PPWR 2026: what changes for your business?

With the European Commission's recent guidelines and FAQ, one thing becomes clear:
the impact on businesses is greater and more concrete than many organisations realise today.

The PPWR is not a theoretical framework. It is an operational reality that directly affects your processes, responsibilities and documentation.

Why the PPWR is a gamechanger

Where the previous packaging directive mainly laid down general principles, the PPWR goes a step further. The regulation introduces:

• Directly applicable obligations in all member states
• Stricter requirements on materials and substances
• Mandatory recyclability of packaging
• Extensive documentation and conformity requirements
• A redistribution of responsibilities within the chain

The biggest pitfall: misjudging your role

One of the most underestimated elements of the PPWR is the distinction between different economic operators.

Companies today often assume that ultimate responsibility lies with their packaging supplier. However, the new guidelines show that this is often not the case.

Food companies that fill products in particular will often be considered the manufacturer, since they carry out the final processing step with the packaging. And that has direct consequences.

As manufacturer, you become legally responsible for a number of crucial obligations. You must carry out conformity assessments, draw up EU declarations of conformity, and collect and manage the necessary technical documentation. You must also be able to demonstrate that your packaging complies with the applicable material and design requirements. In other words: you bear ultimate legal responsibility for the packaging you place on the market. This represents a fundamental shift in responsibility that, in many organisations today, has not yet been translated into concrete action.

What specifically changes for packaging from 12 August 2026

The first obligations come into effect soon. A few important points to note:

1| Conformity becomes mandatory

• A conformity assessment must be carried out for every piece of packaging.
  This also applies to transport packaging such as pallets, film and strapping.
• Each packaging unit must have its own assessment and a separate EU declaration of conformity.

2| Stricter requirements on substances

The PPWR sets limits for:

• Heavy metals
• Substances of concern (SoC)
• PFAS (for food contact materials)

These substances are assessed at the level of the complete packaging, including inks, adhesives and coatings.

3| Recyclability becomes the standard

All packaging must be recyclable from 2026.
The further elaboration of "design for recycling" will follow later, but the basic obligation is immediately in force.

4| Responsibilities are more sharply defined

Not only manufacturers, but also importers and distributors bear responsibility when they place packaging on the market.

Why this requires action today

Although 12 August 2026 still seems far away, preparing for the PPWR takes time and structure. Companies will first need to gain insight into their role within the chain, in order to then gather the right information from suppliers. In addition, internal processes need to be adjusted, documentation structured, and responsibilities clearly embedded within the organisation.

Those who start too late run real risks. Think of audit problems, delays in the chain and increased legal liability. The impact of the PPWR will not be limited to compliance alone, but will also be felt in operational processes and commercial relationships.

From regulation to workable practice

The challenge of the PPWR lies not only in understanding the legislation, but above all in translating it into daily practice. What exactly do you need to do? Where do you start? And how do you ensure that this does not become an additional administrative burden, but instead delivers a more efficient process?

At AMNorman, we guide businesses through this transition, with a clear focus on feasibility and impact. We help you correctly determine your role in the chain, support you with practical implementation, and build compliant and workable dossiers together with you. In doing so, we ensure that everything is integrated into your existing quality processes, so that compliance is not a standalone exercise, but a strengthening of your organisation.

Where does your organisation stand today?

Are you unsure about your role within the PPWR, or about how well prepared your organisation is? Then now is the moment to get clarity.