For years, corporate sustainability pledges have been heavy on talk but short on concerted action or real evidence. The EU's PPWR is about to change all that, with very costly consequences for companies whose fine-sounding commitments lack solid foundations...Corporate sustainability strategies are facing a reckoning. Many of the bold packaging commitments made three and four years ago have already been quietly revised, extended or abandoned. The gap between what consumer goods companies have promised and what they have delivered on packaging is becoming increasingly visible to the retailers, investors and regulators scrutinising those promises.
The EU’s Packaging and Packaging Waste Regulation (PPWR) is about to make that gap impossible to hide.
PPWR (Regulation EU 2025/40) came into force as of February 2025. As of August 12, 2026, it becomes directly enforceable across all 27 member states at once. It requires every company placing packaging on the EU market to produce an EU Declaration of Conformity (DoC) for every packaging type, backed by complete, auditable technical documentation, covering material composition, recyclability evidence, recycled content, hazardous substance concentrations and labelling compliance.
DoC documentation must be available to market surveillance authorities at any time.
This is not a reporting exercise. It is legal proof that your packaging meets defined sustainability standards. If you cannot produce DoC evidence for the packaging your products cannot legally be placed on the EU market. Anywhere.
High stakes
For consumer goods businesses, the implications go beyond compliance. PPWR operationalises, at a regulatory level, exactly what corporate sustainability strategies have been promising for years: that packaging is recyclable, recycled content targets are being met, hazardous substances are being eliminated.
The difference is that PPWR requires documented, SKU-level evidence – not well-meaning statements, targets or progress reports.
The companies whose sustainability programmes are genuinely embedded in their packaging operations will find PPWR strengthens what they are already doing.
Those whose sustainability commitments have outrun their data and processes will find PPWR mercilessly exposes the gap. This is a crisis in the making that’s commercial as much as legal and reputational: failure to comply will lead to heavy fines and exclusion from all EU markets.
The compliance spiral
August 2026 is only the beginning.
What follows is a decade of tightening obligations: harmonised labelling requirements from 2028, recyclability grade thresholds and single-use bans from 2030, recycled-at-scale requirements from 2035. Extended Producer Responsibility fees across EU member states will be ecologically modulated, meaning companies with less recyclable packaging will pay more. The data and documentation needed for August 2026 is the same foundation that determines cost exposure at every milestone that follows.
Where to start
The first step is an honest audit. Can your organisation produce a complete technical file for a specific packaging type, on request, at any time? For most, the answer will reveal work to do.
The compliance gap for most organisations is fundamentally a data gap. The DoC requires precise, auditable, SKU-level packaging data: exact material composition including heavy metal concentrations and PFAS content for food-contact packaging, recyclability grades, recycled content percentages. For many businesses, that data is scattered across supplier emails, embedded in PDFs and living in people's heads rather than in governed systems.
The six immediate priorities are:
• establish your role(s) under PPWR: there are different obligations for manufacturers/importers/distributors
• map your full packaging portfolio across all EU markets
• audit the state of your packaging data against DoC requirements
• initiate supplier conversations now – many suppliers are not yet ready and finding alternatives will take time
• review labelling compliance across all markets
• start EPR registrations in markets with producer registers already in place.
It’s not too late
Compliance projects of this kind take up to two years, and the window is narrowing. But though it’s late to start, it is not too late. True, companies beginning now with partial, scattered data will face urgent compliance and data remediation challenges running concurrently. But they will at least be building foundations that simplify everything that follows over a decade of spiralling obligations. The ones who continue to delay will face something far worse. As markets start to exclude non-compliant packaging and buyers turn elsewhere, the consequences could even be existential.