New Packaging Rules from 12 August 2026: What the PPWR Will Bring

From 12 August 2026, the majority of the provisions of Regulation (EU) 2025/40 of the European Parliament and of the Council on Packaging and Packaging Waste (the Packaging and Packaging Waste Regulation – PPWR) will become directly applicable.

The PPWR replaces the existing Packaging Directive and introduces a harmonised regulatory framework applicable across all EU Member States, governing the entire lifecycle of packaging—from its design and manufacture to its placing on the market and the management of packaging waste. As an EU Regulation, the PPWR will apply directly without the need for transposition into Slovak legislation.

Certain obligations, particularly those relating to recyclability, recycled content and reusable packaging, will be phased in gradually, with additional requirements becoming applicable by 2030, 2035 and 2040. Nevertheless, 12 August 2026 represents a key milestone for businesses, and preparations should begin well in advance.

Who Will Be Affected?

The PPWR extends far beyond packaging manufacturers. It also applies to businesses that:

• manufacture or place packaged products on the market;
• import products or packaging from third countries;
• act as distributors or retailers;
• operate e-commerce businesses or online marketplaces;
• provide logistics or fulfilment services;
• provide packaging waste management services; or
• fulfil obligations under extended producer responsibility (EPR) schemes.

The scope of affected entities is therefore considerably broader than it may initially appear and is by no means limited to packaging manufacturers in the strict sense.

What Does This Mean for Your Business?

One of the most significant changes introduced by the PPWR is that packaging will no longer be regarded merely as a logistical or marketing component of a product. Instead, it will become an independent object of regulatory compliance.

Businesses will be required not only to ensure that their packaging complies with the PPWR requirements but, in many cases, also to:

• assess the conformity of packaging and prepare and maintain the required technical documentation;
• comply with new requirements concerning recyclability, recycled content, packaging minimisation and labelling;
• fulfil registration, notification and reporting obligations;
• correctly determine their role within the supply chain and identify the responsible entity qualifying as the „producer“; and
• review internal compliance processes and contractual arrangements with suppliers, customers and other business partners.

For most companies, compliance with the new rules will therefore require more than simply modifying their packaging. It will also involve establishing appropriate internal compliance processes, reviewing supply chain arrangements, updating contractual documentation and registering with the relevant national register where required.

What Sanctions May Apply?

The specific penalties for non-compliance have not yet been determined, as each Member State is responsible for adopting its own enforcement regime. However, it is already clear that:

• Member States must adopt rules on penalties for infringements of the PPWR by 12 February 2027;
• sanctions must be effective, proportionate and dissuasive; and
• enforcement measures may include prohibiting packaging from being made available on the market, requiring its withdrawal from the market or ordering its recall where formal non-compliance is identified.

Practical Recommendations

Given the scope and complexity of the Regulation, businesses should not wait until 12 August 2026 to begin preparations. We recommend that companies, in particular:

1. determine whether and to what extent the PPWR applies to their business;
2. identify their role within the supply chain (e.g. producer, importer, distributor or fulfilment service provider);
3. assess whether their packaging complies with the new regulatory requirements;
4. review existing contractual arrangements with suppliers and customers; and
5. establish internal processes to ensure compliance with the new obligations, including registration and reporting requirements.

The PPWR is a comprehensive regulatory framework that affects the entire supply chain—from manufacturing and imports to distribution, e-commerce and logistics. Businesses that fail to prepare in advance risk not only regulatory sanctions but also significant operational disruptions once the Regulation becomes applicable.

How We Can Help

Our Environmental Law team assists businesses in preparing for compliance with the PPWR. We provide support ranging from assessing the impact of the Regulation on specific packaging solutions and implementing compliance processes to reviewing contractual documentation and advising on regulatory obligations.

Should you require assistance in preparing for the new requirements, our team will be pleased to help.