PPWR: New packaging requirements and producer responsibility under the Packaging and Packaging Waste Regulation
This article is based on information from the Danish Environmental Protection Agency and has been editorially adapted by Emballageretur.
On August 12th 2026, the first key provisions of the EU Packaging and Packaging Waste Regulation will enter into force. For many companies, this means new requirements for packaging content and documentation, as well as changes to producer responsibility rules.
The Packaging and Packaging Waste Regulation will be phased in towards 2030 and includes requirements concerning, among other things, substances of concern in packaging, documentation, design for recycling and increased use of reusable packaging.
The first requirements will apply from August 12th 2026.
Below, we review the most important changes and their significance for companies that produce, import or market packaging and packaged products.
From August 12th 2026, all packaging must comply with common EU limits for specific heavy metals.
For packaging intended for food contact, limits for PFAS will also apply.
Denmark already has a national ban on PFAS in paper and cardboard packaging intended for food contact, but in the future the requirements will also apply to food packaging made from other materials. The PFAS limits apply to the entire packaging and not only the layer that is in direct contact with the food.
Companies that market packaging or packaged products should therefore ensure that their packaging complies with the new requirements and that the necessary documentation is available.
From August 12th 2026, all packaging must be covered by a declaration of conformity.
The declaration must document that the packaging complies with the relevant requirements of the Packaging and Packaging Waste Regulation, including for example PFAS limits.
The declaration must clearly identify the packaging it applies to, for example through a series number, type number or batch number. It must also refer to the standards or technical specifications forming the basis for the assessment.
Annex 8 of the Packaging and Packaging Waste Regulation contains a template for the declaration, while the procedure for conformity assessment is described in Annex 7.
All packaging must be traceable to the corresponding declaration of conformity. Therefore, packaging must be provided with an identification number, such as a series number, type number or batch number.
If a packaged product consists of several packaging components with separate declarations of conformity - for example a toothpaste tube and a cardboard box - both packaging components must have an identification number. If one combined declaration of conformity is prepared for both packaging components, it is sufficient that the identification number appears on only one of them.
All companies in the packaging value chain are responsible for only placing packaging on the market that complies with the requirements of the Packaging and Packaging Waste Regulation.
The responsibility depends on the company's role:
It is important to note that responsibility under the Packaging and Packaging Waste Regulation is not necessarily identical to responsibility under producer responsibility rules.
The Danish Packaging Executive Order currently regulates which companies have producer responsibility. The Packaging and Packaging Waste Regulation harmonises definitions across the EU.
The main changes concern:
The changes will affect the packaging quantities to be reported for 2026 in the DPA producer responsibility register between January 1st and May 31st 2027. For most companies, reporting will continue to be handled by their producer responsibility organisation.
The biggest change is the so-called unpacker rule.
From August 12th 2026, Danish companies will become responsible for imported packaging that is unpacked before the products reach the end user.
This means that companies importing goods and unpacking transport packaging or other packaging at their own premises will become responsible for that packaging under producer responsibility rules.
Under the current Danish rules, responsibility in many cases lies with the foreign supplier. This change is because the Packaging and Packaging Waste Regulation expands the producer definition to include the company unpacking the packaging.
The rules do not change in this situation.
If a Danish company imports products for its own use and is itself the end user of the product, producer responsibility will continue to remain with the foreign company that supplies the product directly to the end user.
A Danish retail store imports 2-litre containers of olive oil from a Greek supplier.
The containers are delivered in cardboard boxes on a single-use pallet. The store unpacks the goods and places the containers on the shelf, while the cardboard boxes and pallets become waste.
Until August 11th 2026:
From August 12th 2026:
The company will therefore become responsible for a larger quantity of packaging than previously.
Because the rules change during the calendar year, companies affected by the unpacker rule must calculate their packaging quantities according to two different sets of rules.
January 1st - August 11th 2026
Quantities must be calculated according to the producer definition in the Danish Packaging Executive Order.
August 12th - December 31st 2026
Quantities must be calculated according to the producer definition in the Packaging and Packaging Waste Regulation.
The reporting process itself does not change. Companies must simply ensure that they report the correct packaging quantities according to the rules applying in the two periods.
The Packaging and Packaging Waste Regulation also changes the definition of end user.
Where the Danish rules currently focus on the final recipient of the packaging, the Packaging and Packaging Waste Regulation defines the end user as the final recipient of the product inside the packaging.
An end user can be both a private individual and a company. For example, a consumer purchasing a pair of shoes is the end user of the shoes, while a pizza manufacturer can be the end user of a bag of spices used in the production of frozen pizzas.
The new definition is an important part of the background for the unpacker rule.
The EU guidance clarifies that producer responsibility for sales and multipack packaging lies with the company that fills or has the empty packaging filled.
The allocation of responsibility does not depend on which name or trademark appears on the packaging.
The clarification does not change current Danish practice but will lead to an update of the Danish Environmental Protection Agency’s guidance.
The Packaging and Packaging Waste Regulation contains several additional requirements that will be phased in towards 2030.
These include:
The Danish Environmental Protection Agency will continue to inform companies about upcoming requirements through newsletters and its dedicated packaging regulation information pages (in Danish). The EU has also published a guide and FAQ, and further guidance is expected later in 2026.
Emballageretur will also ensure that you stay up to date through webinars, guidance materials and practical resources. Keep an eye on our PPWR information page, use our guidance materials and resources on MitRetur, subscribe to our newsletter and look out for member updates when they arrive in your inbox.
In 2026, companies were required for the first time to report information on reusable packaging.
By June 1st 2026, companies with producer responsibility were required to report:
Producer responsibility generally applies to companies that:
Companies generally do not have producer responsibility if they receive reusable packaging from Danish suppliers or import reusable packaging that is only made available outside Denmark.
Companies with producer responsibility for reusable packaging are also required to organise the take-back and waste management of end-of-life reusable packaging.
The Danish Environmental Protection Agency has initiated work on a new analysis of the public costs associated with the clean-up of single-use plastic products.
The analysis follows from the EU Single-Use Plastics Directive and will map both the amount of littered products and the costs incurred by municipalities and the state for collection and clean-up.
The results are expected to be published in the first quarter of 2027 and will form the basis for the fees that companies with producer responsibility for single-use plastics must pay during the period 2028-2030.
The scheme covers eight product groups: food containers, wrappers and packaging films, beverage containers, drinking cups, lightweight plastic carrier bags, wet wipes, balloons and tobacco product filters.