Commission Delegated & Implementing Acts under PPWR: What Brands, Importers and Converters Need to Track

EU Commission PPWR Secondary Acts: What's Coming, What's Not, and What to Do Now

An older version of this article reported that a single "Commission guidance document" existed to explain Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation (PPWR). That was inaccurate. PPWR does not mandate, and the Commission has not adopted, a single consolidated guidance package. What the regulation does require — and what actually drives compliance — is a series of delegated and implementing acts to be adopted by the Commission between 2026 and 2028.

This article replaces the earlier narrative. It summarises the secondary-legislation calendar, the topics each act will cover, and the concrete work economic operators should start now so they are ready when the rules take effect.

The PPWR Secondary-Act Calendar

Article 64 of PPWR empowers the Commission to adopt the following acts. Dates are those written into PPWR; the Commission publishes the draft acts for public comment on Have your say before they enter the EU Official Journal.

• Article 44 (EPR register format) — implementing act, due by 12 February 2026. Sets the harmonised format and fields for national producer registers.
• Article 12 paragraph 6 (harmonised labelling pictograms) — implementing act, due by 12 August 2026. Finalises the pictograms and data-carrier specification that become mandatory on packaging from 12 August 2028.
• Articles 10, 11 and 29 (reuse, minimisation, reuse targets) — delegated acts, due by 12 February 2027. Refines reuse categories and methodology for calculating reuse targets.
• Article 24 (empty space for transport & e-commerce packaging) — delegated act, due by 12 February 2028. Adjusts the 50% empty-space ceiling and exemption criteria.
• Article 6 (Design for Recycling & recyclability grades) — delegated act, due by 1 January 2028. Spells out the assessment methodology for grades A, B and C under Annex II, Table 3. Packaging below the Grade C floor cannot be placed on the EU market from 1 January 2030.
• Article 7 (recycled content in plastics) — implementing act on the calculation methodology for post-consumer recycled content, expected in 2026–2027 ahead of the 2030 targets.

Already Adopted: The Pallet-Wrapping Delegated Act

On 25 February 2026 the Commission adopted the first delegated act under PPWR. It exempts plastic pallet wrapping (stretch film) and plastic strapping used in transport packaging from the reuse obligations of Article 29, on the basis that a 100% reuse mandate would create disproportionate logistics costs and hygiene risks without commensurate environmental gains. Pallet wrapping and strapping remain subject to every other PPWR obligation — recyclability, minimisation, substance restrictions and labelling.

Where the Binding Rules Already Live

While the secondary acts are being drafted, a large share of PPWR is directly applicable from 12 August 2026. Economic operators do not need to wait for a guidance document to comply with the following.

Declaration of Conformity — Article 39 & Annex VIII

Every economic operator placing packaging on the EU market must prepare and hold a Declaration of Conformity (DoC) for each packaging unit or group of packaging units from 12 August 2026. A single DoC may cover a family of functionally identical packaging (for example, identical bottles sold under different brand labels). Manufacturers and importers should be collecting and archiving DoCs from their supply chain now.

Recyclability — Article 6 & Annex II Table 3

PPWR defines three recyclability grades: A (≥95%), B (≥80%) and C (≥70%). Packaging that does not reach the Grade C floor is treated as not recyclable under PPWR and cannot be placed on the EU market from 1 January 2030. Grade C itself exits the market on 1 January 2038. Until the Commission's delegated act on assessment methodology is published (by 1 January 2028), operators should document their self-assessment using established industry references such as RecyClass and CEFLEX guidelines.

Substances of Concern — Articles 5 and 13

PPWR prohibits per- and polyfluoroalkyl substances (PFAS) in food-contact packaging above a threshold of 25 parts per billion for the sum of PFAS, and imposes limits on lead, cadmium, mercury and hexavalent chromium. In the absence of a harmonised testing standard, operators should use EN 17681-1 or equivalent validated methods and retain test reports with the technical documentation.

Empty Space — Article 24

From 12 August 2026, grouped packaging, transport packaging and e-commerce packaging must not exceed a 50% empty-space ratio relative to the product being packaged. Protective fillers (air pillows, foam) count toward total packaging volume, and the limit applies at the point of dispatch. The 2028 delegated act will refine the ratio and exemption criteria.

Harmonised Labelling and the Data Carrier — Article 12

Harmonised labelling becomes mandatory on 12 August 2028. The data carrier (typically a QR code) conveys two kinds of information: the PPWR labelling data set (material composition, sorting and reuse instructions) and, where the packaging category is covered by the Ecodesign for Sustainable Products Regulation (ESPR, Regulation (EU) 2024/1781), the Digital Product Passport. The DPP framework is governed by ESPR, not PPWR; PPWR's role is to specify the labelling pictograms and the on-pack data carrier through the 12 August 2026 implementing act.

What Economic Operators Should Do Now

• Audit your DoC pipeline: Ensure every packaging unit or family has a Declaration of Conformity prepared by the responsible manufacturer ahead of 12 August 2026.
• Document recyclability assessments: Record your methodology, inputs and estimated grade (A, B or C) now. The 2028 delegated act will validate methodologies already documented; undocumented claims will not survive audit.
• Test for substances of concern: Food-contact packaging and plastics should already be in the PFAS and heavy-metals testing queue.
• Check empty-space ratios: Review e-commerce and transport packaging against the 50% ceiling at the point of dispatch.
• Track EPR registration formats: The Article 44 implementing act (due 12 February 2026) will harmonise producer-register fields across Member States.
• Prepare for harmonised labelling: Start building the data set and data-carrier workflow now so that, when the 12 August 2026 pictogram implementing act is published, you can roll out labelling ahead of the 12 August 2028 deadline.

How PPWR Connect Helps

PPWR Connect tracks each secondary act as it moves through the Commission's "Have your say" portal and the EU Official Journal, updates your compliance checklists automatically, and maps every obligation to your packaging portfolio. You get audit-ready DoCs, documented recyclability assessments, and a labelling workflow that is ready for the data-carrier specification the moment it lands.

Start your compliance journey today — visit ppwrconnect.com to see how PPWR Connect can help your organisation meet every requirement of Regulation (EU) 2025/40.