PPWR 2026: What Non-EU Sellers Must Prepare Before August

The PPWR enters application on August 12, 2026

The EU Packaging and Packaging Waste Regulation (PPWR, Regulation EU 2025/40) is a directly applicable regulation across all 27 EU Member States. Unlike directives, it does not require national transposition. It applies uniformly from August 12, 2026, creating a single set of packaging requirements for the entire EU market.

For non-EU sellers shipping products to France, this means a new layer of compliance on top of existing French EPR obligations. French EPR (Citeo registration, IDU, annual declarations) continues unchanged. PPWR adds packaging design, documentation, and labelling requirements that overlay on the existing system.

What changes for non-EU sellers in August 2026

PFAS ban in food-contact packaging: per- and polyfluoroalkyl substances (forever chemicals) are restricted in food-contact packaging above defined thresholds. If your products include food packaging with PFAS-based grease barriers or non-stick coatings, reformulation is required before August 2026. Substance restrictions continue: lead, cadmium, mercury, and hexavalent chromium remain limited to 100 milligrams per kilogram total across all four substances combined. This is unchanged from the existing Packaging Directive but now directly enforceable.

Documentation obligation: producers and importers must ensure technical documentation is available for each packaging type placed on the EU market. This documentation must demonstrate compliance with PPWR requirements and be available to market surveillance authorities upon request. For non-EU sellers, the importer or authorised representative bears this documentation obligation. Your French EPR mandataire should coordinate this alongside existing EPR registrations.

The recyclability grade system from 2030

From January 1, 2030, all packaging placed on the EU market must achieve a minimum recyclability grade of C on a scale from A (fully recyclable) to E (not recyclable). Grades D and E will be banned. From January 1, 2038, only grades A and B will be permitted.

The assessment methodology will be published by the European Commission before January 2028, but the core principles are already established in the regulation. Mono-material packaging compatible with existing sorting and recycling infrastructure will score highest. Multi-material laminates, dark rigid plastics not detectable by optical sorting, and packaging with non-separable components will score lowest.

For non-EU sellers, this means evaluating your packaging now rather than waiting for the detailed methodology. Packaging redesign takes 12 to 18 months including R and D, supplier qualification, testing, and production ramp-up. Companies that start the assessment in 2026 will have time to adapt. Those that wait until 2028 will face rushed and expensive redesigns.

Recycled content requirements

Plastic packaging will require minimum percentages of recycled content starting in 2030, with progressive increases through 2040. Contact-sensitive packaging such as food containers will have lower initial thresholds than non-contact packaging. Documentation proving the recycled content percentage and origin will be mandatory.

This affects non-EU sellers whose packaging is typically manufactured in Asia where post-consumer recycled plastic supply chains are less established. Building relationships with certified recycled content suppliers should begin now.

E-commerce packaging void ratio

The PPWR limits the void ratio in grouping and e-commerce packaging to 50 percent from 2030. Empty space and filler materials count toward the void calculation. Oversized boxes with excessive bubble wrap or air pillows will not comply. Packaging must be the minimum size necessary for product protection, transport safety, and required information display.

For Amazon FBA sellers, this means the packaging in which products arrive at the fulfillment centre and the packaging Amazon uses for shipment to the consumer are both subject to void ratio limits. Sellers shipping pre-packed products must ensure their packaging complies.

How our mandataire service covers PPWR

Our French EPR mandataire service includes PPWR compliance monitoring at no additional cost. We track the regulatory timeline, alert you to relevant changes, and provide guidance on packaging assessment. The setup fee of 490 euros and monthly fee of 249 euros per EPR category already include PPWR monitoring as part of the service.

For sellers who need detailed packaging compliance assessment, recyclability pre-evaluation, or reformulation guidance, we offer these as additional advisory services. Contact us through the application form to discuss your PPWR preparation needs alongside your EPR registration.

Labelling harmonisation timeline

The PPWR introduces harmonised labelling requirements across the EU, replacing the patchwork of national labelling rules. From 2028, packaging must display standardised recycling and material identification symbols. France currently uses the Triman logo and Info-tri sorting instructions, which are uniquely French. The PPWR will eventually replace these with EU-wide symbols.

For non-EU sellers, this is actually good news: one labelling design for all EU markets instead of country-specific versions. However, the transition period will require managing both French and EU labelling simultaneously.

Action checklist for non-EU sellers

Before August 2026: ensure your French EPR registration is current through a mandataire. Check packaging for PFAS in food-contact applications. Verify substance limits (lead, cadmium, mercury, hexavalent chromium under 100 mg/kg). Begin auditing packaging recyclability.

Before January 2028: prepare for recyclability grade assessment methodology publication. Start collecting packaging composition data for future documentation requirements.

Before January 2030: achieve minimum grade C recyclability for all packaging. Meet recycled content requirements for plastic packaging. Comply with void ratio limits for e-commerce packaging.

Our mandataire service tracks all PPWR deadlines and provides advance guidance. Apply through the form to get started.

The reusable packaging requirements

The PPWR introduces mandatory reuse targets for certain packaging types from 2030. While these primarily affect large producers and B2B packaging, non-EU sellers shipping in reusable transport packaging may benefit from eco-contribution exemptions under current French EPR rules. Packaging designed for reuse with documented reuse schemes can qualify for minus 100 percent eco-contribution bonuses from Citeo. If your logistics allow for reusable shipping containers between your warehouse and French distribution points, this is worth exploring.

Why starting EPR compliance now prepares you for PPWR

Companies that already have a French EPR mandataire in place are better positioned for PPWR because the data infrastructure is already established. Your mandataire already tracks your packaging materials, weights, and compositions for annual declarations. This same data feeds directly into PPWR documentation requirements. Companies starting from zero in 2026 face building two compliance systems simultaneously instead of extending an existing one.