The EU Packaging and Packaging Waste Regulation applied on 12 August 2026. There is no sell-through window for stock already made.
Phased in its substantive targets, immediate in its documentation duties — and the documentation is the part that needs your item master.
Who it binds
- Any manufacturer, importer or distributor placing packaged goods on the EU market, including UK exporters selling into the EU.
- Obligations attach per packaging type, not per product line, which is where most item masters turn out to be modelled the wrong way round.
What it actually demands
- A written EU declaration of conformity for each packaging type (Article 39 and Annex VII).
- PFAS restrictions in food-contact packaging: 25 ppb individual, 250 ppb combined, 50 ppm total fluorine. Heavy metals ≤100 mg/kg combined.
- Manufacturer or importer identification on the packaging or via a data carrier.
- A traceable identifier — type, batch, serial.
- EPR registration in each relevant member state.
The Regulation is expressly phased — labelling from 2028, recyclability grades and recycled-content minimums from 2030, reuse targets from 2030 — but there is no general sell-through relief for existing stock against the duties that applied on 12 August 2026. Anyone telling you the whole thing is a 2030 problem has read the targets and not the application date.
What it means for the estate
The declaration of conformity has to be produced per packaging type, which means the packaging bill of materials has to exist at component level and be linked to the material master, not held in a spreadsheet beside it.
The same component-level packaging BOM — material, weight, recyclability, recycled content — satisfies UK packaging EPR reporting and the deposit return scheme. Built once, it serves three regimes; built three times, it reconciles to none of them.
Supplier declarations of conformity need collecting, versioning and tying to the purchase record, because your declaration rests on theirs.
Caveat
The Commission's own announcement says the Regulation 'applies generally from 12 August 2026' — the qualifier is doing real work, and the phasing matters for planning. It does not create a grace period for the duties already in force.
Primary sources
Run the exposure check — three minutes, free, and it will tell you which of the other 11 dates catch you as well and in what order they have to be done. Sequencing is most of the cost on these programmes.