PPWR August 2026 Update: 6 Changes That Matter

The European Commission published the second edition of its official FAQ on the Packaging and Packaging Waste Regulation (PPWR) on 31 July 2026, shortly before the Regulation’s general application date of 12 August.

It adds a large batch of answers to questions from the market. Many are technical. A smaller number change, or at least clarify, how companies should understand their responsibilities. These are the points worth acting on.

1. The name on the pack can determine who is the manufacturer

The biggest theme in the update is a question the market kept asking: when one company designs or sells packaging and another manufactures or fills it, who carries the obligations?

The Commission’s answer is now clearer. If packaging bears a company name or trademark, the economic operator under whose name or trademark it is placed on the market is generally the manufacturer under the PPWR, even when another operator physically makes or fills it. This holds even where the company selects standardised packaging and requests no design changes.

One narrow exception applies. Where the company whose name or trademark appears is a micro-enterprise and its supplier is located in the same Member State, the supplier is the manufacturer.

The consequence lands hardest on retailers. A retailer selling private-label products is generally the manufacturer of that packaging and carries the design, documentation and conformity duties of the role. A co-packer or supplier may perform parts of the work under contract, but the retailer cannot assume that the legal responsibility moved with those tasks.

Where one company’s name and another’s trademark appear on the same pack, neither takes priority by default. The decisive question is which company determines the packaging design and specifications. A licensor that prescribes the design may be the manufacturer. A licensor whose trademark merely appears, without controlling the packaging, may not be. That assessment is made case by case, based on the contracts and the real decision-making between the companies.

One more distinction matters: a manufacturer is not the same as a producer. The manufacturer holds product-compliance duties. The producer is responsible for extended producer responsibility in a given Member State. Depending on the supply chain, different companies may hold each role.

2. Existing stock does not have to be scrapped

The update settles a question that had been worrying operations teams. Packaging produced and held in stock before 12 August 2026, but not yet placed on the market, does not have to be destroyed, remanufactured or relabelled.

Where that stock needs a unique identifier and the manufacturer’s name and address under Articles 15(5) and 15(6), the information can travel in an accompanying document rather than being printed on the pack. Packaging already placed on the market before 12 August may remain there even if it does not comply with the PPWR.

For packaging made after 12 August, the accompanying-document route is narrower. It applies only where the size or nature of the packaging means that the identifier and manufacturer information cannot be affixed directly, judged case by case.

The clarification protects the value of warehouse stock, but it does not remove every documentation duty. Where information on pre-12-August packaging is missing or insufficient, the manufacturer must make best efforts to recover it—for example, from a former supplier, a successor company after an acquisition, or by carrying out its own assessment.

Permission to sell existing stock and the ability to demonstrate its compliance are not the same thing.

3. Early enforcement is correction-first

The Commission is explicit that enforcement from 12 August 2026 should not disrupt trade, supply chains or consumer access to goods.

If a Member State identifies a case of non-compliance listed under Article 62, it must first require the economic operator to end it. The operator should receive notice and a chance to correct the problem before the authority takes further measures. Only where the non-compliance remains unresolved may a Member State restrict or prohibit the packaging, or require its recall or withdrawal.

The Commission says authorities should support responsible operators through awareness-raising, requests for information and corrective-action requests with a reasonable timeline, rather than opening with a sanction.

This is not a general grace period. The FAQ sets no standard correction deadline, and companies should not assume that incomplete files can be assembled at leisure once an authority makes contact. The time allowed will depend on the circumstances.

Enforcement should begin with correction, but the window helps only if the company can produce the missing evidence within it.

4. Conformity documentation becomes more practical

Several answers make conformity documentation more workable.

The conformity assessment and EU Declaration of Conformity cover the packaging unit as a whole. For a bottle consisting of the bottle, closure and label, one assessment and one declaration can suffice, provided the declaration covers all components.

Traceability does not require a serial number for every item. A type, batch or serial number—or another identifier that links the packaging to its technical file and declaration—is sufficient.

Nor does every component need individual marking. For a yoghurt cup consisting of a cup, lid and sleeve, displaying the required information on one component of the sales packaging should be sufficient.

Related sizes may share one declaration where they contain the same product and the size difference does not affect any applicable requirement. Where characteristics or products differ, separate documentation may be needed.

The declaration must be available in one or more languages required by each relevant Member State, so translation and document control are part of PPWR readiness.

5. EN 13428:2004 is no longer sufficient on its own

The old substances-of-concern standard no longer proves compliance by itself.

Annex C of EN 13428:2004 may still be used until an updated harmonised standard becomes available, but the Commission states that it no longer creates a presumption of conformity with the strengthened substances-of-concern requirements.

The PPWR reaches wider, covering the presence and concentration of substances of concern in packaging materials, emissions and waste outcomes, and connecting these requirements to reuse, recycling and chemical safety.

Teams relying on the standard should treat it as a method and a starting point, not as complete evidence that Article 5 has been met.

6. Transport packaging must be assessed item by item

Using tape, stretch wrap, boxes and pallets together in a shipment does not make them one packaging item.

Each may have reached its final form before the shipment is assembled, and each may have a different manufacturer responsible for providing the technical documentation and information needed to demonstrate conformity.

The Commission confirms that distinct transport-packaging types—including pallets, pallet collars, wrappings and straps—require separate conformity assessments and declarations.

A flat cardboard box has reached its final form even though it still needs folding, and adding an ordinary shipment label does not normally make the company applying that label the manufacturer.

Companies assembling shipments from bought-in packaging should map the manufacturer and documentation route for each type rather than treating the finished pallet as one unit.

What companies should do now

The thread through these clarifications is the same: the August update is less about new targets and more about who owns each obligation, what evidence must exist and how the transition is policed.

Four actions follow:

1. Confirm the manufacturer for each packaging type. Check the names and trademarks on the pack, who commissions it and who controls its design.

2. Separate manufacturer and producer roles. Product compliance and EPR responsibility need not sit with the same entity.

3. Map the supporting documentation. Confirm who holds the technical file, who signs the declaration, how the packaging links to those records and whether the necessary translations exist.

4. Create a defensible stock record. Identify packaging made before 12 August 2026 and retain evidence of when it was produced or placed on the market. Where supplier information is incomplete, document the efforts made to recover it.

Existing stock is protected and early enforcement is intended to be correction-first. Neither point removes the need to know who is responsible and to have the evidence ready.

PSL helps brand owners, retailers and material suppliers map where their PPWR obligations sit, identify documentation gaps and sequence the work that follows.

To pressure-test who owns what across your packaging portfolio, get in touch.