PPWR module
PPWR packaging compliance module
In useIf you sell packaging or packaged goods to the EU, your buyer will ask you for declarations and documents. The PPWR module prepares them from your packaging records.
In force today
Four requirements since 12 August 2026
The label, recyclability grades and recycled content are tied to later years. The following apply today.
Heavy metal limit
The sum of lead, cadmium, mercury and hexavalent chromium may not exceed 100 mg/kg in packaging or its components. It applies to all packaging.
2025/40 Art. 5(4)
PFAS in food-contact packaging
25 ppb for any single PFAS, 250 ppb for the sum of PFAS, 50 ppm including polymeric PFAS. For food-contact packaging placed on the market from 12 August 2026.
2025/40 Art. 5(5)
Conformity assessment and declaration
Before placing on the market, the manufacturer carries out the conformity assessment itself (Module A), draws up the technical documentation and issues the EU declaration of conformity. No notified body is required.
2025/40 Art. 15, Art. 38, Art. 39, Annex VII, Annex VIII
Identification
Packaging carries a type, batch or serial number and the manufacturer's name and postal address. The importer adds its own name and address. If there is no room, a QR code or an accompanying document is used.
2025/40 Art. 15(5)-(6), Art. 18(3)
Your role
First, know which role you are in
Manufacturer
Whoever makes the packaging or the packaged product. If someone else has it designed or made under their own name or trademark, they are the manufacturer. The definition has no requirement to be established in the EU.
2025/40 Art. 3(1)(13)
Supplier
Whoever supplies packaging or packaging material to a manufacturer. Its duty is to give the manufacturer all the information and documents needed to demonstrate conformity, in a language it understands.
2025/40 Art. 3(1)(16), Art. 16
Importer
Established in the EU and placing packaging from a third country on the market. It ensures the manufacturer has done the assessment and drawn up the technical documentation, and keeps a copy of the declaration.
2025/40 Art. 3(1)(17), Art. 18
According to the information note of Türkiye's Ministry of Trade, a company that makes packaging under its own brand and sells it to the EU can be treated as the manufacturer, and a company selling material to an EU manufacturer as a supplier. Your role depends on the product and the contract. Ministry of Trade of Türkiye, PPWR information note, 3 August 2026
Timeline
What comes next
| Date | What happens | Source (2025/40) |
|---|---|---|
| 12 August 2026 | The Regulation started to apply. Directive 94/62/EC was repealed in general. | Art. 70(1), Art. 71 |
| 31 December 2026 | The Commission sets the method for calculating and verifying recycled content in plastic by this date. | Art. 7(8) |
| 12 February 2027 | Member States lay down their rules on penalties by this date. The Regulation itself sets no amounts. | Art. 68 |
| 1 January 2028 | The Commission adopts the design for recycling criteria and performance grades by this date. | Art. 6(4) |
| 12 August 2028 or later | Harmonised material label. The date moves to 24 months after the implementing act if that is later. | Art. 12(1) |
| 1 January 2030 or later | Packaging outside grades A, B and C cannot be placed on the market; minimum recycled content in plastic starts. Both dates can move later depending on secondary legislation. | Art. 6(3), Art. 7(1) |
| 1 January 2038 | Only grade A and B packaging can be placed on the market. | Art. 6(3) |
The module
What the PPWR module does
The module covers the requirements in force today. Recyclability grades, minimum recycled content and the new label depend on secondary legislation and are not assessed yet.
Records
- Packaging and component recordsPackaging types, your role (manufacturer or supplier), components and materials.Working
- Evidence storeLaboratory reports and supplier declarations linked to the packaging they cover, stored encrypted.Working
- Conformity checkChecks the measurements you enter against the limits and lists what is missing.Working
- Bulk import from ExcelImports many packaging records and their components from one file; an import can be undone.Working
- Supplier data requestYour material supplier sends measurements and a declaration through a form without an account. Once you approve, the document becomes evidence for the packaging.Working
- Recycled content summaryTotal weight and weighted recycled content of the packaging from component records. It will follow the official method once adopted.Working
Documents
- Heavy metal and PFAS declarationsChecked against the limits, with the laboratory report as evidence.Working
- Technical documentationFollowing the headings of Annex VII, filled from your records. Downloads as PDF.Working
- EU declaration of conformityIn the Annex VIII model, one per packaging type. An issued declaration cannot be changed and is kept for the retention period.Working
- Supplier packFor a company in the supplier role, the English document set that goes to the manufacturer.Working
- Document linkYour buyer sees only the valid declaration for that packaging without logging in and downloads the PDF. The link can be withdrawn.Working
- Identification labelType or batch number with the manufacturer's name and address, as a printable label with a QR code.Working
Let us look at your packaging documents together
If you sell packaging or packaged goods, write to us. We will walk through the module with your packaging.
No sign-up. You browse the panel of a sample company. · bilgi@registamp.com