PPWR Declaration of Conformity Requirements In Effect As of August 12th, With EU Missing Deadline to Adopt Implementing Act on Recycling Labelling
As of August 12th, all packaging placed on the EU market must have a Declaration of Conformity documenting its components, as well as any substances of concern. While the Declaration of Conformity does not need to filed with customs, it may be requested during an audit by competent authorities to prove that applicable packaging may be circulated on the EU market.
However, one aspect of the Packaging and Packaging Waste Regulation did not meet its intended August 12th deadline. The EU Commission missed the deadline to adopt detailed rules for harmonised recycling labels and specifications under the law. A separate implementing act establishing the methodology for identifying the material composition of packaging using digital marking technologies was originally due on August 12th as well, yet the date came and went without the act being filed.
This means that companies subject to PPWR requirements must now await further instruction from the EU Commission regarding timing for this implementing act. Under Article 12, packaging will eventually have to carry a harmonised label providing consumers with information on its composition. This label will help consumers sort waste and recycle the packaging appropriately. The requirement to apply such labels is due to apply from August 12, 2028, or 24 months after the relevant implementing acts enter into force - whichever is later.
Trash bins will also have to have their own labels corresponding to the material-specific fractions they collect. The EU missed the deadline to establish specifications for these labels by August 12, 2026 as well.
While the Commission missed its deadline to pass the implementing act, companies placing packaging on the EU market must still abide by all other PPWR requirements that went into effect on August 12th lest their packaging be pulled from the EU market.
To learn more about how PPWR impacts your supply chain and what you can do to ensure your packaging is compliant, reach out to our team of policy experts today.
