12 August has passed, and PPWR is officially part of doing business. For fashion brands, that means getting serious about packaging data, documentation and who is actually responsible for what. Here is what you need to know now, and what is still coming.
You probably know EPR: register in each country you sell in, pay a fee. That stays. But the new PPWR (Packaging and Packaging Waste Regulation), live from 12 August 2026, adds a second job.
The part most brands already know: pay your dues, register and pay fees where your packaging ends up. Proving your packaging follows the rules is the new part. The law now sets rules on the packaging itself (what it's made of, how little material it uses, how recyclable it is, what's printed on it), and you have to show you follow them if asked.
"Packaging" means all of it, polybags, tissue paper and boxes, whether you make it in Europe or import it. And it's not just inspectors: the big marketplaces like Zalando and Amazon are already checking that sellers are registered.
Relief up front: anything you shipped before 12 August 2026 is fine, no recalls, no restickering of polybags. This is about what you send out from that date on.
Think of it as a stack: proof at the bottom, a signed slip in the middle, a label on top.
A signed slip (the Declaration of Conformity). This is a short document where you sign to say "this packaging follows the rules." The important word is type. You need one slip per type of packaging, not one per style or individual piece of packaging. So if forty different styles all go in the same polybag, that's one document, not forty. Though five different box sizes? That's five DoC's.
The proof behind it (the technical file). You can't sign that slip out of thin air. Behind it you keep a file that shows why the packaging is OK: what it's made of, every material and component, and any test results. You hold onto this file for 5 years (10 for reusable packaging).
A label to trace it back. A number plus your name and contact details, on the packaging or in a QR code. Good news: the item number you already use is fine. You don't need a unique code on every single box; the same number can cover a whole run. A sorting symbol (which bin it goes in) joins later - see the roadmap.
You design clothes; someone else packages your dress in a polybag and boxes your shoes. So the supplier's responsible, right?
Well, it depends entirely on whether your branding is on it:
Your name and logo is on it or it is custom designed → You are legally treated as the manufacturer, even if another factory physically produced it. Note that there are exceptions for micro-enterprises.
But what if it's completely plain? If you buy completely generic, unbranded boxes, mailers, or stretch wrap straight off a supplier's catalog without any custom changes, the supplier is legally the manufacturer and must handle the compliance paperwork.
So if you brand them, your polybags, hangtags and shoe boxes all need those three things, with you legally responsible. But don't panic, just know it's on you, not your packaging factories. The only calm way through is knowing what's in each type of packaging and which supplier can prove it. Know your supplier, and keep what they tell you as usable data.
August 2026 is the start, not the finish, but it all builds on the same data.
2026: DoCs, strict heavy metal limits, and initial EPR registrations go live.
2028: Material sorting labels become mandatory on packaging across Europe. (If you use reusable packaging, mandatory QR codes for tracking trips and rotations join the party in early 2029).
2028-29: Sister laws for garments start to kick in. Textile EPR schemes (paying recycling fees on the clothes themselves) and the first Digital Product Passport (DPP) rules are expected, pulling heavily from your existing supplier data.
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2030: The administrative headache eases as registration and reporting formats are completely harmonised across all 27 national registers (with the first harmonised annual reporting due by 1 June 2030).
Also in 2030: Every piece of packaging must hit a recyclability Grade A, B, or C (Grade D is restricted and banned from the market). Plus, e-commerce shipping boxes are hit with a strict 50% maximum limit on empty space
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Different laws, different years, but they are all asking for the exact same thing: solid, supplier-backed data on what your products and packaging are made of. Get it right once, and it’s one compliance job, not four. That’s why brands treat their PLM software as their single source of truth, rather than relying on a pile of disconnected spreadsheets.
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