The EU Packaging and Packaging Waste Regulation (PPWR) is no longer something to prepare for. Regulation (EU) 2025/40 has applied since 12 August 2026. It replaces Directive 94/62/EC in all Member States and covers every type of packaging placed on the EU market.
Compliance in phases: what applies when
Since 12 August 2026, the following already apply:
• Heavy metals are limited and PFAS limits apply to food-contact packaging. There is no transition or sell-off period: packaging placed on the market after that date must comply.
• Before placing packaging on the market, the manufacturer carries out the conformity assessment, keeps the technical documentation and issues the EU Declaration of Conformity.
• Each economic operator has defined obligations, and extended producer responsibility applies in each Member State where packaging is first made available.
• Packaging must be recyclable as a general principle.
The next milestones follow quickly. Nevertheless, the marked dates depend on delegated or implementing acts:
• August 2028: harmonised labelling system, showing materials and how to sort them.
• January 2030: at least recyclability Grade C; minimum recycled content in plastic packaging; minimisation rules, including the ban on double walls, false bottoms and unnecessary layers that only increase perceived volume, with limited exceptions; the Annex V bans single-use cosmetics, hygiene and toiletry packaging for the accommodation sector.
• January 2038: at Grade B (recyclability of 80% or more).
For brands, this means packaging decisions made today will still be judged against rules that tighten for more than a decade.
Where Groupe GM Cosmética Portugal fits in
Under the PPWR, each packaging has one “manufacturer”: the operator who has the packaging or packaged product designed or manufactured under its own name or trademark. In private label projects that is usually the brand owner, who is therefore ultimately responsible for the EU Declaration of Conformity. But the brand cannot build that declaration alone. It depends on specifications, test reports, material data and supplier declarations that sit inside the manufacturing chain.
At Groupe GM Cosmética Portugal we have a dedicated team that follows the evolution of the legislation and turns it into practical support, with sustainability embedded throughout our formulation, production and packaging processes.
What brands should ask their manufacturer
As the PPWR phases in, a few questions can quickly reveal how prepared a manufacturing partner really is:
• Who is responsible for each part of the packaging documentation, and is this written into the contract?
• Can the manufacturer provide up-to-date supplier declarations and test reports, including PFAS and heavy metals for every packaging component?
• Has recyclability been assessed for each project, and which packaging would fall below Grade C with today's design?
• Is there a team tracking delegated and implementing acts as they are published?
For clients, this means working with a team that considers regulatory requirements from the first development brief, providing early guidance on packaging decisions so they can focus on launching. Let’s start the conversation.
