Key updates and practical implications
PPWR enters into application as guidance advances
The core rules of the Packaging and Packaging Waste Regulation (PPWR) have applied across the EU since 12 August 2026.
Among the first requirements taking effect are restrictions on PFAS in food-contact packaging, while further obligations will follow progressively, including harmonised packaging labelling from 2028 and requirements on recyclability, reuse and recycled plastic content from 2030.
Shortly before the application date, the Commission published an updated and substantially expanded FAQ, replacing the March 2026 version.
This document provides further clarification on the identification of the responsible producer in cross-border supply chains and on the practical enforcement of the new rules.
In parallel, work is advancing on the secondary legislation needed to operationalise the PPWR, where many of the detailed technical requirements will be defined.
Four consultations are currently open:
- Calculation and verification of recycled plastic content: harmonised methodology, documentation and verification rules (open until 16 September)
- Imports of recycled materials from third countries: rules to assess and certify equivalence with EU requirements (open until 16 September)
- Sustainability criteria for plastic recycling technologies: criteria covering environmental and economic performance, output quality and energy use (open until 16 September)
- National producer registers: harmonised rules for producer registration and reporting under packaging EPR systems (open until 10 September)
The first three initiatives were launched as a package on 14 August and concern the PPWR’s recycled-content requirements. The Commission plans to adopt the corresponding acts in the fourth quarter of 2026.
Digital Product Passport: EU registry is live
The European Commission has made the EU Digital Product Passport (DPP) Registry available for organisation enrolment, together with a testing environment for economic operators. The Registry is an important part of the DPP framework established under the EU Ecodesign for Sustainable Products Regulation.
The Registry will act as an EU-level indexing service for Digital Product Passports. It will hold unique product identifiers, registration information and specified metadata rather than the complete product information contained in individual passports. The underlying product data will remain decentralised and under the responsibility of the respective companies.
What does this mean for industry?
Where a DPP is required by the applicable EU legislation, it must be registered before the product is placed on the EU market.
For businesses, the practical challenge extends beyond registration. Product information may be dispersed across internal systems, supplier records and different business functions. Companies preparing for DPP requirements should assess what product data they already hold, identify missing information, establish how supplier data will be collected and validated, and determine how information will be maintained when products or supply chains change.
Read more about the role of the EU DPP Registry and why effective implementation depends on establishing a structured, reliable and scalable product-data foundation here.
H2 Compliance has launched SimpliPass, a solution for managing supplier and product data through a structured DPP workflow.
Contact the team to learn more.
Restrictions in food-contact packaging
The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, applies across the European Union from 12 August 2026. It replaces the previous directive-based framework with directly applicable EU rules covering the full packaging lifecycle, from design and manufacture to use and waste management.
One of the chemical requirements in force from the PPWR’s application date is the restriction on PFAS in food-contact packaging above the concentration limits specified in the Regulation.
The rules also retain limits for the combined concentration of lead, cadmium, mercury and hexavalent chromium in packaging.
The European Commission has published updated PPWR frequently asked questions which are helpful for addressing some practical issues.
H2 Compliance can support your PPWR compliance with a full range of services.
Contact the team here.
From PPWR assessment to documentation and representation
H2 Compliance offers crucial support
The application of the PPWR brings both regulatory and packaging data challenges. Businesses must first establish their role under the Regulation, identify the packaging within scope and determine which regulatory requirements and supporting evidence apply to their portfolio.
H2 Compliance provides PPWR consultancy and readiness support covering packaging scope, regulatory roles, supplier information, substance requirements, documentation and compliance planning.
Support ranges from introductory and advanced workshops to packaging reviews, compliance checks, action plans and follow-up implementation assistance.
For businesses preparing packaging Declarations of Conformity (DoC), SimpliDoC provides a structured platform for creating, managing and storing PPWR DoCs.
It supports the organisation of packaging information, supplier evidence, technical documentation and completed declarations within one guided workflow.
H2 Compliance also offers coordinated Authorised Representative support. The service distinguishes between national EPR Authorised Representatives established under Member State legislation and the EU-wide Authorised Representative framework introduced by the PPWR.
H2 Compliance’s team supports businesses in identifying where representation is required and coordinating national and EU-wide services through:
Support for PPWR role and obligation assessment, packaging scope, supplier evidence, substance requirements, packaging data management, technical documentation and Declarations of Conformity preparation
Guided platform for creating, managing and storing PPWR Declarations of Conformity, linking packaging records with supporting documentation
EU-wide Authorised Representative support under the PPWR, including assessment of representation requirements, registrations, reporting and administration
