European Commission says PPWR applies when packaging is placed on the EU market, not when it is made
The European Commission said on 21 August 2026 that PPWR compliance is triggered by the date packaging is placed on the EU market rather than its date of manufacture, so stock transferred to an independent retailer or distributor before 12 August 2026 is generally exempt, while stock still at a manufacturer's premises or with a logistics provider is not automatically covered. The Packaging and Packaging Waste Regulation became applicable across the bloc on 12 August 2026, replacing national rules and banning PFAS above set thresholds in food-contact packaging such as takeaway containers, bakery paper and pizza boxes. Labelling requirements for stock already made can be met through an accompanying document, so existing stock generally need not be destroyed or relabelled.
Why this mattersPPWR's entry into force and the Commission's stock-transition guidance together set the near-term compliance costs and reformulation timetable across the EU packaging supply chain.
- On 21 August 2026 the Commission clarified that the compliance date is when packaging is placed on the EU market, not when it is manufactured.
- Packaging transferred to an independent retailer or distributor before 12 August 2026 is generally treated as already placed on the market and is exempt.
- Stock held at a manufacturer's own premises or with a logistics provider is not automatically deemed placed on the market and must comply once placed.
- PPWR became applicable across the EU on 12 August 2026, banning PFAS above set thresholds in food-contact packaging.
- Labelling requirements for such stock may be met by an accompanying document; the Commission statement is interpretative and not a binding ruling.
- An EU-wide waste-sorting label applies from 2028 and, from 2030, empty-space limits, single-use plastic restrictions, reuse targets and recycled-content thresholds for plastic packaging.