PPWR Regulation (EU 2025/40): What changes in August and how does it affect the industrial packaging chain?

On August 12, 2026, the first major phase of Regulation (EU) 2025/40 on packaging and packaging waste, known in the industry as PPWR (Packaging and Packaging Waste Regulation), came into effect.

Unlike former EU directives, the PPWR is a directly applicable regulation across all 27 Member States. This means it establishes uniform rules for the entire European market without requiring national transposition, supplementing existing national frameworks such as Royal Decree 1055/2022 in Spain.

What does the regulation require starting this august?

In this first stage, the PPWR requires a packaging conformity assessment, focusing primarily on three main pillars:

1. Clean composition: A mandatory declaration guaranteeing the absence of Substances of Very High Concern (SVHC) and compliance with chemical limits in the material.
2. Recyclability and traceability: Design and tracking requirements whose definitive technical methodologies will be finalized between the remainder of this year and 2027.
3. Supported technical documentation: Technical files proving the origin and composition of the materials used, which must be kept on file at the manufacturing facility for a period of 5 to 10 years.

Packacking manufacturers vs. Packaged product manufacturers: Who is responsable for what?

The regulation clearly distinguishes between the roles and obligations of each entity within the supply chain:

If you manufacture packaging or packaging components

You are responsible for performing the conformity assessment and issuing/signing the EU Declaration of Conformity. As a manufacturer, you are not required to proactively send it to every customer, but you must have it drafted, signed, and immediately available should a client or an official inspector request it.

If you manufacture or distribute packaged products

You must assume Extended Producer Responsibility (EPR) for all packaging and protective materials you place on the European market. This means you must request and archive the Declarations of Conformity for consumable items such as strapping, stretch film, or cardboard used in your processes.

Over the past few weeks, packaging facilities have already begun receiving formal information requests from their own customers, who need to ensure that every package in their catalog complies with the new European legislation.

Composition transparency: The HTP Global Hardboard guarantee

Faced with the need to certify the chemical composition of raw materials for the Declaration of Conformity, HTP Global Hardboard offers a clear and straightforward solution.

Manufactured via a wet process using solely natural wood lignin as a binder, our hardboard is completely free of synthetic glues and added resins. This natural composition simplifies the technical evaluation, guaranteeing the total absence of Substances of Very High Concern (SVHC) and streamlining the documentation required by the European framework.

PPWR implemantation timeline

 

Date	Requirements and obligations
February 2025	Entry into force of Regulation (EU) 2025/40.
August 12, 2026	General Application: Mandatory Declaration of Conformity on composition (SVHC), technical file available at the facility, and enforcement of empty space limits in grouped packaging.
2027-2028	Final definition of recyclability criteria (grades A–E), digital marking (QR codes), and standardized EU labeling.
2030	Mandatory minimum recycled plastic content targets and global goals for reuse and overall waste reduction.