PPWR in force for 15 days: the 3 questions we get every day

In shortSince 12 August 2026, the PPWR Regulation applies directly across the Union. Mandatory NOW is a single substantive requirement - Art. 5, substances - plus the documentation that proves it: Annex VII and the Declaration of Conformity (Annex VIII). Recyclability (Art. 6) becomes enforceable in 2030. The rest is a calendar, not a panic.

1. "What is mandatory right now?"

A single substantive requirement is already in force: Art. 5 - the restrictions on substances. The sum of heavy metals (lead, cadmium, mercury, hexavalent chromium) must stay below 100 mg/kg in any packaging, and food-contact packaging is subject to the PFAS restrictions. The idea is not new - but it is now a directly applicable regulation, not a transposed directive.

Added to this is the obligation to be able to prove it: every piece of packaging placed on the market needs technical documentation (Annex VII) and a Declaration of Conformity in the 8-point format of Annex VIII. In an inspection, these are the first things asked for.

Worth remembering: "I have test reports from my supplier" does not automatically mean "I have the documentation". The test reports are the evidence; Annex VII and the DoC are the documents that organise it in the form the regulation requires.

2. "My packaging is recyclable - so I am compliant?"

These are two different things. The design for recycling requirement (Art. 6) only becomes enforceable on 1 January 2030, based on the criteria in the delegated acts to be adopted by 2028. Until then, the recyclability assessment is optional in the declaration - recommended, because your partners ask for it, but optional.

Compliance today means: substances below the thresholds, complete documentation, declaration issued. Recyclability is tomorrow's compliance - and whoever assesses it now arrives in 2030 with the homework done.

3. "I have hundreds of packaging codes. How do I physically produce all these documents?"

Manually - with difficulty. The documentation is produced per code, and with a few hundred codes we are talking about thousands of pages that must stay consistent with each other: if the data sheet says one thing, the declaration cannot say another.

This is exactly why we built Yvora: you enter the packaging data once, and the data sheet, the technical documentation and the declaration are generated from it, always consistent. The complete technical file takes minutes, not days.

The next deadline in the calendar: 12 August 2028 - the harmonised composition label (Art. 12) and the new material codes. More on that in a future article.