The EU Commission published updated PPWR guidance in June 2026
The first major market access milestone applies from 12 August 2026. Most businesses still haven’t interpreted it. Here’s what product managers, supply chain directors and business leaders need to understand before summer.
The nature of the calls I’ve been getting has changed this year.
12 months ago, PPWR queries came from sustainability managers and packaging teams. People who’d been tracking the regulation for a while, doing early groundwork, wanting to test and clarify their thinking.
Now the calls come from commercial directors and C-suite leaders. The question has shifted too. It used to be “are we compliant?” Now it’s “can we still sell into Europe after August?” and there’s an urgency in the voice that tells me the business is already behind.
Packaging compliance has reached the boardroom as business critical matter, it’s no longer a technical matter. It’s about market access. And market access issues have a way of compressing timelines very quickly.
WHAT THE JUNE GUIDANCE ACTUALLY CHANGES AND WHY AUGUST 12 MATTERS MORE THAN MOST BUSINESSES REALISE
The EU Commission published detailed guidance on the Packaging and Packaging Waste Regulation (PPWR) (Regulation (EU) 2025/40) June 2026. It updated the earlier version published in March 2026.
Thirty-three sections of legal interpretation, responding to questions from businesses, Member States and trade associations since the regulation entered into force in February 2025.
The latest regulation milestone to be able to sell compliant packaging into the EU is 12 August 2026. That’s this summer. The guidance doesn’t introduce new requirements, but instead it removes the legal ambiguity that some businesses were, perhaps quietly, relying on. The obligations were published in 2025 but now they’re sharply defined. If your packaging compliance position was built on broad assumptions rather than documented evidence, the June guidance is the moment that comfort disappears.
The first major compliance milestone your business needs is a document called the Declaration of Conformity. It must be produced and signed by the Manufacturer. From 12 August, it is the legal basis on which your packaging moves through the European supply chain. It must be backed by a complete technical file with traceable supporting evidence. A general statement of intent doesn’t satisfy the requirement. Documented analytical proof does.
FOUR CLARIFICATIONS FROM THE GUIDANCE THAT CARRY IMMEDIATE WEIGHT
- The brand owner is legally the manufacturer
Under PPWR, “manufacturer” is the company whose name or trademark appears on the packaging not the factory that physically produced it. If your brand name is on the box, you are in all likelihood the manufacturer for PPWR purposes. That means you bear legal responsibility for the Declaration of Conformity and the technical file behind it. Literally signed by your business leaders. The guidance makes this unambiguous. Businesses that assumed their packaging supplier was carrying this responsibility need to revisit that assumption immediately. - PFAS in food-contact packaging and heavy metal concentrations: no grace period
From 12 August, food-contact packaging containing PFAS (per- and polyfluorinated alkyl substances) above specified concentration limits cannot be placed on the EU market. There is no exhaustion-of-stocks provision and no transitional arrangement for packaging with either of these types of restricted substances. Packaging produced before the deadline but not placed on the market before that date must still comply. Technical documentation must evidence compliance through a specific stepwise testing protocol. This likely involves lab testing – neither cheap or easy to access with bottle-neck like access to results and reports. If your packaging uses PFAS in grease-resistant coatings, barrier treatments or functional layers, or doesn’t have the evidence to show heavy metal concentrations are not exceeded per the previous ‘Essential Requirements’ Directive, this needs attention now. Restricted PFAS substances are most commonly found in paper, cardboard, and moulded-fibre packaging designed to resist water, grease, and oil or treated plastic containers for food and cosmetic packaging. But at least heavy metal should be a familiar topic to evidence compliance. - The basic recyclability requirement is live from 12 August 2026
Detailed design-for-recycling criteria won’t arrive until around 2030, when future delegated acts come into force. But the general recyclability requirement under Article 6(1) applies from the application date, but to the earlier PPWD Annex II, point 3(a), of Directive 94/62/EC on packaging and packaging waste. This outlines the essential requirements for packaging recoverable in the form of material recycling. It stipulates that packaging must be manufactured so as to enable the recycling of a specified percentage by weight of the materials used in order to market the product in the EU. Your Declaration of Conformity and technical file must address recyclability against the existing harmonised standard, EN 13430:2004, until those later delegated acts supersede it. The full conformity assessment procedure under Article 38 is not required yet for recyclability but the obligation to address it in your documentation is. - UK businesses and third-country suppliers with EU branches need to act
A branch office has no separate legal personality. The guidance is explicit: a non-EU manufacturer with only a branch in the EU cannot act as an importer under PPWR. If you are a UK business or a third-country supplier selling into EU Member States end users, you need either a subsidiary incorporated in an EU Member State or an authorised representative. This directly affects who is legally empowered to create, sign and issue or oversee the Declaration of Conformity and who carries the compliance liability.
To define your roles and responsibilities under PPWR a deep understanding of your product supply chain is necessary, beyond that of your immediate supplier or customer. Collaboration will be key to the transfer of data, trust that is built through demonstrating compliance and ability to supply the mandatory compliance and evidence records between stakeholders. Will you be ready when your sales team ask for the compliance documentation?
THE COMMERCIAL PRESSURE WILL ARRIVE BEFORE THE ENFORCEMENT ACTION
I want to be direct about where I believe the real risk sits, because I think the regulatory conversation sometimes misses it.
Distributors and retailers across Europe do not wait for regulators to act. They start requiring compliance evidence as a pre-condition of sale and procurement teams will be adding this to their list of requests. I’ve watched this pattern play out across major product regulation cycles: plastic tax, waste electricals (WEEE/e-waste), the Battery Regulation, even the old Packaging Directive saw this, albeit without the leverage that prevented sales.
Procurement teams update their supplier questionnaires. Logistics operators revise acceptance criteria. Retailers add (even more) compliance documentation requirements to onboarding. Data is king and opens the doors to sell, otherwise risk losing customers and market share.
If you cannot produce a valid Declaration of Conformity when a distributor asks for it, you are commercially exposed before any regulator has opened a file. There are thousands of distributors per market and only 1 regulator – the math and probability are massively stacked towards compliance documentation requests becoming the norm and virtually self regulating each market. A distributor may decline to list your products. A retailer can pause orders pending evidence. An importer can refuse to handle your goods. The market closes without a fine being issued.
This is what the C-suite and other business leaders are waking up to right now. And it’s why the businesses must treat compliance documentation as a priority condition of sale, not a formality.
WHAT BUSINESSES IN GOOD SHAPE ARE DOING DIFFERENTLY
The businesses I work with that are entering August in a defensible position share a few characteristics.
- They’ve been through a level of readiness review,
- They know which role they occupy in the supply chain: manufacturer, producer, importer, authorised representative,
- They have reviewed or baselined their packaging portfolio against their specific obligations, and look to the new June guidance as a sense check of our interpretations, rather than a new set of requirements,
- They have built technical documentation designed to withstand the planned updates between 2026 and 2030, and
- The paper trail and backing data is strong enough stand up to scrutiny, and transparency with customers who demand these records.
That’s the standard and it’s achievable before August 12 but only for businesses that start with the right questions and hold the relevant compliance data records.
PPWR CLINIC: A WORKING SESSION BUILT AROUND YOUR BUSINESS
If you are a product manager, supply chain director or business leader asking whether your PPWR compliance position is as robust as it needs to be, the most useful next step is a focused conversation with someone who is familiar with the regulation.
Multiple guidance documents, industry commentary, and articles explaining the technical requirements are just the resources to use. The real challenge is applying this to your business correctly, generating the right outputs for your Declaration of Conformity, and assuring your sales teams you are compliant. Mapping each Article directly against your own packaging portfolio and supply chain.
I run a PPWR Clinic: a structured working session with your team where we review the pririty actions for your product and packaging portfolio against the obligations now in force. We establish your precise role and responsibilities under the regulation, identify gaps in your documentation, and build a practical compliance roadmap. It’s designed around your products and your markets not a generic or high-level briefing.
Using a Declaration of Conformity template that follows a Module A procedure interpreted from the Regulations themselves, we can create the compliance documentation you are looking for.
The guidance is published. August is close. If the sales team or sale director is already asking questions, that urgency is working in your favour. The question is whether it leads somewhere concrete before the deadline.
Arrange a call. Tell me where you are with your compliance position, and we’ll work through what this guidance means for you specifically.
PPWR JUNE GUIDANCE DIGEST
The June Guidance and Clarification document is the latest in a line of published reports and guidance documents. There are over 22k words in the latest guidance document, plus the preceding and earlier published guidance, and on top of a lengthy legalese Regulation 2025/40 itself. This compounds into an unmanageable amount of information. It requires bespoke application. The result is often far fewer responsibilities and thereby reduced complexity applicable to the clients I work with.
If your business has or might have PPWR responsibilities and would like a synthesised review of what I believe are the most important points from the latest guidance, email me to request a free copy. Business leaders will want to quickly understand the latest positioning and risks. This digest gives them the top line issues and will allow you to dive a little deeper and reflect on where changes may be necessary for your business and packaged goods to be compliant, ready for August.
Mark Sayers is the founder and consultant at CircuMetrics, advising brands, importers and manufacturers on product, packaging and waste compliance across European and UK markets. With 20 years of experience across leading compliance organisations and consultancies, CircuMetrics delivers independent, practical guidance for SMEs navigating today’s complex regulatory landscape.