In short: The EU Packaging and Packaging Waste Regulation (PPWR) applies from 12 August 2026. From that date, a declaration of conformity must be in place for each packaging type, backed by technical documentation; the substance requirements for heavy metals and PFAS apply; and the Danish EPR fees have just been set: approximately DKK 0.27 to 16.94 per kilo, with a 35 percent surcharge for packaging in the red tier. At the same time the de minimis threshold rises from 8 to 10 tonnes, but it does not exempt you from registration. 2026 is about documentation, not redesign.
The rules apply from 12 August, whether or not you are ready
On 12 August 2026, the EU Packaging and Packaging Waste Regulation, PPWR, applies. It is a regulation, not a directive: it applies directly in every EU country. The new Danish packaging order (emballagebekendtgørelse) enters into force the same day.
From day one, three things apply to everyone who places packaged products on the market: a declaration of conformity per packaging type, substance requirements with limits for heavy metals and for PFAS in food-contact packaging, and stricter requirements for the documentation behind environmental claims. The recyclability grades A, B and C, the recycled-content requirements and the empty-space (void) rule, by contrast, belong to the 2030 wave.
That gives an important priority: 2026 is about documentation, not redesign. The convenient answer is to wait and see how the authorities enforce it. It is also the wrong answer, because the documentation requirement applies from day one, and the fees are charged regardless.
The declaration is the visible requirement. The documentation is the real one
The core of PPWR from August is the EU declaration of conformity, commonly called the DoC. It is issued per packaging type, not per SKU, and it confirms that the packaging meets the regulation’s product requirements.
But the declaration is only the tip. Behind it sits a conformity assessment and technical documentation that must be available when the authorities ask for it. A signed declaration with no documentation behind it is an empty signature, and a compliance problem in its own right.
Three things are often underestimated:
- Retention: The declaration and documentation must be kept for 5 years for single-use packaging and 10 years for reusable packaging, counted from the point the packaging was placed on the market.
- Changes: If you change supplier, material or design, the assessment must be renewed. A change of supplier is, in other words, a compliance change, not just a purchasing decision.
- Roles: If you sell under your own brand, or you import, the manufacturer’s responsibility sits with you, not with the supplier.
Your packaging data now determines what you pay
Running in parallel with PPWR is the Danish extended producer responsibility (EPR), and the two share a data foundation. The fees are eco-modulated: red, yellow or green per packaging. From 1 August 2026, VANA’s rates range from approximately DKK 0.27 to 16.94 per kilo depending on material and tier. Packaging in the red tier is additionally charged a surcharge of 35 percent of operational costs. The surcharge is set in the Danish packaging order and applies across the collective schemes.
The calculation belongs with the CFO, not only with the quality department. Purely as an illustration: for a company with 100 tonnes of packaging, the fee ranges from around DKK 27,000 to just under DKK 1.7 million a year depending on material and modulation tier. Poor data can place you in a more expensive tier than you belong in, and good data is therefore a direct line on the bottom line.
And the de minimis threshold exempts less than many think. The threshold rises from 8 to 10 tonnes on 12 August, but registration in the producer register applies regardless of volume. Below the threshold you avoid eco-modulation and can report aggregate volumes. You do not avoid having to register.
What you should do now
- Clarify your role per market. Manufacturer, importer or distributor under PPWR, and producer under EPR. The role determines who must issue the declaration.
- Map your packaging. A catalogue of all packaging types with components, materials and weight. It is the catalogue, not the template, that is the big task.
- Group into families. One declaration can cover variants with the same construction, material and supplier. A well-considered family rule determines whether you maintain 30 declarations or 3,000.
- Demand data from your suppliers. A material declaration per component, a heavy-metal declaration and a PFAS declaration that also covers process additives and barrier treatments. Suppliers are obliged to provide the information, but it does not happen by itself.
- Check your EPR status per country. Registration, reporting and collective scheme in every market you sell in.
- Start measuring towards 2030. Void space, recyclability and recycled content become binding later, but you build the data foundation now.
How Prduct fits in
Prduct is built for exactly the data model PPWR and EPR require: packaging components, composite packaging and sales units, linked to suppliers and sales figures. Today the platform keeps track of 108 EPR schemes across 27 EU markets, collects supplier data via Data Requests without email threads, grades each piece of packaging red, yellow or green with concrete recommendations, and delivers packaging reports and take-back documents in 31 languages, ready for reporting.
We already structure and store the declaration of conformity today, together with the technical evidence behind it. Generating the declaration itself, when you are the responsible producer, we are building as a separate module that is currently in development.
Your auditor or ESG advisor does not become redundant with Prduct — on the contrary. The advisor knows your reporting better than anyone, so we build the automations together with them: method, control and law stay with the advisor; the data foundation and documentation we gather. Today you buy the same knowledge again every year; entered into the platform once, it is reused every time. Same budget, less repetition, more advice for the money.
We mark ourselves what is live and what is on the way. We only promise what the system does. And we do not make the legal assessment for you: Prduct provides the tools to document and prove the compliance work; the responsibility and interpretation stay with you and your advisor.
In most cases the first overview of packaging data is in place within an hour, often in around 30 minutes. The pace depends on where your data sits today. From there you can see where the gaps are, and what they mean for your fees.
Want to see the calculation on your own numbers? Book a demo or see the whole solution at prduct.com.
Frequently asked questions about PPWR
What is the difference between PPWR and EPR?
PPWR is the EU regulation on packaging and packaging waste itself. EPR, extended producer responsibility, is the model that makes companies financially and administratively responsible for the packaging they place on the market in each country. PPWR sets the common EU framework; EPR is the national implementation with registration, reporting and fees through schemes such as VANA and Emballageretur.
Who must issue the declaration of conformity?
The manufacturer, and the declaration is issued on the manufacturer’s responsibility alone. If you sell packaged products under your own brand, or you import them into the EU, you take on the manufacturer’s responsibility for the packaging. It cannot be placed with the supplier.
Are we exempt if we place less than 10 tonnes of packaging on the market?
No. Registration in the producer register applies regardless of volume. Below the de minimis threshold — 8 tonnes today and 10 tonnes from 12 August 2026 — simplified reporting of aggregate volumes applies, and the packaging is not eco-modulated.
Does all packaging need a QR code?
No. There is no general PPWR rule on QR codes for single-use packaging. The digital-labelling requirement applies to reusable packaging from February 2029, and the harmonised material labels arrive from August 2028.
How long must the declaration of conformity be kept?
Five years for single-use packaging and ten years for reusable packaging, counted from the point the packaging was placed on the market. This applies to both the declaration and the technical documentation, and importers must be able to present a copy themselves.
Can you guarantee that we are compliant?
No. No software can, and it is not a legal assessment we make for you. Prduct holds, structures and attests your data, and files your EPR reports, so you have a current, sourced evidence base you can stand on and defend in an inspection.
