Polygon One PPWR compliance software,
simple and fast.

The PPWR (Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40) is the new European packaging regulation. As an EU regulation it applies directly in all member states, with no national transposition. Its goals are to reduce packaging waste, make recyclability mandatory and strengthen the circular economy.

The PPWR (Regulation (EU) 2025/40) regulates the requirements packaging must meet to be placed on the EU market: substance restrictions, recyclability, recycled content, minimisation, reusability and labelling. Manufacturers demonstrate conformity with technical documentation and an EU declaration of conformity. The PPWR also carries extended producer responsibility forward, with registration in every member state where packaging is first made available. Duties follow from the role per packaging unit: manufacturer, producer, importer, distributor or authorised representative.

The regulation entered into force on February 11, 2025. Most obligations apply from August 12, 2026. Further requirements follow in stages from 2028, 2030, 2035 and 2038.

Practically every company placing packaging or packaged products on the EU market. Unlike the German Packaging Act, the PPWR covers all packaging, regardless of material or packaging type and regardless of whether it is subject to scheme participation. What matters is your role in the supply chain: manufacturer, importer, distributor, supplier, or producer under extended producer responsibility.

From that date, only packaging that meets the PPWR's requirements may be placed on the market. Manufacturers must carry out a conformity assessment for their packaging, compile technical documentation and issue an EU declaration of conformity. Labelling obligations and substance restrictions also apply, including PFAS limits for food-contact packaging.

With the EU declaration of conformity, the manufacturer confirms that its packaging meets the requirements of Articles 5 to 12 of the PPWR (substance restrictions, recyclability, recycled content, minimisation, reusability). It is based on a conformity assessment under Module A (internal production control) with technical documentation under Annex VII. The documents must be available to market surveillance authorities on request.

Usually yes. Anyone who has packaging designed or manufactured under their own name or trademark is the manufacturer, even if the supplier prints or fills it (Art. 3(1)(13) PPWR). Exception: if your company is a micro-enterprise (fewer than 10 staff, no more than EUR 2 million turnover or balance sheet total) and the supplier is established in the same Member State, the supplier is the manufacturer. More in the article on micro-enterprises and online retail.

Yes. Packaging and packaged products from third countries must meet the same requirements. Importers must ensure the manufacturer has carried out the conformity assessment and that the technical documentation exists. They must also state their name and contact details on the packaging.

Yes. The German Packaging Act ceased to apply on August 12, 2026 and was replaced by the Packaging Law Implementation Act (VerpackDG). It continues to govern extended producer responsibility in Germany; registration in the LUCID packaging register and scheme participation remain in place. The PPWR carries extended producer responsibility forward. In future, registration is required in every member state where packaging is first made available.

From February 2028, certain packaging (e.g. tea bags, fruit stickers) must be compostable. Harmonised labelling of material composition follows from August 2028 at the earliest. From 2030, minimum recyclability requirements apply (at least 70 percent, with performance grades), along with binding recycled content quotas for plastic packaging (10 to 35 percent depending on packaging type, higher quotas from 2040), weight and volume minimisation requirements, a maximum empty-space ratio of 50 percent for shipping, grouped and transport packaging, and bans on certain single-use plastic formats.

A distribution ban applies: the packaging, and with it the product inside, may not be placed on the market. Market surveillance authorities can order corrective measures, withdrawals or recalls. Penalties are set by the individual member states.

Packaging placed on the market before August 12, 2026 may generally continue to be made available. What counts is the moment of first placing on the market, not the sell-through. New goods are subject to the full conformity obligations from the cut-off date.

Polygon One keeps, per packaging unit, the master data per component (material, weight, food contact), the substance evidence for heavy metals and PFAS, the labelling requirements under Article 12 with their deadlines, the declaration of conformity under Annex VIII and the registration duties per target market, for Germany with LUCID registration and the volume report.

Software that maps the obligations of Regulation (EU) 2025/40 per packaging unit: master data per component, roles and duties, data collection from suppliers, technical documentation and the declaration of conformity under Annex VIII, EPR registration and retention for five to ten years. Polygon One covers these six areas in one platform; the criteria that count in a selection are set out in the comparison of 25 vendors.

The first step is clarifying roles: what function does your company have for each packaging unit in the supply chain? Your obligations follow from that, from conformity assessment through labelling to registration. Since, unlike other EU regulations, there is no central reporting portal, and conformity, EPR and labelling run separately, a structured process across all three tracks pays off.

Like all platform data, with Amazon Web Services in the Frankfurt am Main region (eu-central-1), in Germany. Details on certifications and data processing are on the page Hosting and data protection.