PPWR · 12 August 2026
PPWR from 12 August 2026: what actually changes, and what does not
Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation, applies from 12 August 2026. It replaces the 1994 packaging directive with one directly applicable law across all 27 member states. Most of what lands on that date is registration and paperwork, not a redesign of your boxes. The rules that will actually force you to change packaging, recycled content minimums, the harmonised sorting label, and the cap on empty space, arrive in 2028 and 2030.
What actually applies on 12 August 2026
Six things become live obligations on that date for anyone placing packaging on the EU market:
- Registration in national producer registers. You have to be registered in each member state where you first make packaging or packaged products available, and be able to produce that registration number on request.
- An authorised representative for EPR in every member state where you are not established. Appointed by written mandate, one per country. A non-EU seller shipping to five countries needs five appointments.
- Conformity assessment, a declaration of conformity, and technical documentation for each type of packaging you place on the market. This is the CE-marking pattern applied to packaging, and it is the obligation most sellers have not started.
- Substance limits. The sum of lead, cadmium, mercury and hexavalent chromium in packaging is capped at 100 mg/kg, and PPWR sets concentration limits for PFAS in food-contact packaging.
- The minimisation duty. Packaging must be reduced to the minimum weight and volume needed for function, safety and hygiene. No percentage is attached yet, but the duty itself is live.
- Checks by everyone downstream. Distributors have to verify that the producer is registered, fulfilment providers have to check compliance before handling goods, and online marketplaces have to make best efforts to verify producer registration information.
The one that catches Shopify sellers
Conformity documentation is per packaging type, not per product. If you ship in three mailer sizes and two carton sizes, that is five types needing a declaration of conformity and supporting technical documentation, whether you designed the packaging or bought it off a shelf. Start asking your packaging supplier for theirs now, because you are the one placing it on the market.
What is not happening in August, whatever you have read
Most coverage compresses the whole regulation into one date. The obligations that would genuinely change your packaging are staggered over the following four years.
| Requirement | Applies from |
|---|---|
| Registration, EPR representative, conformity documentation, substance limits, minimisation duty | 12 August 2026 |
| Harmonised sorting label with EU-wide pictograms (Article 12) | 12 August 2028 |
| Maximum 50% empty space in e-commerce, transport and grouped packaging (Article 24) | 1 January 2030 |
| Minimum recycled content in plastic packaging, 10% to 35% depending on type | 1 January 2030 |
| Reuse targets and bans on specified single-use plastic formats | 1 January 2030 |
The empty-space rule, specifically
You will see the void-space cap quoted as an August 2026 obligation, and sometimes at 40%. Both are wrong. Article 24 sets a maximum empty space ratio of 50% for grouped, transport and e-commerce packaging, and it applies by 1 January 2030, or three years after the relevant implementing acts if that is later. What applies from 2026 is the general minimisation duty, which carries no number. The practical read: an authority can already challenge an obviously oversized parcel in 2026, but the hard 50% figure is not enforceable until 2030.
The suspension that did not happen
On 10 December 2025 the Commission published its Environmental Omnibus. One of the six proposals, COM(2025) 982, would have suspended the EPR authorised-representative rule in Article 45(3) of PPWR until 1 January 2035. A lot of supplier newsletters picked that up and told sellers the requirement was going away.
It did not. The suspension was aimed at producers already established somewhere in the EU, and in June 2026 the Council reported that negotiations had been discontinued because a large majority of member states had strong reservations. The adopted text stands. Plan against the law in force, not against a proposal that stalled.
If you are outside the EU, this was never your escape route
A producer with no establishment in any member state needs a representative in each country it sells into, both under PPWR from 12 August 2026 and, in several countries, under national law that already applies today. Spain and France do not wait for August.
What this means if you sell on Shopify
PPWR does not create a single EU packaging registration. It harmonises the rules and then leaves you registering, reporting and paying country by country, through the national scheme and the national register in each market. If your Shopify Markets settings let customers in Germany, France, Italy, Spain and the Netherlands check out, that is five registers, five schemes, five sets of representative paperwork, and five annual declarations.
The volumes you declare come from your packaging, not your products, so the data you need is unglamorous: for every SKU, what it ships in, what that packaging is made of, and roughly what it weighs. Most stores have never recorded this anywhere. That is the real August work, and it is the part nobody can do for you at the last minute.
A realistic sequence for the next few weeks
- List every packaging type you ship in, including tape, void fill and inserts
- Ask each packaging supplier for their declaration of conformity and material data
- Record material and weight per packaging type, then map it to your SKUs
- Confirm which EU countries you actually ship to, and in what volume
- Appoint an authorised representative in each of those countries where you have no entity
- Register in each national producer register and keep the numbers where a marketplace can be shown them
- Diarise 12 August 2028 for the harmonised sorting label and 1 January 2030 for recycled content and empty space
How Assuro helps
Assuro connects to your Shopify store, totals packaging by material across your catalogue, flags the countries where you ship without a registration on record, and tracks the deadlines that follow. It organizes and flags. It does not act as your authorised representative, register you, issue a declaration of conformity, or certify packaging.
Frequently asked questions
Does PPWR replace my Germany LUCID or France Citeo registration?
No. PPWR harmonises the rules but keeps registration and reporting national. You still register in LUCID for Germany and hold an identifiant unique for France, and you still pay each national scheme separately.
Is the 50% empty space rule in force from 12 August 2026?
No. Article 24's maximum empty space ratio of 50% for e-commerce, transport and grouped packaging applies by 1 January 2030, or three years after the relevant implementing acts if that is later. What applies from August 2026 is the general duty to minimise packaging, with no percentage attached.
Was the authorised representative requirement suspended?
No. The Commission proposed suspending Article 45(3) until 2035 in its Environmental Omnibus of 10 December 2025, but the Council discontinued negotiations in June 2026 after strong member state reservations. The requirement applies from 12 August 2026.
Do I need a declaration of conformity if I buy standard boxes and mailers?
Yes. The obligation sits with whoever places the packaging on the EU market, which is you when you ship a packed parcel to an EU customer. In practice you rely on documentation from your packaging supplier, so ask for it and keep it on file.
What happens if I am not registered on 12 August 2026?
The immediate risk is commercial rather than a fine: distributors, fulfilment providers and marketplaces are obliged to check registration, so the first symptom is usually a blocked listing or a fulfilment partner refusing stock. National penalties then sit on top, and they vary by country.
See where your store actually stands
Connect your Shopify store and Assuro flags which products are missing GPSR and EPR data, country by country, and tracks every deadline. Free to scan, no credit card.
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