The new Packaging Regulation: what applies now and what comes next

The new EU Packaging Regulation already applies, but its big visible change, harmonised labelling, is still to come. Understanding what to do now and what can wait avoids unnecessary reprints and opens the door to something more interesting: packaging that is also an information channel.

What is the PPWR?

Regulation (EU) 2025/40 on packaging and packaging waste, known as the PPWR, replaces the 27 national frameworks that existed until now with a single set of rules that apply directly in every Member State. It has applied since 12 August 2026, and its obligations will be phased in until 2040: recyclability, recycled content, minimisation, reuse and labelling.

It affects manufacturers, brands, importers and distributors placing packaging on the EU market, including e-commerce packaging.

What already applies since August 2026

The first obligations are not visible on the packaging, but in the file behind it:

• EU declaration of conformity for each type of packaging placed on the market.
• Conformity assessment and technical documentation demonstrating compliance with the applicable requirements.
• Packaging identification: each unit must allow its type and batch number to be identified.

The labelling timeline

The harmonised labels under Article 12 depend on implementing acts that the European Commission has yet to publish. Deadlines start counting from those acts, so the dates below are the earliest possible:

The regulation also provides a three-year period to sell off packaging made before each deadline, and will ban symbols that could mislead about sorting or recyclability once harmonised labelling exists. Meanwhile, national marking rules remain in force; in Spain, those of Royal Decree 1055/2022.

Why connected packaging will be at the centre

The PPWR confirms something we already saw coming: physical packaging doesn't have room for all the information it is asked to carry. Composition, sorting instructions, reuse, substances, languages for each market… The regulation's own answer is the digital data carrier.

A single QR code or NFC tag can do several jobs at once:

• Compliance: recycling, composition and EPR information in each country's language.
• Reuse: identify each package and record its rotations with OKO Logistics.
• Digital Product Passport: the same carrier can give access to the DPP when the product requires it.
• Brand experience: content, recipes, warranties or loyalty programmes with OKO Experience.
• Data: know where and when each product is scanned with OKO Analytics.

The key is that content is managed from a platform rather than printed: if a requirement changes, the information is updated without touching the packaging. That is the logic of connected packaging.

What to do now

1. Get your documentation in order. The declaration of conformity and technical documentation have been required since August 2026.
2. Don't reprint for labelling yet. The official designs don't exist yet; wait for the implementing acts.
3. Make room for the digital carrier. In your next redesigns, plan where the QR code or NFC tag will go.
4. Review your symbols and claims. Remove arrows and recyclability messages you can't justify.
5. Choose a platform, not just a code. A static QR code falls short; you need to be able to update content and measure.

This article is for information purposes only and does not constitute legal advice. Information updated October 2026.