The European Union’s Packaging and Packaging Waste Regulation applies from today, and with it comes the piece of paperwork that will define packaging compliance for the next decade: the EU Declaration of Conformity. From 12 August 2026, every distinct packaging type placed on the EU market, every format, material and construction variant, must be backed by a signed declaration and a technical file proving it complies. For an industry that ships thousands of SKUs, that is not a legal problem. It is a data problem, and it lands squarely in RFID territory.
What changes today
The PPWR, formally Regulation (EU) 2025/40, entered into force in February 2025 and becomes applicable today. It replaces the 1994 Packaging Directive, and because it is a regulation rather than a directive, it applies identically in every member state with no national transposition to soften it.
From today, whoever places packaging on the EU market under their own name, which the regulation calls the producer and is usually the brand owner rather than the factory, must do four things for each packaging type:
- Assess conformity against the regulation’s design and safety requirements, using internal production control (known as Module A, with no external certification body required in standard cases).
- Compile technical documentation covering the packaging’s description, design drawings at component level, the material composition of every layer, test reports for restricted substances and the assessments behind every claim.
- Draw up and sign an EU Declaration of Conformity with a unique identification number, referencing the regulation and its Articles 5 to 12.
- Keep it all for five years for single-use packaging, and ten years for reusable packaging, ready to hand to a market surveillance authority within ten days of being asked.
Importers must verify the producer has done this before the goods cross the border, and distributors must check compliance markings before putting packaging on shelves. A blanket statement covering “all our packaging” is explicitly not acceptable: each variant needs its own file.
The substance limits with immediate effect
The declaration is not an empty formality, because the substance restrictions it certifies against apply from today too. The combined limit of 100 mg/kg for lead, cadmium, mercury and hexavalent chromium carries over from the old directive, but the PPWR adds the first EU-wide PFAS restrictions for food-contact packaging: 25 parts per billion for any individual measured PFAS, 250 ppb for the sum of targeted substances, and 50 parts per million for total PFAS including polymeric forms. Test reports proving those numbers belong in the technical file.
Not everything bites at once. Recyclability performance grades arrive in 2030, minimum recycled content follows, the harmonised consumer sorting labels become mandatory from August 2028, and the 50 per cent empty-space limit for e-commerce packaging waits until 2030. But the documentation spine those future requirements will hang from must exist from this morning.
Why this is an RFID story
Nothing in the PPWR mandates RFID. The regulation is deliberately technology-neutral, and where it mentions a data carrier the everyday example given is a QR code. But look at what the regulation asks companies to know, and to keep knowing for up to a decade, and the fit becomes obvious.
Identification is now a legal requirement. The regulation requires packaging to be identifiable by type and batch, with the producer’s details carried on the packaging itself or in a data carrier. Any organisation already running item-level or batch-level UHF RFID in its supply chain holds exactly the provenance data the technical file demands: which components, from which supplier, in which batch, on which date, with a read history to prove it. Companies still reconciling spreadsheets against purchase orders will be assembling that evidence by hand.
Reusable packaging must count its own trips. This is the sharpest fit of all. The PPWR’s reuse provisions require reusable packaging to be part of a functioning reuse system, and its labelling rules, arriving from 2028, require reusable packaging to carry a data carrier that facilitates, in the regulation’s own words, tracking of the packaging and the calculation of trips and rotations. Counting rotations of crates, pallets, kegs and roll cages through washing and refill loops is something passive UHF RFID has done commercially for years: it is the founding use case of the returnable transit packaging pools run across European grocery and logistics. A printed QR can identify a crate, but it cannot be read three hundred at a time through a dock door, and it stops working the day the print scuffs off. Expect RFID to do the operational tracking while the QR serves the consumer-facing layer.
Impinj, whose reader chips and tag silicon sit beneath much of the world’s RAIN RFID infrastructure, sees the regulation the same way. The company gave RFID News this comment:
“As regulations like PPWR accelerate the shift toward a more circular economy, businesses will need greater visibility into packaging and materials throughout their full lifecycle. Impinj’s Physical Intelligence platform utilises RAIN RFID to make physical items and packaging visible to businesses, from manufacturing through recycling, and every step in between. With RAIN RFID, organisations can automatically identify and track reusable packaging, improve sorting and recovery, and gain the data needed to keep materials in circulation longer and reduce waste.”
Megan Brewster, VP of Advanced Technology, Impinj
Ten-year record keeping favours automation. Reusable packaging documentation must survive for ten years from the last unit placed on the market. Rotation logs generated automatically by readers at depot doors are audit evidence that writes itself.
NFC gives the label a second job. The harmonised labels coming in 2028 put sorting information in front of consumers. Brands that want more than the minimum are already pairing that with NFC: one tap on a tagged pack can present reuse instructions, deposit-return locations or recycling guidance alongside the marketing content that justifies the tag’s cost. Compliance rides along for free.
And one warning for our own industry. From 2030, packaging will be graded on recyclability, and a tag or inlay is part of the pack it sits on. Inlay makers have seen this coming, which is why paper-faced and aluminium-reduced constructions have moved from trade-show novelty to volume products. Tags that help packaging comply with the PPWR’s data demands must not drag down the recyclability grade of the very pack they sit on.
What to do this week
For packaging producers and brand owners, the immediate work is unglamorous: inventory every packaging variant you place on the EU market, confirm substance test reports exist for each, and get declarations drafted and signed, because the obligation started this morning, not at the end of a grace period. For RFID suppliers and integrators, the opportunity is to frame what your systems already capture, identity, batch, movement and rotation counts, as the compliance evidence the regulation now demands. The companies selling tracking as an efficiency play last year are selling it as a regulatory necessity this morning.
The PPWR will reshape European packaging for the rest of the decade, with recyclability grades, recycled content minima, reuse targets and deposit-return schemes all still to land between now and 2030. Today’s declaration requirement is the foundation all of it stands on, and the message under the legal language is simple: if you cannot identify it, you cannot comply with it. Identification is our industry’s home ground.
Photo credit: Jas Min
