The EU Packaging and Packaging Waste Regulation, PPWR (Regulation (EU) 2025/40), entered into force in February 2025 and has applied since August 12, 2026. Since that date, a manufacturer must carry out the conformity assessment and draw up the technical documentation set out in Annex VII before placing packaging on the EU market, then draw up a signed EU declaration of conformity once compliance is demonstrated. Both must be kept for 5 years for single-use packaging and 10 years for reusable packaging.
What changed on August 12, 2026
- Technical documentation and an EU declaration of conformity are now required before packaging is placed on the EU market (Articles 15 and 39).
- The declaration states that the requirements of Articles 5 to 12 have been demonstrated, and by drawing it up the manufacturer takes responsibility for compliance.
- The manufacturer is generally the company that has the packaging or packaged product made under its own name or trademark, which is why brand owners ask their printers and converters for the data behind the file.
- Substance rules apply now: the sum of lead, cadmium, mercury and hexavalent chromium in packaging or packaging components must not exceed 100 mg/kg, and PFAS limits apply to food-contact packaging (Article 5).
- Obligations follow the packaging, not the printer: importers and distributors carry their own duties (Articles 18 and 19).
Other obligations arrive later, each with its own date. A harmonized label on material composition applies from August 12, 2028, or 24 months after the implementing acts, whichever is later (Article 12). Packaging must be recyclable within grades A, B or C from January 1, 2030, or 24 months after the Article 6 delegated acts, whichever is later, and within grades A or B from January 1, 2038 (Article 6). Minimum recycled content targets for plastic parts of packaging apply from January 1, 2030, or 3 years after the implementing act, whichever is later (Article 7). The PPWR does not create a separate packaging Digital Product Passport, but where the packaged product needs one under the Ecodesign Regulation, the PPWR expects that passport to carry the packaging information too.
A worldwide rule, not a European one
The PPWR applies to packaging placed on the EU market, wherever it was printed. A folding carton printed in Ohio, a label printed in Izmir or a flexible film printed in Guangzhou all fall under the same requirements the moment the packaged product is placed on the EU market. This is why brand owners ask their converters worldwide for structured production data, and why pressrooms on every continent are standardizing. Rutherford supports that shift with closed loop color deployed on more than 1,000 systems in over 30 countries, from North American plants to European packaging groups.
Where color data fits in the compliance file
Compliance is a documentation exercise, and documentation is only as good as the data behind it. A pressroom running closed loop color already produces, job after job: the agreed color targets, the measured values, DeltaE against the reference, the substrate used, and a time-stamped record of the run. That is exactly the kind of evidence brand owner audits and technical files feed on. The Offset360 workflow captures it at the press, and platforms like PPWR Connect consolidate production data into audit-ready reports per run.
Does the PPWR apply to printers outside the EU?
Yes, indirectly but firmly. The obligations attach to packaging placed on the EU market, so any printer or converter exporting packaging, or printing for a brand that sells in the EU, can expect to be asked for conformity data. Non-EU printers who can hand over clean, structured production records will keep those contracts; those who cannot create risk for their customers.
What should a printer have in place now that the PPWR applies?
Three things. First, know which of your jobs end up on the EU market. Second, be able to document materials and production per job: substrates, inks, measured color, run records. Third, agree with each brand owner which company acts as manufacturer and draws up the EU declaration of conformity, and what data they need from you. If those conversations did not happen before August 12, they are now overdue. Our PPWR and DPP printer checklist walks through the full list.
Does closed loop color make me PPWR compliant?
No single tool does. Compliance covers materials, design and documentation. What closed loop color control does is remove the weakest link: it standardizes color to the reference, measures every sheet, and logs the evidence automatically. If your press qualifies, the free Rutherford Check takes two minutes, and the ROI calculator shows what the same discipline saves in makeready waste.
The pragmatic path: fix the data at the press first
August 12, 2026 has passed, and the 2028 and 2030 milestones are next. Printers who treat this as a data problem, not a paperwork problem, move faster: standardize color, measure every run, keep the records. The compliance file then writes itself from data you already trust.