As of 12 August 2026, Regulation (EU) 2025/40 – PPWR (Packaging and Packaging Waste Regulation), which formally entered into force in February 2025, has become fully applicable.
However, the start of its application does not coincide with the completion of the regulatory process. The PPWR requires the European Commission to adopt numerous delegated and implementing acts aimed at defining the criteria, methodologies and operational procedures necessary for the application of the various requirements.
To date, among the delegated acts already published, the only one is Commission Delegated Decision (EU) 2026/429, concerning the exemption of certain economic operators from the 100% reuse requirements applicable to pallet wrapping and strapping.
Several important measures are still pending, including those concerning design-for-recycling criteria, methodologies for assessing recycled content, requirements for minimising the weight and volume of packaging, environmental labelling, and other technical aspects provided for by the Regulation.
At present, the applicable provisions include Article 5, concerning substances of concern, and Article 11, concerning reusable packaging.
Despite the fact that the regulatory framework is still partly incomplete, one aspect is already clear: technical documentation plays a particularly important role. The PPWR requires the manufacturer to prepare the documentation necessary to demonstrate the conformity of the packaging and to retain it for the periods specified in the Regulation.
It is important to emphasise that the evidence supporting the declarations made must actually be available to the manufacturer, as part of the technical documentation and document management system supporting the conformity assessment.
It is therefore not sufficient to declare that packaging is compliant: the manufacturer must be able to demonstrate, through objective and documented evidence, why it is compliant.
The PPWR is therefore now operational, but the technical framework is still evolving. For companies, this is already the right time to properly organise the data, analyses, tests and documentation supporting their declarations of conformity.
CEPRA laboratory performs analytical testing to support packaging compliance, including the determination of heavy metals and regulated substances.
