PPWR since August 2026: what applies right now

Since 12 August 2026 the EU Packaging Regulation (PPWR, Regulation (EU) 2025/40) applies directly in every Member State. In Germany, enforcement and fines are governed by the VerpackDG. This article explains, as of today, what has actually been required since the application date, who it affects and what only arrives with the pending secondary acts.

1. 11.02.2025

   Entry into force

   The PPWR enters into force (Art. 71). Reusable packaging placed on the market from this day is later subject to the Art. 11 criteria.

2. 12.08.2026

   Date of application

   Conformity assessment, technical documentation and the EU declaration of conformity (DoC) must exist for the requirements that apply. Directive 94/62/EC is repealed.

3. 12.02.2027

   Fines in Germany

   Only from this day are breaches of the conformity duties subject to fines (Section 68(17) VerpackDG), usually up to EUR 10,000. Until then authorities demand corrective action.

4. 2028 to 2029

   Labelling under Art. 12

   The sorting label applies at the earliest from 12.08.2028, realistically 2029, because the implementing act is still missing.

5. 01.01.2030

   Art. 6, 7 and 10

   Recyclability, recycled content and minimisation become mandatory, each subject to the delegated acts.

What has actually been required since 12.08.2026

Where a provision has no date of its own, it applies since the application date. At the core these are Art. 5(1), (4) and (5) and Art. 11, plus the manufacturer details under Art. 15(5) and (6). For these requirements the manufacturer needs technical documentation under Annex VII and a signed DoC under Annex VIII. The procedure is Module A, internal production control without a notified body.

• Art. 5(1): minimise substances of concern. There is no limit value; a substance inventory with a risk assessment and an SVHC declaration from the supplier is sufficient.
• Art. 5(4): lead, cadmium, mercury and chromium VI together at most 100 mg/kg per component, including inks, labels and closures. The evidence belongs in the technical documentation.
• Art. 5(5): PFAS limits only for food contact: 25 ppb per PFAS, 250 ppb in total, 50 ppm including polymeric PFAS. A total fluorine value below 50 mg/kg covers all three limits according to the Commission.
• Art. 11: reusable packaging must meet criteria a to i. Records are kept for ten years.
• Art. 15(5) and (6): an identifier plus the name and address of the manufacturer on the packaging or in the accompanying documents.

Who is affected: the role attaches to the packaging

Each packaging has exactly one manufacturer: whoever makes packaging, or has it made, under their own name or trademark (Art. 3(13)). For sales and grouped packaging that is usually the filler or brand owner; for neutral transport packaging it is the maker of the box, film or pallet. The same company is therefore the manufacturer of its printed folding box but not of the neutral shipping carton.

What suppliers must provide, and what they need not

Suppliers do not issue a DoC. Under Art. 16 they hand the manufacturer all information and documentation needed for the evidence, on paper or electronically, in an easily understandable language. The law prescribes no signature, form or validity period. Industry practice is a dated, item-specific declaration with the name and function of the declaring person and an undertaking to report changes. Test reports make sense only for risk materials such as flexible PVC, printed parts from third countries or paper in contact with food. The PPWR currently requires certificates nowhere.

Sanctions: only from February 2027 and mostly capped

In Germany the federal states enforce under the Market Surveillance Act. Fines for a missing or incomplete assessment, missing retention or late submission are possible only from 12.02.2027 and are usually capped at EUR 10,000. Ignoring an enforceable order risks up to EUR 100,000. The Commission expects authorities to demand corrective action first and only then order withdrawal or recall. The VerpackDG provides no fine for suppliers who ignore Art. 16.

Date of application

12.08.2026 (Art. 71)

Required today

Art. 5(1), (4), (5), Art. 11, manufacturer details Art. 15(5)/(6)

Fines

from 12.02.2027, usually up to EUR 10,000 (Sections 66, 68(17) VerpackDG)

Submission deadline

10 days after a reasoned request (Art. 15(10))

Still pending

secondary acts on Art. 6, 7, 11(2), 12 and 24

What only comes later

• Recyclability (Art. 6): performance grades only after the delegated act, due 01.01.2028. Grades from 01.01.2030. Until then a self-assessment, for example under EN 13430, is enough.
• Recycled content (Art. 7): minimum shares from 01.01.2030, only post-consumer material counts. The implementing act on the calculation is planned for late 2026.
• Minimisation (Art. 10): from 01.01.2030. Until then EN 13428 continues to carry a presumption of conformity.
• Labelling (Art. 12): sorting label at the earliest 12.08.2028, reuse label at the earliest 12.02.2029, realistically 2029.
• Empty space (Art. 24): from 2030 for the filler, not part of the DoC.