2026-08-06

PPWR is changing the design and the system behind it

From 12 August 2026, the EU Packaging and Packaging Waste Regulation, PPWR, starts to apply generally across the European Union. [1][2]


For packaged brands, this is about more than legal text or new recycling symbols. PPWR creates a stronger connection between:


  • What appears on the packaging
  • Who is responsible for it
  • How it can be identified
  • What environmental claims are made
  • How consumers should handle it
  • What evidence exists behind every statement


The visible label is only one part of the change. Behind it, brands need a reliable system connecting artwork, materials, suppliers and documentation.




Every pack needs to be identifiable

From August 2026, packaging must carry a type, batch, serial number or another identifying mark. If the size or nature of the packaging makes this impossible, the information may in certain cases be provided in accompanying documentation. [1][3]


For brands, traceability means being able to connect every packaging version to the correct:


  • artwork
  • material specification
  • components
  • supplier
  • market
  • production version
  • compliance documentation


This is particularly important for portfolios containing several sizes, materials, closures or country-specific versions.




Responsibility needs to be visible

The packaging must also make it clear which company is responsible and how that company can be contacted. Relevant details may include:


  • registered company name or trade mark
  • postal address
  • electronic means of communication, where available [1][3]


This is not simply a question of adding a website. The information must make responsibility clear and work consistently across products and markets.




Environmental claims need proof

PPWR places greater focus on communication that could mislead consumers about sustainability, recyclability or how packaging waste should be handled. [1][3] 


Broad expressions such as “sustainable”, “green”, “eco”, “climate-smart” and “recyclable” can become problematic when they are vague, unqualified or unsupported. A stronger approach is to replace broad language with clear, verifiable facts:


  • a defined reduction in material or weight
  • a specified recycled-content percentage
  • precise sorting instructions
  • a documented material change
  • a clearly limited and supportable recyclability statement




Sorting information becomes part of the design system

PPWR introduces harmonised EU sorting labels intended to make it easier for consumers to understand the material composition of packaging and sort it correctly. The current target is for the requirements to apply from 12 August 2028, or 24 months after the relevant implementing acts are adopted. [1][3]


Until the final EU labels have been approved, NPA recommends continuing to use the Nordic sorting symbols in Sweden. [3]


For brands, this means sorting information should not be added wherever there happens to be space. It needs to become part of the pack’s information architecture.


Multi-component packs may need separate instructions for the main container, labels or sleeves, caps and closures, inner bags, taps and dispensing components, outer boxes or secondary packaging.


Clear sorting information can strengthen trust, but only if it is easy to understand and visually prioritised without overpowering the brand.




Existing symbols and market versions need to be reviewed

The use of the Green Dot changes from 12 February 2027. If used to communicate producer responsibility, it may no longer appear as a standalone symbol and must instead be presented through a QR code or equivalent digital solution that clearly explains its meaning. [3]


Packaging included in deposit-return systems will also need clear marking, with relevant PPWR requirements applying by 1 January 2029. [3]


Brands operating across several markets should therefore review:


  • Which symbols appear on each SKU
  • Local sorting and deposit requirements
  • Market-specific artwork
  • Obsolete packaging stock
  • Artwork changeover dates
  • Whether symbols could be misunderstood




The visible label needs an invisible system

A pack can only communicate accurately if the information behind it is structured and current.


For every packaging format, brands should be able to identify:


  • Every separate component
  • The material used in each component
  • The weight of each component
  • The relevant suppliers
  • How the components should be sorted
  • Recyclability assumptions
  • Plastics and other controlled materials
  • Environmental claims and supporting evidence
  • The correct contact and identification information
  • Applicable market and deposit-system requirements


This information should be connected to the right SKU and artwork version, not scattered across inboxes, old spreadsheets and supplier folders.




PFAS: a relevant August deadline

From 12 August 2026, food-contact packaging placed on the EU market must comply with the PFAS concentration limits established in PPWR. [1][2]


Relevant materials, coatings and packaging components therefore need to be assessed and documented. Brands should be able to show:


  • Which materials each pack contains
  • Whether relevant components contain PFAS
  • That applicable limits are met
  • That suppliers can provide declarations or test results


Claims such as “PFAS-free” should only be used when they can be properly substantiated.




Three dates to keep on your radar

12 August 2026

  • PPWR starts to apply generally
  • Packaging identification and contact-information requirements apply
  • Packaging communication must not mislead
  • PFAS limits apply to relevant food-contact packaging [1][2][3]


12 February 2027

  • New restrictions affect how the Green Dot and similar producer-responsibility symbols may be displayed. [3]


From 12 August 2028

  • Harmonised EU sorting instructions and certain additional labelling requirements are expected to apply, depending on the adoption of the relevant implementing acts. [1][3]




A quick check for packaged brands - Ask:


  1. Can every packaging version be identified and traced?
  2. Is it clear which company is responsible for the pack?
  3. Can every environmental claim be supported?
  4. Is sorting information clear for every component?
  5. Does the artwork contain symbols that need to be reviewed?
  6. Can the correct supplier and material data be linked to each SKU?
  7. Are future artwork changes coordinated across markets?
  8. Has relevant food-contact packaging been reviewed for PFAS?


The goal is not to add more information. It is to make sure the right information is visible, understandable and supported.



Sources:
[1] European Union - Regulation (EU) 2025/40 on packaging and packaging waste. 


[2] European Commission - Packaging waste and the Packaging and Packaging Waste Regulation. 


[3] Näringslivets Producentansvar, NPA - New EU Requirements for Packaging Labelling. 


[4] European Commission - Information on the implementation of the Packaging and Packaging Waste Regulation.