EU packaging regulation starts applying, creating immediate compliance checks for cargo entering the Union

**Verified facts**

Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) applies across the European Union from **12 August 2026**. It is directly applicable in all Member States and replaces the Packaging and Packaging Waste Directive, subject to specified transitional provisions. Its scope covers all packaging placed on the EU market and all packaging waste, including transport packaging used in international cargo movements.

For manufacturers, the immediate compliance architecture is material. Before placing packaging on the market, they must carry out a conformity assessment, compile technical documentation and, where conformity is demonstrated, issue an EU declaration of conformity. The declaration and technical file must generally be retained for five years for single-use packaging and ten years for reusable packaging. Packaging must also carry an identifying element, such as a type, batch or serial number, and manufacturer identification/contact information; limited alternatives apply where the packaging’s size or nature does not permit this.

Importers may place only conforming packaging on the market. Before doing so, they must ensure that the manufacturer has completed the conformity assessment and documentation, that applicable labelling and accompanying-document requirements are met, and that manufacturer identification obligations have been fulfilled. On a reasoned request from a national authority, importers must provide relevant conformity information and documentation within 10 days.

The Regulation retains a 100 mg/kg combined limit for lead, cadmium, mercury and hexavalent chromium in packaging or packaging components. From today, food-contact packaging may not be placed on the market at or above specified PFAS thresholds: 25 ppb for an individual targeted PFAS, 250 ppb for the sum of targeted PFAS, and 50 ppm for total PFAS including polymeric PFAS, subject to the Regulation’s measurement provisions.

Packaging already placed on the Union market before the applicable requirements took effect is not generally required to be retrospectively brought into line merely because it remains in distributor stock. That distinction makes the date on which packaging was first placed on the EU market operationally important.

**Analysis and operational relevance**

For Brazilian and other non-EU shippers, the PPWR is not a vessel-operating rule, but it can become a cargo-readiness and delivery-risk issue before or after ocean carriage. The practical exposure is greatest where exporters supply packaged consumer goods, food products, industrial parts in retail-ready packs, or empty packaging into the EU; act as importer of record; use their own brand; or alter packaging within an EU fulfilment chain.

Charterers, cargo interests and logistics providers should map which entity is the PPWR “manufacturer,” importer, distributor or fulfilment service provider for each packaging format. Purchase terms should allocate responsibility for specifications, PFAS and heavy-metal evidence, declarations of conformity, record retention and authority responses. Booking and shipping documents will not replace the technical file, but they can help establish when, by whom and into which Member State the packaged goods were first placed on the EU market.

A missing declaration, incomplete technical documentation or absent operator information is treated as formal non-compliance. The Regulation requires authorities first to require the operator to end that non-compliance; if it persists, packaging can be prohibited from being made available, recalled or withdrawn. This creates a credible risk of shipment holds, rework, customer disputes and delayed release rather than an automatic border-wide ban on all non-compliant cargo.

**Why this matters:** Packaging compliance is now a trade-control issue alongside product, customs and documentary compliance. The near-term priority is an auditable evidence chain from packaging supplier to EU consignee, especially for food-contact cargoes and multi-party shipments.