New packaging rules restrict access to EU market

What is packaging?

For PPWR purposes, packaging means any item, irrespective of the material used, that is designed to contain, protect, handle, deliver or present products. Packaging is used by economic operators to transfer products to other economic operators or to end consumers.

The definition covers not only consumer packaging intended for direct sale, but also grouped packaging and transport or shipping packaging.

Current PPWR requirements

As of 12 August 2026, packaging may be placed on the EU market only if the following requirements are met:

• Packaging must contain only very low concentrations of heavy metals. Packaging intended to come into contact with food, is subject to additional restrictions on the concentration of PFAS.
• Manufacturers must prepare technical documentation for each packaging type. The documentation must contain information on, among other things, the composition, weight, and environmental impact of the packaging. Manufacturers must also ensure that the packaging can be identified and be traced back to them, for example through the use of a QR code or similar identifier.
• Manufacturers must draw up an EU Declaration of Conformity (DoC) confirming that the relevant packaging complies with the applicable PPWR requirements. In practice, the DoC serves as the passport for access to the EU market.
• Importers and distributors, including retailers, must be able to provide the technical documentation and the corresponding EU Declaration of Conformity issued by the manufacturer.

Future PPWR Obligations

Over the coming years, PPWR will introduce additional requirements relating to, among other things:

• Packaging labelling;
• Packaging sustainability and recyclability;
• Minimum recycled content requirements for certain types of packaging;
• Reuse, recycling and waste-management obligations for packaging and used packaging materials; and
• The registration of businesses placing packaging or packaged products on the EU market.

The PPWR in the Netherlands

The PPWR requirements described above apply in the Netherlands in the same way as in other EU Member States. Compliance will be supervised by the Dutch Human Environment and Transport Inspectorate (Inspectie Leefomgeving en Transport).

In addition, the existing Dutch extended producer responsibility (EPR) system for packaging remains in place. Businesses that place packaged products on the Dutch market are legally required to finance the collection, recycling, and recovery of packaging waste, including the operation of the Dutch deposit-return scheme. To facilitate this, the industry has established a waste management fund administered by Verpact.

Businesses that place more than 50,000 kg of packaging on the Dutch market per calendar year, or that place certain plastic disposable products or single-use plastics on the market, are currently required to pay a waste management contribution and submit periodic declarations to Verpact.

This Dutch system is expected to be amended as a result of the PPWR. We will provide further updates on this in due course.

If you would like to discuss the impact of the PPWR on your business, please contact your regular Forvis Mazars adviser.