal to or above 25 ppb for any PFAS, 250 ppb for the sum of PFAS, or 50 ppm for PFAS including polymeric PFAS, where the packaging is in contact with food.
Regulation (EU) 2025/40, EUR-Lex · retrieved 1 Sep 2026Open source
Why it applies here
- Is the packaging in contact with food?
- Yes — beverage, direct contact
- Does any component contain PFAS?
- Yes — C-4, fluoropolymer coating
- Measured concentration against the 25 ppb single-substance limit
- 31 ppb — above
- Is there an exemption for this use?
- None in the Regulation
Non-compliant. The packaging may not be placed on the market in this configuration.
What you hold
| PFAS, single substance | 31 ppb | Measured | Accredited laboratory, report LAB-4471, 14 Aug 2026 |
| PFAS, sum | 88 ppb | Measured | Same report — below the 250 ppb limit |
| Total fluorine | 62 mg/kg | Supplier statement | Above 50 mg/kg, so Article 5(5) proof duty falls on the upstream actor |
When
Applies since 12 August 2026. This is a fixed date and depends on no pending act.
The single-substance limit is exceeded by the barrier coating alone. Two suppliers offer a non-fluorinated barrier for this bottle; a specification comparison is attached to the task.
Rule PPWR-5-5-A v3 · rule set 2026.08 · assessed 1 Sep 2026
The verdict, with the law next to it
Each assessment shows what the law says in its own words, why it applies to this packaging, what you hold, and — where relevant — why nothing can be determined yet. That last block is the one competitors skip.
- Quoted article text with its source and retrieval date
- The inputs used and where each came from
- The rule version the verdict was reached under, bound permanently
Compliance by market
4 configurations × 3 markets
| Configuration | Germany | France | Netherlands |
|---|---|---|---|
| CFG-1042 · 500 ml PET bottle | Non-compliant PFAS | Non-compliant PFAS · registration | Out of scope Not sold |
| CFG-3388 · Board grouping pack | Information missing Supplier data | Information missing Supplier data | Out of scope Not sold |
| CFG-2210 · Sauce sachet | Non-compliant Annex V from 2030 | Out of scope Not sold | Out of scope Not sold |
| CFG-4501 · Reusable crate | Compliant — | Compliant — | Action required Registration |
Why a cell, not a score
The Regulation is uniform but registration, reporting and penalties are national. The same packaging can be sellable in one Member State and not in another, and a single figure would hide exactly that.
A register of what nobody can calculate yet
Obligations whose method the Commission has not adopted are tracked in their own right: what is missing, which instrument is expected, when it was due, and when the source was last checked. These items are not spread through your task list as though they were yours to close.
- The expected instrument and its legal deadline
- Whether the deadline has already passed
- The date the Official Journal was last reviewed for it
Supplier data request
Atlantique Carton SA · CFG-3388
Built from the gaps, not from a template
Seven questions, each generated because a specific field is missing for this packaging. Questions that would have been asked by a standard questionnaire but are not needed here were dropped, and the reason is shown below.
| Question | Legal basis | Evidence required |
|---|---|---|
| Total heavy-metal content, sum of Pb, Cd, Hg and Cr(VI)C-5 | Article 5(4)Certainty A | Test report |
| Is any substance of concern present above the reporting threshold?C-5Preparatory | Article 5(1)Certainty C | Declaration |
| Fibre composition and coating typeC-5 | Annex IICertainty A | Specification |
| Component weight as suppliedC-5 | Article 6(9)Certainty A | Specification |
| Adhesive chemistry and whether it separates in a standard pulping processC-6Preparatory | Article 6(2)(a)Certainty B | Declaration |
| Post-consumer recycled content, with the chain-of-custody scheme namedC-5Preparatory | Article 7(1)Certainty B | Scheme certificate |
| Collection region of the recovered fibreC-5Preparatory | Article 7(3)Certainty B | Declaration |
- Supplier
- Atlantique Carton SA
- Country
- France
- Union established
- Yes — Article 16 applies
- Components supplied
- C-5 board, C-6 adhesive
Not asked, and why
A fixed questionnaire would have sent these anyway. Asking for data that no rule needs costs you supplier goodwill and buries the questions that matter.
PFAS content
This component is not in food contact — Article 5(5) does not reach it
Compostability certification
Not an Article 3(1)(1)(f) format
Two of the seven questions serve obligations whose EU method is not adopted. They are marked preparatory: the answers are stored as inputs, not used to produce a verdict.
Each answer lands against the field it fills, with its evidence attached, so the assessment updates without anyone re-keying it.
Configuration against Member State
The Regulation is uniform but the filing is national. The matrix puts every configuration against every market you sell into, so a gap that exists in one country and not another is visible rather than averaged away.
- One cell per configuration and country
- Registration, reporting and documentation tracked separately
- Country reference data carries its own source and retrieval date
Technical documentation
CFG-1042 · Annex VII
Shown as elements rather than a percentage, and worded the way Article 62(1)(d) words it — an incomplete file is a finding in its own right, not a partial pass.
| Annex VII element | State | Source |
|---|---|---|
| General description of the packaging | Compliant | Configuration record |
| Intended use and packaged product | Compliant | Configuration record |
| List of materials and components | Compliant | Bill of materials |
| Design drawings and manufacturing information | Compliant | Uploaded, 12 Aug 2026 |
| Substance restrictions — test results | Action required | Heavy-metal report missing |
| Recyclability assessment | Method pending | Article 6(4) criteria not adopted |
| Recycled content documentation | Method pending | Article 7(8) method not adopted |
| Standards and specifications applied | Compliant | None cited — Article 36 gives no presumption |
Annex IV — minimisation criteria
These are design tests you can run today. They need no adopted methodology, which makes them the part of the file most likely to be examined first.
- Protection of the packaged productCompliant
- Manufacturing process requirementsCompliant
- Logistics requirementsCompliant
- Information and labelling requirementsCompliant
- Consumer acceptance and safetyCompliant
- Legal requirements on the packaged productCompliant
- No double walls or false bottomsNon-compliant
- No unnecessary layersCompliant
One criterion fails. Article 10(2) prohibits features whose only purpose is to increase perceived volume.
Article 15(10) gives you a short window to hand over the file, the declaration and the supporting evidence after a competent authority asks. The dossier is assembled from what is already here, in one action.
Requests built from the gaps, not from a template
The data you need from a supplier follows from what the applicability engine decided, so the request contains the fields that are actually missing for that packaging. Article 16 gives you the right to ask; the platform makes the ask specific.
- Questions generated from unfilled fields, mapped to their article
- Union establishment flagged, because it changes who owes what
- Responses land against the field they answer, with the evidence attached
EU declaration of conformity
CFG-1042 · Annex VIII
The declaration will not be generated
Article 39(4) makes the manufacturer personally responsible for the declaration it signs. Two elements of this file are not demonstrated, so the platform will not produce a document asserting that they are.
- Article 5(4)Test report not on file — a supplier statement alone does not demonstrate it
Heavy metals, sum of Pb, Cd, Hg and Cr(VI)
- Article 5(5)Measured at 31 ppb against a 25 ppb limit — the packaging fails this requirement
PFAS in food-contact packaging
On the pending obligations: Recyclability and recycled content are not listed as failures. Their EU methods are not adopted, so no statement about them belongs in a declaration signed today — and Annex VIII does not require one.
Version history
| Version | Languages | Status | Signatory | Date |
|---|---|---|---|---|
| v2 (draft) | EN, DE, FR | Blocked | — | 1 Sep 2026 |
| v1 | EN, DE | Superseded | M. Devriese | 14 Aug 2026 |
The declaration must be supplied in the language required by the Member State where the packaging is made available. Versions are held per language and signed as one act.
The Annex VII file, assembled rather than authored
The technical file is built from the assessments underneath it, so it cannot drift from what was actually assessed. Completeness is shown in the language of Article 62(1)(d), because that is the wording an inspector will use.
- Annex VII elements as a checklist with per-element state
- Every element traced back to the assessment that produced it
- Export as the dossier an authority request asks for
Producer registration
3 markets · Article 44
| Country | Obligated | Register | Legal basis | Format | Registration number | State |
|---|---|---|---|---|---|---|
| Germany | Yes | LUCID | Pre-existing national register | National | DE4711920358 | Compliant |
| France | Yes | Not identified | PPWR Article 44 register not established | Pending Article 44(14) | — | Action required |
| Netherlands | No | — | Not first to make available | — | — | Out of scope |
Three separate facts are held per country and never collapsed: whether you must register, whether a register exists and on what legal basis, and what format applies. Saying 'compliant because no register exists' would be wrong, and so would 'submit Annex IX Part A in the EU format' — that format does not exist yet.
France — what to do now
The obligation applies and the packaging is already on the market there, so the position is Action required rather than Method pending. The EU format is pending under Article 44(14), but that does not suspend Article 44(2). Check the national scheme, register under national rules, and record the basis.
What you sign, and where you are registered
Article 39(4) makes the manufacturer personally responsible for the declaration it signs, so the platform will refuse to produce one where the file behind it is incomplete — and says which element is missing. Registration is tracked per Member State, including where no register has been identified.
- Annex VIII declaration with a full version history
- Refusal panel naming the missing element and its article
- Per-country registration state, with 'none identified' as a real value
Regulatory library
Sources and open questions behind every verdict
Sources
| Ref | Title | Type | Retrieved |
|---|---|---|---|
| ppwr-reg | Regulation (EU) 2025/40EUR-Lex | Binding | 1 Sep 2026 |
| dd-2026-429 | Delegated Decision (EU) 2026/429 — pallet wrappings and strapsEUR-Lex | Binding | 1 Sep 2026 |
| guidance-c-2026-3084 | Commission Notice C/2026/3084 — PPWR guidanceOfficial Journal | Non-binding | 1 Sep 2026 |
| faq-2026-08 | Commission FAQ on PPWREuropean Commission | Non-binding | 1 Sep 2026 |
Open questions
| Ref | Subject | Expected instrument | Due | Status |
|---|---|---|---|---|
| U-03 | Recycled content calculation and verification | Implementing act, Article 7(8) | 31 Dec 2026 | Not adopted |
| U-07 | Design-for-recycling criteria and grades | Delegated acts, Article 6(4) | 1 Jan 2028 | Not adopted |
| U-11 | Empty space ratio methodology | Implementing acts, Article 24(2) | 12 Feb 2028 | Not adopted |
| U-15 | Producer register format and granularity | Implementing act, Article 44(14) | 12 Feb 2026 | Overdue |
| U-18 | Harmonised label specification | Implementing acts, Articles 12(6), 12(7) | 12 Aug 2026 | Overdue |
| U-21 | Harmonised standards under Article 36 | Citation in the Official Journal | — | None cited — no presumption of conformity for anything |
A verdict links to the source it rests on and to the open question that stops it going further. Non-binding items are labelled as such and never produce a non-compliant verdict on their own.
The regulation
Why the EU packaging rules were rewritten in 2026
The 1994 packaging directive left each Member State to write its own law. Twenty-seven national interpretations grew apart, and a pack that was legal in one country could be refused in another. Regulation (EU) 2025/40 replaces that directive with a single text that applies directly in every Member State — no national transposition, no twenty-seven readings. It also moves the burden: instead of the state proving a pack is non-compliant, you hold a file showing that it is.
Source: Regulation (EU) 2025/40, EUR-Lex (CELEX 32025R0040). Retrieved 1 September 2026.
What applies today
Article 5(5)
PFAS in food-contact packaging
Three separate limits apply: 25 ppb for any single PFAS, 250 ppb for the sum of them, and 50 ppm including polymeric PFAS. Where total fluorine exceeds 50 mg/kg, upstream actors owe you proof of what that fluorine is. This is the first substantive restriction in the Regulation to bite, and it bites now.
Article 5(4)
Heavy metals
Lead, cadmium, mercury and hexavalent chromium together must not exceed 100 mg/kg. It is a sum, not four separate ceilings, so a pack can pass on each metal individually and still fail.
Article 10(2), Annex IV
Packaging that only looks bigger
Double walls, false bottoms and layers that serve no function other than to increase perceived volume are prohibited. Unlike the empty-space rule, this one needs no calculation method — it is a design test you can run today.
Articles 38, 39, Annex VII
Technical file and declaration of conformity
Before a packaging is placed on the market you must hold the Annex VII technical documentation and issue the EU declaration of conformity. Article 39(4) makes the manufacturer personally responsible for what it signs.
Article 44(2), 44(4)
Producer registration
You must be registered in every Member State where you first make packaging available, and you may not make it available while unregistered. This applies now — even though the EU register format is itself still pending.
Article 14
Environmental claims
A claim about a packaging's environmental properties may only be made where it goes beyond what the Regulation already requires. 'Recyclable' is not a selling point when recyclability is compulsory.
Your role follows from what you do, not what you call yourself
The Regulation assigns roles by activity. A company can hold several at once, and the duties attached to each are different. Two of these catch people out: Article 21 moves the full manufacturer's duties onto anyone who puts their own name on someone else's packaging, and a non-EU producer is a manufacturer without being a producer for registration purposes.
- ManufacturerArticle 3(1)(13)
- Whoever makes the packaging, or has it made and markets it under their own name or trademark. Holds the technical file, signs the declaration, and cannot delegate either.
- ImporterArticle 3(1)(14)
- Established in the Union and placing packaging from a third country on the market. Must verify the manufacturer's file exists and keep a copy.
- DistributorArticle 3(1)(16)
- Makes packaging available without being manufacturer or importer. Duties are checks rather than assessments — labelling, declaration, and not supplying what is visibly non-compliant.
- ProducerArticle 3(1)(15)
- Whoever first makes packaging available within a given Member State. This is the role that triggers registration and extended producer responsibility — and it is national, not EU-wide.
- Authorised representativeArticle 17
- A non-EU manufacturer may appoint one by written mandate. The mandate can cover holding documents and cooperating with authorities — but drawing up the technical file and the Article 15(1) duties stay with the manufacturer.
- Own-name and modification shiftArticle 21
- Put your brand on packaging someone else made, or modify a pack already on the market, and you become the manufacturer for it — with the file, the declaration and the liability. This is usually a commercial negotiation before it is a compliance question.
Enforcement
Enforcement has two layers. The first is documentary: under Article 62(1) a missing or incorrect technical file or declaration is independently enforceable — you do not need to have breached a substantive limit for it to be a finding. The second is national. Article 68 requires Member States to lay down penalties and to notify them by 12 February 2027, and for the Article 24–29 obligations those must include administrative fines. Amounts therefore differ by country and are not set in the Regulation itself.
Timeline
Some of these dates are not dates yet
Part of the Regulation gives a plain calendar date. Another part says 'from 1 January 2030, or three years after the implementing act enters into force, whichever is later' — and that act has not been adopted. Eleven headline obligations are worded that way. Storing 1 January 2030 for them would be a guess presented as a fact, so the platform shows 'not before' and names the act everything is waiting on. There is no countdown for a date the law has not fixed.
- Applying— In force as at 1 September 2026
- Fixed future date— A calendar date in the Regulation, contingent on nothing
- Not yet determined— Waiting on a Commission act
These all took effect together on 12 August 2026, when the Regulation began to apply in general and Directive 94/62/EC was repealed.
11 February 2025
Article 71
Entry into force. Also the reference date for the micro-enterprise definition, the design and trademark protection cut-off in Article 10(2)(a), and the start of the Article 11(1) reusability test.
12 August 2026
Article 71
The Regulation applies in general, and Directive 94/62/EC is repealed with the survivals listed in Article 70(1).
12 August 2026
Article 5(5)
PFAS limits in food-contact packaging: 25 ppb for any single substance, 250 ppb for the sum, 50 ppm including polymeric PFAS.
12 August 2026
Article 5(4)
Lead, cadmium, mercury and hexavalent chromium together capped at 100 mg/kg.
12 August 2026
Articles 38, 39, Annex VII
Technical documentation, conformity assessment and the EU declaration of conformity become preconditions for placing packaging on the market.
12 August 2026
Articles 15–22
The full set of operator duties, including supplier information, the authorised representative and the Article 21 own-name shift.
12 August 2026
Articles 44(2), 44(4)
Producer registration applies, and making packaging available while unregistered is prohibited.
12 August 2026
Article 14
Environmental claims may only be made where they go beyond what the Regulation already requires.
'How many of our packs are caught by the 2030 recycled-content rule' is a fair question and the platform answers it. 'How many days until the recycled-content deadline' is not, because that deadline does not legally exist yet.
Compliance states
Seven distinct states instead of one score
Most compliance tools show a score or a percentage. That works where the law is about risk — EUDR is, and our EUDR product has risk gauges for exactly that reason. PPWR is not. Its obligations are binary: a packaging either meets a rule or it does not, and there is no operator-side risk concept anywhere in the text. Averaging binary outcomes into 87 % hides the one market-access failure inside a reassuring green. So the platform returns seven named states with their legal reasoning, and counts them.
Every applicable rule was tested against the data and documents you hold, and each passed. The evidence and the rule version are recorded with the verdict.
Passes, but on an assumption that is written down — a supplier statement not yet backed by a test report, or a value taken from a specification rather than a measurement.
Something is missing or wrong and you can fix it. The work belongs to you: obtain a document, correct a value, register in a market.
An applicable rule was tested and failed. Not a warning — a packaging in this state should not be placed on the market.
The rule does not reach this packaging, and the reason is shown: the exclusion, the exemption, or the role you do not hold.
The obligation exists and applies to you, but the EU has not adopted the method for calculating it. Nobody can produce a verdict yet — including us.
The rule applies and the method exists, but an input is absent. The platform names the field, the article that needs it and who can supply it.
Blue is not amber
'Action required' means you have something to do. 'Method pending' means the Commission does. Collapsing the two would put work on your list that no one on earth can currently complete, and would bury the items you actually can close. They are different colours, carry different icons and are counted separately.
When a packaging lands in more than one state
- Non-compliant
- Information missing
- Method pending
- Action required
- Conditionally compliant
- Compliant
- Out of scope
Several rules apply to a single packaging and they can disagree. The platform does not average them. A tested failure outranks everything: one non-compliant rule makes the packaging non-compliant, whatever the other twenty say. Below that, missing information outranks a pending method, which outranks action required, which outranks conditional. The screen shows the state and the rule that produced it, so you can always see which obligation is driving the verdict.
Why ERWAY
The things this software deliberately will not do
You have to keep records for five to ten years, documentation errors are independently enforceable, and the rules will change repeatedly as the pending acts land. That combination makes restraint a feature. Each of the following is something the platform could technically produce and refuses to, because producing it would create for you exactly the liability you bought the software to avoid.
It does not generate a score
The Regulation defines no compliance score. Inventing one would create a legal concept that does not exist and would let a single market-access failure average away into green.
It does not estimate a missing value
Where an input is absent, the field stays empty and the state says so. A plausible-looking number in a technical file is worse than a gap, because it looks like evidence.
It does not substitute a third-party method for a missing EU one
Where the Commission has not adopted a methodology, no industry scheme is silently used in its place. The obligation is stated, the missing act is named, and the verdict waits.
It does not derive non-compliance from non-binding guidance
The Commission notice and the FAQ are shown as what they are. Neither on its own turns a packaging non-compliant.
It does not hide the legal basis behind a summary
Every verdict shows the article, the quoted text, the inputs used, the rule version and the retrieval date. An inspector asking why gets the whole chain, not a tick.
It does not rewrite a past assessment
Assessments are append-only and bind the rule version in force when they ran. When a rule changes, a new assessment is recorded — the old one still explains what you did and why.
It does not count down to an undetermined date
Eleven headline dates are formulas whose anchor acts are unadopted. Those render as 'not before', with a link to the act everything is waiting on.
It does not invent a filing channel
There is no EU PPWR API and no central register. Where a country's channel is not documented, the platform says 'none identified' rather than guessing an endpoint.
There is no common EU PPWR system
Some EU regimes give you a central system to submit to. PPWR does not. Every filing is national, and the countries differ in format, in channel and in whether a channel has been published at all. So the integration layer is a per-country adapter registry rather than one connector, and what a country does not offer is recorded as a fact rather than filled in with a guess.
The channel type is stated explicitly
For each country and obligation the platform records how submission actually happens — portal, file upload, scheme operator, or nothing documented — with the source it came from.
Exports match the national format
Where a country publishes a format, the export follows it. Where it does not, the platform produces the data set the Regulation names and says the national format is pending.
Nothing is inferred
An endpoint is never derived from a pattern seen in another country. If it has not been published, the state is 'none identified'.
Every submission is logged
What was sent, when, in which format, against which rule version, and by whom. This is the record that answers a question asked years later.
Integrations we are not building
- A central EU PPWR submission API — it does not exist
- An EU-wide producer register lookup — registration is national
- Automatic recycled-content certification — the method is not adopted
- A recyclability grade calculator — the criteria are not adopted
- Automatic DRS enrolment — deposit systems are national and vary
- A harmonised label generator — the label specification is pending
- Customs interconnection — operational date depends on an unadopted act
None of these exist today. Shipping them as though they did would mean generating output no authority would accept, and putting your signature under it.
See what the Regulation asks of your packaging
The tour runs the whole chain on a worked example: an EU packaging manufacturer selling into Germany and France with a PET bottle and a board grouping pack. No sign-up, and nothing to install.