PPWR 2026: what changes for food producers and e-commerce

The new European Packaging and Packaging Waste Regulation applies from 12 August. What is already in force, which obligations will arrive by 2030, and how food businesses should prepare.

Technical documentation, chemical substances, recyclability, labelling, recycled content and packaging reduction are becoming central considerations for businesses that produce and sell food, including those operating through marketplaces and digital channels.

A jar of preserves, a bottle of olive oil, a packet of pasta or a box of biscuits does not consist solely of the product it contains. Around the food there is an entire system comprising the container, its closure, the label, any outer carton and the packaging used for shipping. Each of these elements performs a specific function, but it also creates technical, environmental and documentary obligations that businesses need to understand.

Since 12 August 2026, this system has been governed by Regulation (EU) 2025/40 on packaging and packaging waste, commonly known as the PPWR, which stands for Packaging and Packaging Waste Regulation. The Regulation entered into force on 11 February 2025 and became generally applicable eighteen months later, progressively replacing the previous European directive on packaging.

The difference is not merely formal. A directive must be transposed through national legislation, whereas an EU regulation is directly applicable in the Member States. The PPWR therefore introduces a common framework intended to affect the design, manufacture, labelling, distribution and end-of-life management of packaging marketed in the European Union.

Its scope covers all packaging, regardless of the material used or the sector from which it originates. Glass, paper, cardboard, plastic, metal, wood and composite materials all fall within the new framework, as do sales packaging, grouped packaging, transport packaging and packaging used in e-commerce.

12 August 2026 is not the date of every obligation

One of the most frequent mistakes is to treat 12 August 2026 as the date from which every requirement contained in the PPWR becomes immediately mandatory. The Regulation instead follows a progressive timetable under which certain provisions already apply, while others require technical acts from the European Commission or will become operational between 2028 and 2030.

The date of 12 August 2026 marks the general start of the new system. From that point, the obligations assigned to the different economic operators, packaging conformity assessment, technical documentation and, for the food sector, the limits on PFAS in food-contact packaging become relevant.

Other measures, including the harmonised European label, the final design-for-recycling criteria, minimum percentages of recycled plastic and the limit on empty space in e-commerce packaging, follow later deadlines. Understanding this distinction allows businesses to avoid two opposing risks: overlooking obligations that already apply or immediately incurring costs for adaptations that have not yet been fully defined at technical level.

Manufacturer and producer do not always identify the same business

The PPWR assigns different responsibilities to manufacturers, importers, distributors and producers subject to extended producer responsibility. In everyday language these terms are often used as though they were interchangeable, but under the Regulation they identify different legal roles.

The manufacturer is the party responsible for the conformity of the packaging. Before placing it on the market, the manufacturer must perform, or have performed, the conformity assessment procedure required by the Regulation, prepare the technical documentation and draw up the EU declaration of conformity.

A food business that purchases standard packaging from a European supplier does not automatically become the manufacturer of that packaging. The position may change, however, when a company has packaging designed or manufactured and markets it under its own name or trademark. The Regulation also establishes specific rules for microenterprises that commission customised packaging from a supplier established within the European Union.

Within the extended producer responsibility system, the producer is instead the party that makes packaging or a packaged product available for the first time in the territory of a Member State. This status becomes particularly important in cross-border sales, imports and e-commerce.

The first task for a food business is therefore to reconstruct its supply chain and assign each role correctly. It is necessary to understand who designs the packaging, who manufactures it, who imports it, under whose trademark it is marketed and who first places the packaged product on the market in each country.

Without this mapping exercise, it becomes difficult to establish who must prepare the documentation, who must retain it and who is responsible for any non-conformity.

The EU declaration of conformity for packaging

One of the most important requirements is the EU declaration of conformity. Article 15 establishes that, before placing packaging on the market, the manufacturer must perform the conformity assessment referred to in Article 38 and prepare the technical documentation specified in Annex VII.

If the assessment demonstrates compliance with the applicable requirements, the manufacturer draws up the EU declaration of conformity using the structure set out in Annex VIII. Through this document, the manufacturer assumes responsibility for the conformity of the packaging.

The declaration is not the same as CE marking. The PPWR does not introduce a specific CE mark for packaging, since such a symbol could be confused with marking that applies to the product contained in the package.

The documentation must make it possible to identify the packaging, reconstruct its design and understand its manufacturing process. It must also contain the assessments, technical specifications and, where necessary, test reports used to demonstrate compliance with the applicable requirements.

The manufacturer must retain the technical documentation and the declaration for five years in the case of single-use packaging and for ten years in the case of reusable packaging. Traceability must also be ensured through a type, batch or serial number, or another element that allows the packaging to be identified.

Suppliers of packaging and packaging materials must provide the manufacturer with the information and documents required to demonstrate conformity. For a food producer, this means that the relationship with a packaging supplier can no longer be limited to price, dimensions and visual appearance. Businesses need to request up-to-date documents, verify the model or batch to which those documents refer and store them in an orderly manner.

PFAS in food packaging: a limit that already applies

For food businesses, one of the most immediately relevant provisions concerns per- and polyfluoroalkyl substances, identified by the acronym PFAS.

PFAS are a broad family of synthetic chemicals characterised by strong resistance to water, grease and high temperatures. Because of these properties, they have also been used in certain coatings and treatments applied to packaging intended to come into contact with food. Their high persistence in the environment and their potential effects on health have led the European Union to establish specific limits on their presence in food packaging.

Since 12 August 2026, food-contact packaging cannot be placed on the market when it contains PFAS at concentrations equal to or above the limits established by Article 5 of the PPWR. The specified values are 25 parts per billion for PFAS measured through targeted analysis, with polymeric PFAS excluded from quantification, 250 parts per billion for the sum of PFAS measured through targeted analysis, and 50 parts per million for total PFAS, including polymeric PFAS.

Compliance must be demonstrated in the technical documentation. The European Commission has also clarified that there is no transitional period for exhausting stocks of packaging manufactured before 12 August 2026 but not yet placed on the market.

Food-contact packaging placed on the market before that date may remain on the market and does not have to be withdrawn. Packaging placed on the market after that date must comply with the new limits, including packaging that contains recycled material.

For a food business, receiving a generic declaration that a material is suitable for food contact is not sufficient. The business should verify that the supplier's documentation expressly addresses the PPWR requirements relating to PFAS and precisely identifies the material and packaging model supplied.

The new European label is not yet mandatory

The general application of the PPWR does not result in the immediate replacement of the current Italian environmental labelling system.

Article 12 provides for a future harmonised European label, based on pictograms and containing information on the material composition of packaging, with the aim of helping consumers sort packaging waste correctly in every Member State.

The obligation will apply from 12 August 2028 or twenty-four months after the entry into force of the relevant implementing acts, whichever date is later. Until the transition to the harmonised system, the applicable national provisions remain relevant.

According to the guidance published by CONAI, the current Italian environmental labelling system may be maintained until 11 August 2028. For packaging intended for the final consumer, this system includes the identification code of the packaging material and waste collection instructions.

Businesses redesigning their labels and packaging today should nevertheless take the future transition into account. Providing sufficient graphic space, avoiding packs that are difficult to update and keeping product information separate from packaging information may reduce the cost of subsequent changes.

Recyclability and recycled content: preparations for 2030 begin now

One of the central aims of the PPWR is to make packaging placed on the European market recyclable. From 2030, recyclability will be assessed through performance classes identified by the letters A, B and C, based on technical design-for-recycling criteria.

Packaging that does not reach at least class C may not be placed on the market from 1 January 2030 or twenty-four months after the entry into force of the delegated acts establishing the technical criteria, if that later date applies. From 2038, class C will no longer be sufficient.

Minimum percentages of post-consumer recycled material are also established for plastic packaging. From 2030, or three years after the entry into force of the European act establishing the calculation methodology if that date is later, the minimum share will be 30 per cent for contact-sensitive packaging whose main component is PET, excluding single-use beverage bottles, 10 per cent for contact-sensitive packaging made from plastics other than PET, excluding single-use beverage bottles, 30 per cent for single-use plastic beverage bottles and 35 per cent for other plastic packaging.

The Regulation provides for exemptions and specific rules, particularly when the use of recycled material could compromise product safety or compliance with the legislation governing materials intended to come into contact with food.

For this reason, virgin plastic cannot simply be replaced with recycled plastic without a technical assessment. Food safety, substance migration, material stability, product shelf life and recyclability must be considered together.

Less volume and less empty space in shipments

From 1 January 2030, the manufacturer or importer will have to ensure that the weight and volume of packaging are reduced to the minimum necessary to guarantee its functionality, taking into account its shape and the material from which it is made.

The rule does not prohibit elements that are necessary to protect fragile food, preserve its characteristics or comply with hygiene requirements. It instead addresses elements that serve only to increase the perceived volume of the package, including double walls, false bottoms and unnecessary layers.

Specific provisions apply to grouped packaging, transport packaging and packaging used in e-commerce. By 1 January 2030, or three years after the entry into force of the act establishing the calculation methodology if that date is later, the maximum empty space ratio may not exceed 50 per cent.

Filling materials such as air cushions, shredded paper, bubble wrap, foam, wood wool and polystyrene chips are counted as empty space. The Regulation nevertheless recognises the need to protect liquid, fragile, irregularly shaped or easily damaged products.

For food packaging, air between or inside food products and protective gases used for preservation are not considered empty space. When a product settles during transport, conformity is assessed by considering the fill level at the time of packaging.

This provision directly concerns marketplaces and businesses that sell online. Using boxes that are theoretically recyclable will not be sufficient if the logistics system continues to ship oversized packages filled with large quantities of protective material. Compliance will have to connect product design, warehousing, the range of shipping boxes available and order preparation.

Why the PPWR also concerns marketplaces

The PPWR connects online sales with extended producer responsibility obligations. The Regulation provides for national registers in which producers must register when they make packaging or packaged products available for the first time in the territory of a Member State.

The system established by the Regulation also requires online platforms that enable consumers to conclude distance contracts with producers to obtain certain information before allowing those producers to use their services. This information includes the producer's registration details and a self-certification confirming compliance with extended producer responsibility obligations.

Platforms will be required to make their best efforts to assess the completeness and reliability of the information received, using public registers and the documentation available.

A marketplace is therefore not regarded solely as a commercial showcase. It becomes a point in the supply chain where product quality, completeness of information and operator compliance must come together.

For producers seeking to expand their online sales, preparing documentation and data in advance makes it easier to access new commercial channels. For a specialist marketplace such as 360ItalyMarket, it means selecting companies capable of supporting food quality with an organisation that is appropriate for the rules of the European market.

A review that should begin immediately

The PPWR does not require businesses to replace every package indiscriminately, but it does require them to understand and document what they use. An initial review should include an inventory of primary, secondary, transport and e-commerce packaging, identification of the manufacturer, importer and party responsible for conformity, collection of the available EU declarations of conformity and technical documentation, specific verification of PFAS limits for food-contact materials, analysis of materials and separable components, checks on package dimensions and empty space in shipments, planning for the graphic updates required by the future harmonised label, and verification of registration and extended producer responsibility obligations in the countries where the products are sold.

The assessment will need to be updated as the European Commission adopts the additional methodologies, technical criteria and implementing acts required by the Regulation.

Compliance becomes part of product quality

For many years, packaging was regarded primarily as a tool for preservation, communication and sales. The PPWR adds a further dimension: packaging must be designed, documented and managed as an integral part of product compliance.

For food businesses, this change does not concern the technical department alone. It involves purchasing, quality, marketing, production, logistics and e-commerce, because a choice made about packaging may affect food safety, product shelf life, transport costs, recyclability and the ability to sell in different European markets.

Preparing for compliance does not mean chasing every regulatory development at the last moment. It means building a supply chain in which every party knows which information it must produce, which documents it must retain and which characteristics it must verify.

For a producer seeking to join a marketplace, quality can no longer end when the food is packaged. It must continue through documentation, labelling, shipping packaging and the ability to demonstrate that each decision has been taken in accordance with the rules.

This article is provided for information purposes and does not replace a legal or technical assessment of the individual packaging solution and the specific business organization.

Official sources consulted

Regulation (EU) 2025/40, full text

European Commission guidance on the application of the PPWR

European Commission, Packaging and Packaging Waste Regulation

CONAI, tools and information on the new Packaging Regulation