PPWR does not require a digital product passport for packaging. A passport is a voluntary addition. Reusable packaging must, however, carry a QR code or other data carrier from 12 Feb 2029 or 30 months after the implementing act, whichever is later (Art. 12(2)).
Dates
| Date | What | Legal basis |
|---|---|---|
| 11 Feb 2025 | Reusability criteria apply to packaging placed on the market from this date (enforced from 12 Aug 2026)Art. 11(1) | Art. 11(1) |
| 12 Aug 2026 | General application, including the general duty for packaging to be recyclableArt. 71; Art. 6(1) | Art. 71; Art. 6(1) |
| 12 Aug 2026 | Substances of concern minimised; lead, cadmium, mercury and hexavalent chromium at most 100 mg/kg in totalArt. 5(1) and (4) | Art. 5(1) and (4) |
| 12 Aug 2026 | PFAS limits for food-contact packagingArt. 5(5) | Art. 5(5) |
| 12 Aug 2026 | EU declaration of conformity and technical documentationArts 38-39; Annexes VII-VIII | Arts 38-39; Annexes VII-VIII |
| 12 Feb 2027 | If packaging in an extended producer responsibility scheme is identified as such, this may only be done with a symbol in a QR code or other digital markingArt. 12(9) | Art. 12(9) |
| 12 Feb 2028 | Compostability for the packaging listed in Art. 9(1), and design for material recycling of other packaging, including biodegradable plasticsArt. 9(1) and (3) | Art. 9(1) and (3) |
| 12 Aug 2028 or later | Harmonised label with material compositionArt. 12(1) | Art. 12(1) |
| 12 Feb 2029 or later | Label and QR code on reusable packagingArt. 12(2) | Art. 12(2) |
| 1 Jan 2030 | Minimisation of weight and volume (Art. 10(1)). Paragraph 2 has no date of its own; Commission guidance applies 1 Jan 2030 to it as wellArt. 10 | Art. 10 |
| 1 Jan 2030 or later | Design for recycling; grades A to C onlyArt. 6(2)(a) and (3) | Art. 6(2)(a) and (3) |
| 1 Jan 2030 or later | Recycled content in plastic (2030 targets)Art. 7(1) | Art. 7(1) |
| 1 Jan 2035 | Separate collection and sorting; the recycled-at-scale requirement applies from 1 Jan 2035 or 5 years after the Commission implementing acts (Art. 6(5)), whichever is laterArt. 6(2)(b) | Art. 6(2)(b) |
| 1 Jan 2038 | Only recyclability grade A or BArt. 6(3) | Art. 6(3) |
| 1 Jan 2040 | Higher recycled content targets for plasticArt. 7(2) | Art. 7(2) |
Several dates depend on when the Commission adopts delegated or implementing acts. In those cases the later of the two dates applies.
Until the design-for-recycling delegated acts apply, recyclability is assessed under the Packaging Directive's requirements and EN 13430:2004 (Commission guidance C/2026/3084, section 6).
Who is affected
The manufacturer has the obligations in Art. 15. The manufacturer is whoever manufactures packaging or a packaged product. Where a business has packaging or a packaged product designed or manufactured under its own name or trademark, that business is the manufacturer, typically the company that fills and sells the goods under its own brand. If that business is a micro-enterprise and the supplier of the packaging is located in the same Member State, the supplier is the manufacturer (Art. 3(1), point (13)). Suppliers of packaging and packaging materials must give the manufacturer the information and documentation needed to demonstrate conformity (Art. 16). Importers and distributors have obligations of their own (Arts 18 to 21).
Which documents are required
- An EU declaration of conformity for each packaging type (Annex VII, point 4), following the structure set out in Annex VIII (Art. 39(2)). The declaration must state that fulfilment of the requirements in Articles 5 to 12 has been demonstrated, and it must be kept up to date.
- Technical documentation under Annex VII, point 2: an analysis of the risks of non-conformity, the applicable requirements and elements (a) to (f), including description, drawings and materials, standards applied and test reports.
- The declaration and technical documentation are kept for 5 years for single-use packaging and 10 years for reusable packaging, counted from the date the packaging was placed on the market (Art. 15(3) and Annex VII, point 4).
- Conformity assessment is by internal production control, Module A (Art. 38, Annex VII). No notified body is involved.
How we support it
- The declaration template follows Annex VIII point by point, using the official Danish and English wording.
- Every data field shows its reference, such as "Art. 5(4)", and whether the requirement applies now or from a later date.
- Issued declarations never change. A new issue becomes a new version, and previous versions are kept.
- The supplier portal refers to suppliers' information duty under Art. 16.
See what it means for your products
In a walkthrough we start from a few of your own products.
These pages are an overview, not legal advice. Always read the legal act in the Official Journal.