PPWR 2026 – what is valid from August 12? Documentation, declaration of conformity, packaging labeling and UC100

From August 12, 2026, the PPWR regulation is applicable in the European Union. For packaging producers and users, this means the beginning of a new phase in packaging design, documentation, traceability and compliance with regulations.

PPWR, or the European Parliament and Council Regulation (EU) 2025/40 on packaging and packaging waste, covers the entire life cycle of packaging – from its design and production to waste management.

However, this does not mean that all PPWR requirements came into force simultaneously on 12 August 2026. The regulation provides for the phased application of specific obligations, and some important changes will be implemented in the following years.

PPWR – key dates

What does PPWR mean for the manufacturer of paper bags and packaging?

It changes the way the manufacturer should analyze product design and document its compliance.

In the case of a paper bag, not only the paper itself may be significant, but also:

• the weight and type of paper,
• the origin and parameters of the material,
• a paper handle, string handle, or one made from another material,
• adhesives,
• printing inks,
• varnishes,
• laminates and coatings,
• bottom and handle reinforcements,
• metal or plastic additional elements,
• packaging purpose.

Therefore, the principle "paper = compliance with PPWR" cannot be automatically adopted. The specific packaging design and requirements applicable to a given product are assessed.

What documents need to be prepared after August 12, 2026?

One of the most important practical changes for packaging manufacturers is the need to organize the conformity assessment system and documentation.

There are two basic documents to distinguish:

1. EU Declaration of Conformity.
2. Packaging technical documentation.

1. EU Declaration of Conformity PPWR

The EU Declaration of Conformity should be drawn up in accordance with the structure provided for in Annex VIII PPWR.

The declaration may include, among other things:

• manufacturer's details,
• identification of the product or product family,
• packaging description,
• product code,
• reference to Regulation (EU) 2025/40,
• manufacturer's declaration of responsibility for compliance,
• the standards or specifications used, if applicable,
• place and date of issue,
• name and function of the authorized person,
• signature.

The declaration should be linked to a specific product or a clearly defined product family.

2. PPWR technical documentation

The technical documentation is much broader than the declaration of conformity itself. Its scope results from Annex VII of the PPWR.

For a paper bag, documentation may include, but is not limited to:

• product name and code,
• description of the use of the packaging,
• bag format,
• drawing, photo or description of the structure,
• paper type and weight,
• handle type,
• handle material,
• glue type,
• type of printing inks,
• varnish, if any,
• laminate or other coating, if any,
• strengthening elements,
• material composition of the packaging,
• material documentation received from suppliers,
• test or analytical results, if required,
• description of how to meet the applicable PPWR requirements,
• product and documentation change history.

3. Documents from raw material suppliers

The packaging manufacturer should collect documents allowing him to properly assess the raw materials and components used.

For paper these may be:

• paper technical data sheet,
• information about grammage,
• information about the material composition,
• manufacturer's or supplier's declarations,
• other information needed for compliance assessment.

For adhesives:

• technical specifications,
• safety data sheet, if issued,
• information on composition or restricted substances, where applicable.

For paints:

• technical data sheet,
• safety data sheet, if applicable,
• manufacturer's information regarding paint application,
• documentation related to chemical requirements.

For laminates, coatings and additional components:

• material type,
• its mass or contribution to the structure,
• technical specifications,
• supplier documents needed to evaluate the product.

Does each bag have to be sent to the lab?

The PPWR should not be interpreted to mean that each batch of standard paper bags must automatically undergo a full set of new laboratory tests.

However, the manufacturer should have sufficient evidence to demonstrate the compliance of the product. These may include relevant documents from suppliers, specifications, calculations, material documentation and, where necessary, test results.

The scope of testing should always be adapted to the type of product, materials used and specific legal requirement.

Does PPWR documentation need to be provided to the client?

It is necessary to distinguish documentation kept by the manufacturer from documents provided to the commercial recipient.

Complete technical documentation is not a document that should automatically be included with every carton or given to every customer.

A standard B2B solution may be providing the customer with:

• EU Declaration of Conformity,
• optionally the product data sheet,
• additional documents, if required for a specific application or agreed upon with the customer.

Complete technical documentation remains with the manufacturer and serves, among other things, to demonstrate compliance to the relevant authorities.

Can the customer demand all the manufacturer's documents?

The customer can request additional information from the manufacturer, especially if they themselves have obligations further down the supply chain.

However, a customer's commercial inquiry should not be confused with a formal request from a competent authority.

The mere fact of purchasing packaging does not automatically mean that the recipient should receive all internal technical documentation of the manufacturer, technological documentation, confidential data of suppliers or information constituting a trade secret.

How long must PPWR records be kept?

The documentation retention period depends on the type of packaging.

For typical disposable packaging, e.g. a regular paper bag, the technical documentation and the EU declaration of conformity should generally be kept for 5 years from the date the packaging was placed on the market.

For reusable packaging, the period is longer.

Therefore, the company should use an archiving system that, after several years, will allow to determine what version of the product and documentation was valid for a specific batch.

Don't overwrite documentation – use versioning

If the design of a product or an important raw material changes, the previous documentation should not simply be deleted.

For example, change:

• paper suppliers,
• paper type,
• glue,
• paints,
• laminate,
• handle material

may require checking whether the change affects compliance assessment.

Therefore, it is worth marking the documentation, e.g.:

Do I need to create new documentation for each customer print?

Not always.

If only the print graphics change, but remain the same:

• bag design,
• paper,
• handles,
• adhesives,
• type and series of paints,
• printing technology,
• other components,

it is possible to use documentation prepared for the appropriate product family.

However, the manufacturer should have a system in place to link a specific order to the appropriate documentation.

Product families instead of thousands of documentation

For a manufacturer with a broad offering, a practical solution may be to create documentation for clearly defined packaging families.

For example:

• paper bags with twisted handle – kraft paper,
• paper bags with twisted handle – white paper,
• bags with flat handle,
• flat bags,
• laminated bags,
• premium bags with string handle.

Individual products may be assigned to an appropriate family if their properties and design allow for a common assessment.

What to put on a carton label after August 12, 2026?

A very important element of PPWR is the traceability of the packaging and the entities responsible for its compliance.

For a master carton with bags, a good solution is to use a label containing, among other things:

• product identification,
• product code,
• lot, serial number or other identifier enabling identification,
• quantity,
• basic product parameters, if they are logistically needed,
• required data of the responsible entity,
• optional QR code linking to relevant information or documents.

There is no need to print the entire declaration of conformity or full technical documentation directly on the carton.

Example of a practical label

Do I need to have a "PPWR certificate"?

Commercial offers of "PPWR certificates" appear on the internet. Such a document should be distinguished from the legally required declaration of conformity.

The fundamental importance lies in correctly conducted conformity assessment, prepared technical documentation, and EU declaration of conformity.

Laboratory tests, audits, or opinions from external units can be part of the documentation and can be very helpful, but they should not automatically be equated with the conformity document required by PPWR.

PFAS – important for food contact packaging

Packaging intended for food contact requires special attention.

PPWR introduces restrictions on PFAS in packaging intended for food contact. Therefore, manufacturers of such packaging should carefully verify, among other things:

• barrier paper,
• greaseproof coatings,
• hydrophobic coatings,
• laminates,
• varnishes,
• other substances used in packaging construction.

Please also remember that the PPWR requirements do not replace other regulations regarding materials and products intended for contact with food.

Is the printing on the paper bag PPWR compliant?

The mere imprint of a logo or graphic does not automatically render the bag incompatible with the PPWR.

However, the following may be important in product evaluation:

• type of paint used,
• varnishes,
• refinements,
• additional coatings,
• their impact on post-use packaging management.

Bags with an individual print remain an important brand advertising medium, but conscious design of the entire packaging structure is becoming more and more important.

Recyclability of packaging – why is it not worth waiting until 2030?

Some of the key requirements for packaging design for recycling will become applicable in the coming years, particularly from 2030.

However, this does not mean that the entrepreneur should wait until the end of 2029.

Structures designed and implemented today may remain on the market for many years. That's why it's worth it today:

• reduce unnecessary materials,
• simplify packaging design,
• analyze recyclability,
• reduce elements that are difficult to separate,
• collect material documentation,
• prepare products for future requirements.

UC100 and the Polish ROP system

Regardless of the directly applicable PPWR, work is underway in Poland on national regulations regarding, among others, the extended producer responsibility system – ROP.

Therefore, it is necessary to separate very clearly:

• obligations arising directly from PPWR,
• solutions included in Polish legislative projects.

Proposed ROP rates, deadlines or mechanisms should not be presented as applicable simply because they are included in the draft bill.

What should a packaging manufacturer do after August 12, 2026?

1. Identify your role in the supply chain.
2. Divide products into logical families.
3. Create a product and batch identification system.
4. Prepare technical documentation.
5. Prepare EU declarations of conformity.
6. Collect documents from suppliers of paper, adhesives, paints and other components.
7. Implement document versioning.
8. Archive documentation for the required period.
9. Verify packaging labeling.
10. Analyze food contact products particularly carefully.
11. Monitor subsequent implementing acts, European Commission guidelines and changes in national regulations.

Frequently asked questions – PPWR 2026

Paper bags and packaging in the new PPWR reality

PPWR does not mean the end of traditional paper packaging. On the contrary, well-designed paper packaging can be an important element of the circular economy.

However, what is of greatest importance is not only the selection of the basic material, but also the design of the entire packaging in a thoughtful and documented way.

This also applies to printed promotional bags. The company ordering the bag can still use it as an effective carrier of its brand, while paying more attention to the design, materials and the possibility of managing the packaging after use.

AWIH – manufacturer of paper bags and printed packaging

AWIH produces and supplies paper bags and packaging for companies. When designing new products, not only the appearance and functionality of the packaging are becoming more and more important, but also its material design, recyclability and technical documentation.

If your company needs paper bags with an individual print, it is worth determining its structure, type of paper, handle and finishing method at the product selection stage.

This article is for information purposes only and does not constitute individual legal advice. The scope of responsibilities should be assessed each time for a specific product, the method of marketing it and the role of the entrepreneur in the supply chain.