The EU packaging rules changed on 12 August 2026, and they apply to your packaging rather than your product. So, not the goods — the box, the bag, the wrap, the tape and the pallet. The rule is the Packaging and Packaging Waste Regulation, or PPWR, and it took effect in all twenty-seven EU countries at the same time.
This guide covers what you actually have to do about it. Not the whole Regulation, which runs to well over a hundred pages, but the parts that actually affect the exporter.
New: live training on exactly this. If you'd rather work through your own packaging list with a trainer on hand than piece it together from a guide, our new Understanding PPWR course covers the Declaration of Conformity and technical file in a 90-minute live online session.
Because the rule follows the packaging, not the company. If your packaging ends up on the EU market, it has to meet the EU rules, no matter where it was made.
The way it reaches you is through your customer. Your EU customer is the importer, and before they can bring your goods in, they have to check three things:
So in practice, your customer asks you for paperwork. That is the whole mechanism. If you cannot supply it, you have a commercial problem long before you have a legal one.
Two documents. They sound more intimidating than they are.
A short signed statement saying this packaging meets the rules. Think of it like a certificate of conformity you might already issue for a product. It is drawn up once for each type of packaging, not once for each shipment.
The evidence sitting behind that statement — what the packaging is made of, the design and drawings, any test results. This one stays with you. Your customer does not get a copy, and you should not send commercially sensitive information out with it.
You can outsource the testing, not the responsibility. Pay a laboratory or a certification body to do the testing for you by all means. But the technical file has to be your file. It is not enough to say your box supplier holds all that information, and no contract can pass the responsibility to somebody else. If an authority asks, it asks you.
This is the question that matters most, and it has a simple test.
The EU packaging rules put the legal responsibility on the "Manufacturer". That is not always the business that physically made the packaging. Work through each packaging item you use and ask two questions.
If yes, you are the Manufacturer, even though somebody else made it. Your printed cartons, your branded tape, your own-label boxes.
If yes, you are the Manufacturer, even with no branding on it at all. Foam inserts cut to fit your product. A bespoke crate built to your drawing. You ordered it and you decided the design, so it is yours.
Plain brown boxes, standard stretch wrap, ordinary tape, generic strapping, standard pallets — these belong to whoever produced them. Your job there is simply to get hold of their Declaration of Conformity and keep it.
The rule of thumb: branded or bespoke means you produce the paperwork. Off-the-shelf means you collect it.
There are two things that are worth knowing about getting information out of your suppliers, because where the supplier is based changes your position completely.
Article 16 of the Regulation obliges a supplier to provide the Manufacturer with the information and documentation needed to demonstrate compliance, and the Commission has confirmed they cannot refuse. The Northern Ireland position is set out in the Commission Notice on the application of the PPWR in respect of Northern Ireland.
The PPWR is not part of GB law, and no UK authority enforces it here, so quoting an EU article number at a supplier in Leicester might work as persuasion but it is not a right you can enforce. Make it a condition of purchase instead.
One last thing on ownership. Sticking a shipping label on a box does not make that box yours. A label is not branding.
Say you are sending a pallet of machine parts to a customer in the Netherlands. On that pallet:
One pallet, six packaging items, and you are the Manufacturer of two of them. That is normal. It is also why doing this once properly is worth the effort — the two Declarations you write cover every pallet you ever ship with that packaging.
Want to check exactly which PPWR requirements apply to your own packaging? Understanding PPWR shows you how to confirm the specific requirements against your commodity codes and destination markets, then covers exactly what your Technical Documentation and Declaration of Conformity need to contain, plus an audit-readiness checklist to keep them current.
The EU packaging rules send it to three different places:
No. This is the point that causes needless panic.
You need something that lets an inspector match the packaging to its Declaration — a type, batch or serial number. Batch level is fine. For a retail pack made up of a cup, a lid and a sleeve, marking one part is enough. Bought-in consumables like tape and generic bags are traceable at production batch level, which is how they already work.
Nobody expects you to serialise a roll of tape.
You are fine.
Packaging already on the EU market before 12 August 2026 can stay there. Nothing has to be withdrawn.
Packaging you made before that date and still have in stock does not have to be destroyed, remade or relabelled. When it goes out, you can provide the markings on an accompanying document instead.
The only catch is that this only covers old stock. For packaging made after 12 August 2026, the accompanying document is only allowed where you genuinely cannot mark the item itself.
Then the EU packaging rules do not apply. Packaging that stays in transit on its way somewhere outside the EU is not being placed on the EU market. The trigger is the goods being declared for release for free circulation. No release, no obligation.
Almost certainly not, and the Commission has said so.
Its published position is that enforcement of the EU packaging rules should not disrupt trade flows or supply chains. Goods will not be banned from the market just because the packaging paperwork is wrong. Where a problem is found, the authority has to ask you to put it right first and give you a reasonable amount of time. Only if you ignore that can it stop the packaging being sold.
Be careful how you read that, though. It is guidance about how inspectors should behave. It does not change the law, and it does not give you longer to get your paperwork together. The obligation to hold a Declaration of Conformity started on 12 August 2026 either way.
You may hear that Euro pallets are exempt. They are exempt from something quite specific — the labelling and rotation-reporting rules that apply to reusable packaging systems. They are not exempt from having a Declaration of Conformity, and there is no general exemption for transport packaging.
Six things to work through, roughly in this order.
Most of what changed in August 2026 is paperwork. What changes your packaging itself arrives on 1 January 2030.
That sounds a long way off. It is not, once you allow for redesign, testing and retooling lead times. Anyone whose packaging will need to change is better off starting the conversation with their supplier now. The European Commission's packaging waste pages carry the current detail on each requirement.
No. A label is not branding. You become the Manufacturer when the packaging carries your name or logo, or when it was made specially to your specification. A plain brown box with your delivery label on it still belongs to the box maker.
No. Your customer gets the Declaration of Conformity, once per packaging type. The technical file stays with you and is produced only if an authority asks for it, which means you should not be sending commercially sensitive design or test information out with your shipments.
It depends where they are. An EU or Northern Ireland supplier is obliged to provide it under Article 16 and cannot refuse. A Great Britain supplier is under no such obligation, because the PPWR is not part of GB law — so build it into your purchase terms rather than relying on the Regulation.
Only from the labelling and rotation-reporting rules that apply to reusable packaging systems. They still need a Declaration of Conformity, and there is no general exemption for transport packaging of any kind.
By the end of this 90-minute live online session, you'll be able to identify which PPWR requirements apply to a given piece of packaging for your specific commodity codes and destination markets, know exactly what your Technical Documentation and Declaration of Conformity need to contain, and apply an audit-readiness checklist to keep them compliant.
Dates: 21 September, 6 October, 4 November — all starting 1.30pm.
Price: £105 + VAT per delegate.
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