What actually applies on 12 August 2026, and what does not
Most of the requirements you are currently being scared with do not apply on 12 August 2026. The empty space ratio, the sorting label, the mandatory recycled content percentage: all of those sit between 2028 and 2030. What does count from 12 August 2026 is a shorter and far more boring list, and most of it is paperwork.
On that date the PPWR, Regulation (EU) 2025/40 becomes applicable. What applies then: the heavy metals limit, the PFAS limits in food-contact packaging, the name and address of manufacturer and importer on the packaging, a batch number, technical documentation with an EU declaration of conformity, and the rules on environmental claims. That is the list.
What is not on it matters just as much for your budget. The European Commission guidance of 10 June 2026 states explicitly that you do not need to carry out the conformity assessment for recyclability while the delegated acts for it are still missing. Anyone selling you a full redesign today on the basis of recyclability grades is selling something that cannot yet be tested.
This checklist is a to-do list, not a context piece. Points 1 to 7 need to be done. Points 8 and 9 are about timing. Points 10 to 12 do not need finishing now, but they do determine what you send to print today. For a broader overview see PPWR 2026: what changes for your e-commerce packaging, and the breakdown per packaging type in PPWR per packaging type.
Last updated: 3 August 2026. This version corrects the earlier text on four points: the enforcement situation in the Netherlands, the identification duty for manufacturer and importer, the real application dates of the later requirements, and the absence of a sell-through period.
Which PPWR requirements apply on 12 August 2026 and which do not?
Short answer: seven widely quoted requirements do not apply on 12 August 2026. They are in the regulation, but with their own application date between February 2028 and January 2030. The ones that do start almost all concern documentation and what is physically printed on your packaging.
The table below comes straight from the articles of the regulation and from the Commission guidance linked above. Use it when a supplier or a consultant tells you something is "mandatory from August".
| Requirement | Article | Applies from |
|---|---|---|
| Heavy metals, sum of lead, cadmium, mercury and hexavalent chromium below 100 mg/kg | art. 5(4) | 12-08-2026 |
| PFAS limits in food-contact packaging | art. 5(5) | 12-08-2026 |
| Manufacturer name, address and contact channel on the packaging | art. 15(6) | 12-08-2026 |
| The same details for the importer | art. 18(3) | 12-08-2026 |
| Type, batch or serial number | art. 15(5) | 12-08-2026 |
| Technical documentation plus EU declaration of conformity | art. 15(2), annexes VII and VIII | 12-08-2026 |
| Rules on environmental claims on packaging | art. 14 | 12-08-2026 |
| Distributor duty to verify the details above | art. 19(2)(c) | 12-08-2026 |
| Minimum empty space in sales packaging | art. 24(4) | 12-02-2028 |
| Harmonised sorting label | art. 12(1) | 12-08-2028 |
| Label for reusable packaging | art. 12(2) | 12-02-2029 |
| Empty space ratio capped at 50 percent for e-commerce packaging | art. 24(1) | 01-01-2030 |
| Minimum recycled content in plastic packaging | art. 7(1) | 01-01-2030 |
| Share of reusable transport packaging | art. 29(1) | 01-01-2030 |
| Ban on the packaging formats in annex V | art. 25(1) | 01-01-2030 |
| Ban on double walls and false bottoms | art. 10(2) | 01-01-2030 |
That last row deserves a footnote, because it is counter-intuitive. Article 10(2) bans packaging that only increases perceived volume and carries no date of its own in the regulation text, which would suggest it applies immediately. The Commission guidance states on the basis of Article 70(1)(b) that the old minimisation requirements of Directive 94/62/EC and the standard EN 13428:2004 continue to run until the end of 2029, and that both paragraphs of Article 10 apply from 1 January 2030. Your double-walled gift box has a while yet.
Why there is no sell-through period and customs clearance is the trigger
The PPWR provides no transitional period for exhausting stocks. That does not mean what most sellers think it means, because the trigger is placing on the market, not the sale to your customer.
The Commission guidance is unambiguous on this for the PFAS limits: food-contact packaging placed on the market after 12 August 2026 must comply, while packaging placed on the market before that date may remain on the market and does not need to be withdrawn. There are no exceptions for packaging containing recycled material.
Placing on the market is defined in Article 3(1)(10) as the first making available on the Union market. For anyone producing in Asia the translation is blunt: the guidance refers to the Blue Guide and states that for imported packaging or packaged products the relevant timestamp is the release for free circulation at the end of the customs procedure. The date on your clearance document determines which regime your shipment falls under.
| Scenario | Timing | Which regime |
|---|---|---|
| Container cleared on 11 August 2026 | released for free circulation before the date | old regime, stock can be sold as is |
| The same container cleared on 13 August 2026 | released after the date | PPWR applies to the whole shipment |
| Stock already in your warehouse and placed on the market before 12 August | already placed on the market | old regime, no withdrawal duty |
| New print order arriving in September | placed on the market after the date | PPWR applies |
For food-contact packaging there is a further wrinkle: sales and grouped packaging is placed on the market at the moment of filling and closing, while transport and service packaging is placed on the market empty. That difference decides which date counts for your product.
1. Inventory your packaging materials at SKU level
Without an inventory you cannot tick off any of the other eleven points. Build a table of every packaging component per SKU: product box, mailer, void fill, labels, tape, sleeve, insert card. Per component: material, supplier, weight and estimated annual volume.
The technical documentation in point 6 is built on this, the claim check in point 7 needs the material composition, and you cannot judge which packaging is affected at all until you know what you have. Most of the work sits in chasing suppliers, not in filling in the table.
Start with your highest-volume SKUs. A long-tail item with two orders a month can wait for the next print run; your bestseller cannot.
What we keep seeing in packaging projects like the ones for Nowhey and Maicura: brands have fewer distinct packaging components than they assume, and more SKUs sharing the same mailer or the same sleeve. That works in your favour, because one artwork revision then covers several products at once.
2. Put the name, address and contact channel of manufacturer and importer on the packaging
This is the heaviest of the requirements starting on 12 August 2026, and the one most often missed. Article 15(6) requires the packaging itself, or a QR code or other data carrier, to show the name, registered trade name or trade mark, postal address and where available the electronic contact channel. The postal address must point to a single contact point.
Article 18(3) places the same duty on the importer. So packaging produced in China for a Dutch brand will carry two address blocks, not one. On a small box or a mailer with little printable surface that is not a copy change but a dieline question.
The enforcement route makes this sharp. Your distributor, which includes your marketplace partner or retailer, has to check before offering that these details are present, and may refuse your product if they are not (Article 19). If the gap persists, the Member State has to take measures to withdraw the packaging from the market (Article 62).
In practice this is the reason to freeze artwork before 12 August on everything still going into production. In the middle of a packaging design project? Then the address block belongs in the dieline now, not in the next round.
3. Add a type, batch or serial number
Article 15(5) requires, on top of the identification details in point 2, a type, batch or serial number that makes the packaging traceable. This is a separate requirement, not part of the address block, and it starts on the same date.
A static type number per packaging type is enough for most e-commerce sellers. If you run production batches where the material composition varies, for instance because your board comes from a different supplier each run, you need a real batch number to keep the technical documentation consistent.
Print the number in the existing run. A sticker applied afterwards works, but costs you manual handling in the warehouse on every new batch. Plan the lead time for a new printing plate together with point 2, so it becomes one change instead of two.
4. Request test evidence for heavy metals
Article 5(4) caps the sum of lead, cadmium, mercury and hexavalent chromium in packaging at 100 mg/kg. This is not new in substance, but you now have to be able to prove it in your technical documentation.
Ask your supplier for a recent test report from an accredited laboratory. The packaging-specific test standard is EN 13695. RoHS and EN 71-3 reports also circulate and are regularly offered as evidence, but strictly speaking those cover electronics and toys. Do not accept them as a substitute.
If no usable report arrives within three weeks, order a test from an accredited EU lab yourself. Request three quotes, because the spread between labs is wide. Whatever it costs, it is less than a print run, and documentation with a hole in it gets expensive the moment someone asks.
5. Check PFAS in your food-contact packaging
If you sell food, a concrete limit applies from 12 August 2026 to PFAS in packaging in direct contact with the product. Article 5(5) sets three limits: 25 ppb per individual PFAS, 250 ppb for the sum, and 50 ppm including polymeric PFAS.
This hits grease-resistant pouches, coffee bags, baked-goods boxes and any coating meant to hold back fat or moisture. Many cheap grease-resistant coatings contain PFAS and are still sold freely in the Netherlands. Ask your supplier explicitly for a declaration with measured values, not a statement that something is "PFAS free" without numbers.
Watch the interaction with point 7. Once the limit applies, "PFAS free" on food-contact packaging is no longer a distinguishing feature but compliance with the norm. As a claim on your packaging that becomes a problem rather than a selling point.
6. Draw up the technical documentation and the EU declaration of conformity
Article 15(2) requires the manufacturer, before placing on the market, to carry out the conformity assessment, draw up the technical documentation of annex VII and draw up an EU declaration of conformity in line with Article 39. Those paragraphs carry no separate date, so they apply from 12 August 2026.
Annex VII is module A: internal production control. No notified body is involved. You declare on your own responsibility, on the basis of your own documentation. Annex VIII gives the model form the declaration has to follow.
The recyclability assessment does not have to be in there yet. The Commission guidance states that manufacturers do not need to carry out the conformity assessment for recyclability while the delegated acts under Article 6(4) are missing. The general requirement that packaging be recyclable carries no date of its own and therefore does apply, but for now it can only be tested against the old regime and EN 13430:2004.
Retention period: five years for single-use packaging, ten years for reusable, under Article 15(3). What goes into the file: the material composition from point 1, the heavy metals evidence from point 4, the PFAS declaration from point 5 and the substantiation of your claims from point 7.
7. Test your environmental claims against Article 14
The claims provision in the PPWR is Article 14, not Article 12. Article 12 covers labelling. Article 14 states that an environmental claim about a packaging property for which the regulation itself sets minimum requirements is only allowed if the claim exceeds those minimum requirements, and if you specify whether it refers to the packaging unit, part of it, or all the packaging you place on the market.
The design consequence is larger than it sounds. Once recyclability is a minimum requirement under the PPWR for your packaging category, claiming "recyclable" is not just pointless but not permitted: you would be presenting the law as your achievement. A sustainability story therefore has to rest on something demonstrably above the norm.
Article 12(8) additionally bans labels, symbols and markings likely to mislead about packaging sustainability. That connects to the parallel track in consumer law, which we worked out in what you can still put on your packaging from 2026. Compliance has to be demonstrated in the technical documentation from point 6, so claim and file belong together.
8. Plan your customs clearance and your artwork freeze around 12 August
This is not a material or design point but a calendar point. Because there is no sell-through period and placing on the market is what counts, the date of release for free circulation determines which regime an import shipment falls under.
Concretely: if you have a container in transit, find out when it clears. If that sits close to the date, moving it forward or holding it back is a real option with a real price tag. If it clears well before, that shipment falls under the old regime and you have time until your next print run.
At the same time you want an artwork freeze on everything not yet in production. Every print file produced after 12 August has to carry the address block from point 2 and the batch number from point 3. A file going to the printer today without those fields is a file you will pay to redo in the autumn.
9. Check your registration and contribution with Verpact
Anyone first placing packaged products on the Dutch market falls under extended producer responsibility and has to register with Verpact. That sits alongside the PPWR requirements above, but touches the same group of sellers and the same data from point 1.
Important for private label: the micro-enterprise exemption in the regulation only works if your supplier sits in the same Member State. Produce in China under your own brand and you are the manufacturer yourself, with all the documentation duties of point 6. According to the Commission guidance there is always exactly one manufacturer per supply chain, and if you produce under your own brand, that is you.
The exact thresholds and rates for the 2026 financial year are not settled at the time of writing, and Verpact maintains a page with the current state of play. So do not assume last year's situation still holds, and equally do not budget on figures that can still move.
10. Keep a panel free for the 2028 sorting label
The harmonised sorting label in Article 12(1) starts on 12 August 2028, or 24 months after the corresponding implementing act. The label for reusable packaging follows on 12 February 2029. Neither is a job for this summer.
It is a design job for now, though. The packaging you send to print this month will probably still be in use well into 2028. Reserving space on the panel where the label will go costs nothing today and saves you a full redesign round later.
The exact specifications come via implementing acts that do not exist yet, so naming a format would be guessing. What you can do: pick the panel where the label will sit, keep it empty, and lock it in the dieline as a no-go zone. Then it will not fill up with marketing copy at the next design round, and in 2028 you only have to fill it in.
11. Design for empty space ratio and mono-material now
The empty space ratio capped at 50 percent for e-commerce packaging sits in Article 24(1) and starts on 1 January 2030, or three years after the implementing act if that is later. The requirement on minimum empty space in sales packaging comes earlier, on 12 February 2028. The minimum recycled content in plastic packaging sits at 1 January 2030.
That looks far away until you lay your stock cycle next to it. A mailer you order now and use for two to three years lands exactly on that date. If you are placing a new order anyway, you may as well pick mono-material straight away: recycled board without coating, or a mono-PE pouch instead of a PET, aluminium and PE laminate.
A practical test you can run today: take the box for your highest-volume SKU, measure product volume and box volume, and divide. More than half air means it is already costing you money in shipping rates and will cost you compliance later. We worked out the arithmetic in packaging design and ROI.
12. Schedule your production run on your natural reorder moment
The last point costs you nothing and saves you a rush order. A packaging redesign plus a new production run easily takes three to four months in total, adding up design, production in Asia and shipping. Ask your supplier for their current lead time, because it moves by season. Whoever starts now will not be finished by 12 August.
Nor do they need to be. Because your existing stock falls under the old regime as long as it was placed on the market before 12 August, the right plan is not "as fast as possible" but "at your next natural reorder moment". Look at how many weeks of runway you have on the current packaging and schedule the change there.
What does have to happen this week is the artwork freeze from point 8, so that you do not accidentally receive a September print order built on the old files.
What happens if you are not ready on 12 August?
There is no fine amount in the Netherlands at this point. Anyone quoting you one is selling you something. The risk sits elsewhere.
The Dutch Packaging Management Decree 2014 still rests on the old Directive 94/62/EC at the time of writing, while that directive is repealed on 12 August 2026. An amendment is pending with no date of entry into force. The ILT enforcement strategy for packaging lists three offences and marks the administrative fine as not applicable for all three. What the ILT can do is warn, impose a penalty payment and, in the last resort, file a criminal report.
Member States have until 12 February 2027 to set and notify penalty rules. Administrative fines are in any case only mandatory for Articles 24 to 29, and those do not themselves apply until 2028 at the earliest.
Why sort it now anyway: the real risk is not a fine but your stock. Article 62 obliges the Member State, where non-compliance persists, to take measures to withdraw or recall the packaging from the market. And before that sits the distributor from point 2, who can refuse your product. A refused listing in peak season costs more than any fine.
Why we are holding redesigns back this summer
We have spent six years working with e-commerce brands on their packaging design, and the PPWR changes less about that than you would expect. What changes is the order: the address block and the batch number now belong in the dieline before the first design round, not as a print-ready correction afterwards.
What we are mostly steering clients away from this summer is the expensive redesign that is not needed yet. A packaging line missing only an address block and a batch number needs an artwork revision, not a new design. That is a different order of time and money, and it pushes the real redesign question to the moment the recyclability grades can actually be tested.
The order we work in: inventory and artwork freeze first, then the documentation, then the design question. What separates packaging that merely complies from packaging that also sells has nothing to do with this regulation, and we covered it in where buyers look on your packaging and what has to be on your packaging.
Send us your SKU list and book a call via the packaging page. You get back which points have to happen now, which can wait, and what each of those costs.
The date is fixed: 12 August 2026. For most sellers that means two fields in your artwork and one document in your folder. Turning that into a full redesign means paying for requirements that do not count until 2030.
