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    No transition period on the declaration duty. Get every Declaration of Conformity generated, signed and ready.

    Farm to filing, on one data layer.

    Every product, every market, a Declaration of Conformity generated automatically from your bill of materials and ready to sign. Same platform as EUDR, no second system to run.

    descriptionDoC per product & market account_treeBuilt from your BOM drawSigned in platform
    Declaration of Conformity
    PPWR · Art. 39 / Annex VII (point 2)
    verified
    ProductRetail pouch, 250 g
    Packaging familyFlexible laminate
    MarketEU · DE, FR, NL
    SourceBill of materials
    checkTechnical documentation attached (Annex VII)
    checkSubstances of concern reference fields
    checkAuthorised Representative clause
    drawSigned · M. Tan, Compliance Lead READY
    The regulation

    What is the EU Packaging and Packaging Waste Regulation (PPWR)?

    The Packaging and Packaging Waste Regulation (PPWR) is the European Union’s legislative overhaul to tackle waste, over-packaging, and plastic pollution across the EU market.

    Whether you manufacture, import, fill, or distribute packaged goods in the EU, PPWR will reshape how your packaging is designed, labeled, reused, and recycled.

    It replaces the current Packaging Waste Directive with a directly applicable regulation across all EU countries, accelerating the shift to a circular packaging economy.

    PPWR sets clear, mandatory requirements for:
    check_circlePackaging design and recyclability
    check_circleRecycled content in plastic packaging
    check_circleReuse and refill systems
    check_circleWaste prevention and reduction targets
    check_circleHarmonized labeling across the EU
    Scope
    All actors in the packaging supply chain are covered, including:
    check_circleManufacturers of packaging materials and components
    check_circleBrand owners and product packagers
    check_circleE-commerce retailers and platforms
    check_circleImporters and distributors of packaged goods
    Packaging levels include:
    Primary: direct packaging (e.g., yogurt cup, shampoo bottle)
    Secondary: grouped packaging (e.g., shrink-wrap around cans)
    Tertiary: transport packaging (e.g., pallet wrap, shipping boxes)

    PPWR milestones

    2024-2025
    PPWR is adopted in December 2024, published in the Official Journal in January 2025, and enters into force on 11 February 2025. It applies from 12 August 2026.
    2026
    From 12 August 2026 manufacturers, or an authorised representative appointed under Article 17, must hold technical documentation and a signed EU Declaration of Conformity, retained five years for single-use and ten for reusable packaging from the date the packaging is placed on the market, Article 15(3), and meet the Article 5 heavy metal and PFAS limits. Importers keep a copy at the disposal of market surveillance authorities and make the technical documentation available, Article 18(7). Directive 94/62/EC is repealed from the same date, with the exceptions listed in Article 70(1) surviving to 2028 and 2029. Labelling obligations follow from 12 August 2028 at the earliest, and recyclability obligations from 1 January 2030.
    2030
    Article 29 reuse targets apply from 1 January 2030. Article 7 recycled content minimums apply from 1 January 2030 or three years after the Commission's calculation methodology enters into force, whichever is later. Member States must cut packaging waste per capita by 5% against a 2018 baseline.
    layers
    One data layer, many regulations
    The same first mile and supply chain data already serves EUDR and PPWR, and extends to whatever comes next.
    qr_code_2
    The road to the DPP runs through PPWR
    PPWR today, Digital Product Passport next, with no rework of your data layer.
    warning
    The cost of a missing declaration
    A missing or late Declaration of Conformity means blocked placement, brand risk and exposure to national penalties, with the underlying obligations applying from 12 August 2026. Member States must have their penalty regimes in place by 12 February 2027.
    Obligation coverage

    Every Declaration of Conformity obligation, covered.

    ObligationArticleDeadlineCoverage
    Declaration of Conformity: generation, lifecycle, and PDF exportArt. 39 / Annex VII (point 2)12 Aug 2026COVERED
    Technical Documentation (Annex VII): auto-generated from BOM dataArt. 15.2 / Annex VII12 Aug 2026COVEREDPopulates as client data matures
    Substances of Concern reference fields (heavy metals Art. 5.4; PFAS Art. 5.5)Art. 512 Aug 2026COVEREDReference fields populate via supplier data flow
    Food contact flag per packaging component, input to the Art. 5.5 PFAS testArt. 5.512 Aug 2026COVEREDPopulates as client data is sent
    Packaging type structuring: one BOM driving a Declaration of Conformity per packaging typeAnnex VII pt 412 Aug 2026COVEREDBOM-level structuring, configurable per client
    Authorised Representative mandateArt. 1712 Aug 2026COVEREDEmbedded in DoC output as standard clause
    Signatory block per Annex VIII: name, function, signature, place and dateArt. 3912 Aug 2026COVEREDExtended with country and BOM category scope. Article 39(2) requires the declaration to be continuously updated, which the version history answers
    The numbers

    Recycled content and labelling: the two obligations with hard numbers.

    Most of PPWR is process. These two are arithmetic and artwork, which is why they drive reformulation and reprint decisions being made right now. Both depend on Commission acts that are still pending, so the dates below are the earliest they can bite, not fixed.

    Plastic packaging type (Art. 7)From 2030*From 2040What it turns on
    Contact-sensitive packaging, PET as major component30%50%Excludes single-use beverage bottles. Food contact safety law still prevails.
    Contact-sensitive packaging, plastics other than PET10%25%Excludes single-use beverage bottles
    Single-use plastic beverage bottles30%65%Aligns with the SUP Directive trajectory
    All other plastic packaging, not covered by the rows above35%65%Dangerous goods transport packaging excluded

    * Article 7(1) applies from 1 January 2030 or three years after the Article 7(8) implementing act enters into force, whichever is later. The 2040 tier carries no such deferral. Article 7(11) adds an intermediate date: from 1 January 2029, or 24 months after that act, calculation and verification must follow it.

    Post-consumer only
    Production offcuts and pre-consumer scrap do not count, however a supplier data sheet frames them. Targets are calculated per packaging type and format, Annex II Table 1, as an average per manufacturing plant per year, and do not apply to any plastic part representing less than 5% of the packaging unit's total weight.
    Method still pending
    The targets are set, but the calculation and verification methodology under Article 7(8) is not, and is due by 31 December 2026, alongside two companion acts sharing that date: the Article 7(9) delegated act on recycling-technology sustainability criteria and the Article 7(10) third-country equivalence act. The compliance risk sits in the method, not the percentage. The 2030 numbers for the non-PET and residual categories are themselves contingent: Article 7(12) lets the Commission derogate from the scope, timing or level of those two tiers, on an assessment due by 1 January 2028.
    Safety wins conflicts
    Article 7(5)(b) disapplies both tiers for food-contact plastic packaging where the quantity of recycled content would pose a threat to human health and result in the packaged product failing Regulation (EC) No 1935/2004. Recyclate for food contact must also comply with Regulation (EU) 2022/1616, a suitable recycling technology and, where that technology requires one, an authorised process. That second requirement is freestanding food-contact law, at recital 50 and Article 8(2)(c), not an Article 7 provision.

    Labelling: three clocks, not one.

    The most expensive PPWR mistake available right now is reprinting artwork in 2026 for a pictogram the Commission has not published. Each Article 12 obligation runs on its own conditional date.

    MarkingEarliest applicationConditions and exclusions
    Manufacturer and importer identification: name, brand, postal address, electronic contact, plus a batch or identification feature12 Aug 2026Art. 15.6 for manufacturer identity, Art. 15.5 for the type, batch or serial element, Art. 18.3 for importers. Live now, alongside the Declaration of Conformity duty. May sit on pack or on a data carrier, with accompanying documents allowed only where on-pack marking is not feasible.
    Harmonised material composition label, pictogram-based, for consumer sorting12 Aug 2028, or 24 months after the implementing act, whichever is laterThe exclusion for transport packaging and deposit-return packaging, except e-commerce packaging, attaches to this Article 12(1) label only; deposit-return packaging under Article 50(1) must still carry a clear and unambiguous label. Supersedes divergent national sorting label schemes in the harmonised area. The 24-month clock runs from the Article 12(6) or 12(7) implementing acts, whichever is later, and both were due 12 August 2026.
    Recycled content share label, voluntary12 Aug 2028, or 24 months after the implementing act, whichever is laterArticle 12(4). Not mandatory, recital 67 is explicit on this. If displayed, it must follow the harmonised specification and the Article 7(8) calculation methodology, so it cannot be finalised before that method is.
    Reusable packaging label plus QR or open digital data carrier12 Feb 2029, or 30 months after the implementing act enters into force, whichever is laterOpen-loop reuse systems with no system operator are outside this obligation.
    Recyclability performance grade, Design for Recycling criteria1 Jan 2030, or 24 months after the actAnnex II Table 3 grades A at or above 95%, B at or above 80% and C at or above 70%, scored on a weighted recyclability assessment, not a weight fraction. Below grade C, no EU market. Article 6(10) lets non-compliant innovative packaging stay on the market for up to five years. From 1 January 2038, grade B or better.

    A QR code supplements the harmonised sorting label, it never replaces it. Manufacturer identity and batch data are more flexible: Article 15.6 allows identity on a data carrier, and Article 15.5 allows the batch element in accompanying documents where on-pack marking is not feasible.

    Article 12(12) adds a run-off: packaging manufactured in the Union or imported before a labelling deadline, and which does not meet the new label rules, may still be made available on the market for three years from the date the requirement enters into force. Existing artwork does not become unsellable overnight.

    What you need to collect

    A Declaration of Conformity is only as good as the fields behind it.

    Every obligation on this page resolves to a data question. These are the fields the technical documentation actually needs, grouped the way the file is assembled. If you cannot fill a row from a system today, that row is your gap.

    01
    Packaging unit and composition
    check_circleBill of materials to component level, one row per part
    check_circleMaterial class and polymer type per component
    check_circleWeight per component, and each part's share of unit weight
    check_circlePackaging level: primary, grouped, or transport
    check_circleFood contact designation, per component not per pack
    02
    Recyclate and its proof chain
    check_circleRecycled content percentage per plastic component
    check_circlePost-consumer versus pre-consumer split, stated separately
    check_circleSupplier attestation or certificate, with issue date and validity
    check_circleRecycling process authorisation, where the part is food contact
    check_circleManufacturing plant and calendar year, since the target is a plant average
    03
    Substances and safety
    check_circleHeavy metal concentration declarations, Article 5.4
    check_circlePFAS presence above threshold in food contact packaging, Article 5.5
    check_circleSubstances of concern flags carried from supplier declarations
    check_circleTest reports and their date, where a declaration rests on testing
    04
    Operator identity and signature
    check_circleLegal entity placing the packaging on the market, per market
    check_circleAuthorised Representative mandate, where the producer is outside the EU
    check_circleNamed signee with function, country, and BOM category scope
    check_circleBatch or identification feature tying the pack to the record
    check_circleVersion history, so a superseded declaration stays retrievable
    Still open

    What the Commission has not decided yet.

    PPWR is in force, but several of its most consequential requirements wait on Commission acts that are not yet adopted. Knowing which decisions are still open is what separates a defensible plan from an expensive guess. Each one below changes something operational.

    Recycled content calculation and verification methodology
    AWAITING ACT Due to be adopted by 31 Dec 2026
    Decides
    What counts as recycled content, how chemically recycled material is treated under a mass balance approach, and how a percentage is verified. Article 7(8).
    Unblocks
    Signing feedstock and supplier contracts against a number that will still stand, and the recycled content share label that is built on this method. The targets run from 1 January 2030 or three years after this act, whichever is later, so this act also sets the real deadline.
    Design for Recycling criteria and performance grades
    AWAITING ACT Due to be adopted by 1 Jan 2028
    Decides
    How a packaging unit is graded A, B or C against the Annex II criteria, per material category, and therefore where the grade C threshold actually falls for your formats.
    Unblocks
    Which SKUs cannot be placed on the EU market from 2030, and the order in which to redesign them. The design for recycling obligation itself runs from 1 January 2030 or 24 months after this act, whichever is later, and the Commission is due to adopt it by 1 January 2028.
    Harmonised label formats, pictograms and material codes
    DEADLINE PASSED Was due 12 Aug 2026
    Decides
    The pictogram artwork, the material composition codes, accessibility requirements, and the specification for any accompanying data carrier. Article 12(6) and 12(7).
    Unblocks
    Final artwork. Until this is published no compliant label can be designed, and it also starts the 24 month clock on the labelling obligation itself. That deadline has now passed with no act adopted.
    Framework for modulating extended producer responsibility fees
    AWAITING ACT Due to be adopted by 1 Jan 2028
    Decides
    How recyclability performance grades translate into modulated producer fees, and how consistently member states apply that translation. It rides on the same Article 6(4) delegated acts as the grades themselves, at point (d).
    Unblocks
    The financial case for redesign. Once fees follow grades, recyclability stops being a compliance line and becomes a recurring cost line with a number attached. Under Article 6(8), modulated contributions apply 18 months after both the Article 6(4) delegated acts and the Article 6(5) implementing acts enter into force. The Article 6(5) acts cover the recycled-at-scale assessment and chain of custody mechanism, not fee modulation, and are due by 1 January 2030.
    Reuse rules: minimum rotations and target calculation
    AWAITING ACT Due to be adopted by 12 Feb 2027 and 30 Jun 2027
    Decides
    The minimum number of rotations a format must achieve to count as reusable, Article 11(2), due 12 February 2027, and how the reuse targets themselves are calculated, Article 30(3), due 30 June 2027.
    Unblocks
    Capital decisions on pooled and returnable transport packaging. The obligation to demonstrate achievement runs from 1 January 2030 or 18 months after the Article 30(3) act, whichever is later, and the economics turn entirely on rotation counts.

    These are the Commission's own deadlines, and five have already passed. The implementing act on the national producer register and the standardisation request for compostable packaging under Article 9(6) were both due 12 February 2026, and the harmonised label formats act under Article 12(6), the digital-marking methodology act under Article 12(7) and the waste-receptacle labelling act under Article 13(2) were all due 12 August 2026. None has been adopted. A draft implementing regulation on the producer register format was published for public feedback on 6 August 2026, with the consultation closing 10 September 2026. One piece of PPWR secondary legislation has been adopted: Delegated Decision (EU) 2026/429 of 25 February 2026, exempting pallet wrappings and straps from the Article 29(2) and 29(3) reuse requirement, published in the Official Journal on 6 May 2026 and in force since 26 May 2026. Our regulatory team follows each of these through the Official Journal and Commission consultation record. Where an act changes a date or a definition on this page, this page changes with it.

    Key features

    Built for the way PPWR data actually flows.

    task
    Declaration of Conformity automation
    Generate Declarations of Conformity automatically once the required compliance data is complete, then route each one to its assigned signee, ready to sign.
    database
    Regulation-structured data management
    Store packaging and supplier data in a PPWR-aligned structure, with every version of a declaration and its technical documentation stored and retrievable for audit, supporting the five-year single-use and ten-year reusable retention under Article 15(3).
    move_to_inbox
    Supplier data & contract intake
    Import supplier contracts, technical files, and packaging documentation, then link them directly to materials, products, and compliance records.
    Who it’s for

    Anyone placing packaging on the EU market.

    storefront
    For retailers and brand owners
    Every packaging type covered, with a declaration of conformity generated per market.
    picture_as_pdfPDF
    Readiness guide

    PPWR & DoC Readiness Guide

    What PPWR requires, how the Declaration of Conformity works, and the packaging data you need to start collecting now.

    Download the guide download
    Free · PDF · Takes 30 seconds

    Every declaration ready before the deadline.

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