New EU Packaging Rules — What You Need To Know

The PPWR unfolds in waves. Here are the four dates every glass and plastic packaging business needs in its calendar.

The PPWR applies to everyone in the supply chain, not just the brand that puts the product on shelf. Each actor carries distinct obligations, and failure at any point in the chain can trigger non-compliance for the whole.

The primary obligation holder under the PPWR. Must ensure all packaging meets substance restrictions (Art. 5), recyclability requirements (Art. 6) and, for plastic, recycled-content targets (Art. 7) before placing it on the EU market. Must carry out a conformity assessment procedure, draw up technical documentation and keep records for 5 years (single-use) or 10 years (reusable). In cases where an importer or distributor places packaging on the market under their own name, they assume manufacturer obligations.

Before placing packaging on the EU market, importers must verify that the manufacturer's conformity assessment has been correctly completed, that required technical documentation exists, and that substance and labelling requirements have been satisfied. Importers must keep a copy of the EU declaration of conformity for 5 or 10 years respectively and make it available to market surveillance authorities on request.

Distributors must verify that EPR registration is in place and that the packaging they handle satisfies the relevant requirements before making it available on the market. If they discover non-compliant packaging already in circulation, they must take corrective measures — including suspending supply. Distributors who modify packaging or place it under their own name are treated as manufacturers.

Material and component suppliers must provide the manufacturers they supply with all information and documentation necessary to demonstrate compliance — including substance declarations, material composition data and testing results relevant to recyclability assessment. A glass or plastic manufacturer cannot demonstrate conformity without adequate data from its upstream material suppliers.

The PPWR creates obligations across five distinct areas for glass and plastic primary packaging. Each pillar carries specific deadlines and requirements for manufacturers, importers and distributors.

Pharma & Medical Device Derogation: Immediate and outer packaging of medicinal products (human and veterinary) is derogated from the recyclability requirements of Article 6. Contact-sensitive plastic packaging for medical devices, IVD devices, infant formula, food for special medical purposes and related formats is derogated from the recycled-content requirements of Article 7. These derogations are subject to review by January 2035.

The regulation does not land all at once. Obligations arrive in waves between 2026 and 2038, giving businesses time to adapt — but only if preparation starts early. Design lead times, supplier qualification and material certification all take longer than most businesses expect.

The PPWR gives market surveillance authorities across the EU the power to act against non-compliant packaging. By February 2027, every Member State must have a penalty framework in place. Penalties are set nationally, so the level of financial risk varies by country — but the triggers for non-compliance are consistent across the EU.

A business is in formal non-compliance if: the EU declaration of conformity has not been drawn up or has been drawn up incorrectly; technical documentation is unavailable, incomplete or contains errors; product identification information (batch number, manufacturer details) is absent or false; recycled-content targets for plastic packaging are not met; non-derogated packaging formats fail recyclability grade requirements; or packaging contains prohibited substances above limit values.

Infringements can result in financial penalties, orders to withdraw packaging from the market, and publication of enforcement actions. The obligation to demonstrate compliance sits with the manufacturer — but importers and distributors who fail to verify manufacturer compliance before placing packaging on the market may also be held liable.

The scale of the PPWR's requirements for glass and plastic primary packaging, in four numbers.

Rather than managing separate relationships for product supply, substance compliance data, recycled-content sourcing and technical documentation, GAASCH PACKAGING brings everything together under one roof. From initial gap analysis and product selection through to declaration of conformity preparation and long-term compliance planning, we handle the full scope of what the PPWR requires of your primary packaging.

We focus exclusively on primary packaging in glass and plastic — the formats most directly affected by the PPWR's substance, recyclability and recycled-content requirements. That focus means we understand the specific constraints of your product category: the regulatory derogations that may apply, the material options available, and the design trade-offs between compliance, performance and cost. You are not working with a generalist distributor; you are working with a manufacturer who knows this terrain.

August 2026 is close; 2030 requires design and sourcing decisions that need to start now. Whether you need an immediate substance compliance review, a structured transition plan for your plastic range ahead of 2030, or a long-term programme covering the 2038 recyclability threshold, we build the engagement around your timeline and your product portfolio — not a generic off-the-shelf approach.

Speak to the GAASCH PACKAGING team today. We will review your current glass and plastic primary packaging formats, identify which PPWR obligations apply and when, confirm which formats qualify for derogation, and put together a clear, prioritised compliance plan — without disruption to your supply chain or product development calendar.

E-mail: contact@gaaschpack.eu
Phone: +32 (0) 2 454 14 11