Navigating the EU's New Packaging Rules: Understanding PPWR

What Fresh Produce Exporters Need to Know About PPWR — Compliance Deadlines, PFAS Restrictions & Actionable Next Steps

Executive Summary

The EU Packaging and Packaging Waste Regulation (PPWR) is the most significant overhaul of EU packaging legislation in more than 30 years. It applies directly across all 27 EU Member States and affects every organization that places packaging on the EU market — regardless of where that packaging is manufactured.

In this July 15, 2026, IFPA webinar, Jacqueline Mailly of Hogan Lovells Cadwalader International walked attendees through the regulation's scope, compliance timelines, and practical implications for the fresh produce and floral supply chain. Below are the key takeaways and an actionable compliance roadmap.

The bottom line: Don't wait for every implementing act. Begin internal planning, engage suppliers, clarify legal responsibilities, and establish documentation processes well before the August 12, 2026 compliance date.

Key Takeaways From the PPWR Webinar

All packaging types are in scope — primary, grouped, transport, and sales packaging across all materials.
Global exporters are covered. If you ship packaging into the EU, you have compliance obligations — not just EU-based companies.
Compliance is phased through 2040, but the first wave of requirements hits August 12, 2026.
Documentation is non-negotiable. Conformity assessments, Declarations of Conformity (DoC), and supplier certificates must be in place.
PFAS restrictions apply to food-contact packaging starting August 2026 — test early.
Many implementation details are still developing through Commission guidance and implementing acts; plan for flexibility.

PPWR Compliance Roadmap for Fresh Produce & Floral

Date

Requirement

What Changes

What to Do Now

12 Aug 2026

PFAS restrictions,
conformity assessments, DoC,
packaging minimization,
manufacturer ID, EPR

PFAS limits on food-contact packaging;
heavy-metal evidence; conformity
assessment and DoC; minimization rules;
EPR registration; manufacturer
identification and traceability

Complete a packaging audit. Confirm
manufacturer/producer roles. Obtain supplier data
and certificates. Test for PFAS. Prepare Declarations
of Conformity. Verify EPR registration market by
market.

12 Feb 2028

Fruit stickers must be
industrially compostable (EN 13432)

Stickers attached directly to
fruit and vegetables —
substrate, adhesive, and ink —
must meet EN 13432.

Qualify EN 13432-compliant sticker systems. Confirm
performance in packing operations and export
conditions.

12 Aug 2028

Harmonized EU labeling begins

Harmonized EU labels for
packaging materials and
sorting expected

Reserve artwork space. Maintain redesign flexibility.
Do not treat the current JRC proposal as final artwork.

1 Jan 2030

Plastic packaging restrictions
for fresh F&V <1.5 kg;
recyclability grading;
reuse targets

Ban on certain single-use plastic
for unprocessed fresh fruit and
vegetables under 1.5 kg; minimum
recyclability grade; reuse targets;
50% max empty space for grouped,
transport, and e-commerce
packaging

Identify affected SKUs now. Model paper, fibre,
banding, loose-sell alternatives. Document food-
safety needs that may support exemptions.

Who Is Responsible Under PPWR?

PPWR assigns compliance obligations based on economic role — not geography. Understanding which role your organization fills determines your obligations:

Manufacturers: Any entity that designs or produces packaging, or has packaging designed/produced and markets it under their name or trademark. Responsible for conformity assessments, DoC, and technical documentation.
Importers (into the EU): Must verify that the manufacturer has completed the conformity assessment, the DoC exists, and that packaging carries required markings.
Distributors: Must verify markings and documentation are present before making packaging available on the market.
Authorized Representatives: Non-EU manufacturers may appoint an EU-based representative to handle regulatory correspondence.

For unbranded bulk shipments packed outside the EU, there is no one-size-fits-all answer. The exporter and importer must examine who specified each packaging component, who controls design/manufacture, and who first places it on an EU market — then document the agreed allocation before shipment.

Immediate Actions for Your Business

Audit all packaging entering the EU — identify every material, format, and component.
Map your role under PPWR (manufacturer, importer, distributor) for each packaging type.
Engage suppliers now — request PFAS test results, material declarations, and conformity evidence.
Prepare Declarations of Conformity — one per distinct packaging type, supported by technical evidence.
Verify EPR registration in every EU Member State where you place packaging on the market.
Reserve artwork space on packaging for upcoming harmonized labels (expected Aug 2028).
Identify SKUs at risk from the 2030 single-use plastic restriction on fresh F&V under 1.5 kg.
Establish a regulatory monitoring process — many implementing acts and Commission guidance documents are still pending.

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Why This Matters for Fresh Produce & Floral Businesses

PPWR is not a future concern — the first compliance deadline is August 12, 2026. For companies in the fresh produce and floral supply chain, the regulation introduces requirements that touch nearly every part of operations:

Packaging design must meet minimization rules and, by 2030, recyclability grades.
Fruit stickers must be industrially compostable by February 2028.
PFAS (per- and polyfluoroalkyl substances) in food-contact packaging face strict limits starting August 2026.
Extended Producer Responsibility (EPR) obligations require registration in each EU market where packaging is placed.
Labeling will shift to harmonized EU-wide pictograms — final designs are still pending.

Inside the Webinar

Original Air Date: Wednesday, July 15, 2026
Time: 15:00–16:00 CET

In this IFPA webinar, Jacqueline Mailly, Senior EU Regulatory Affairs Advisor with Hogan Lovells Cadwalader International in Brussels, provides an overview of the EU Packaging and Packaging Waste Regulation and explains why it was introduced.

The session covers:

The background behind PPWR and the shortcomings of the previous EU packaging framework
How PPWR aims to reduce packaging waste and improve circularity
The roles and responsibilities of manufacturers, importers, distributors, and other economic operators
Key requirements related to packaging recyclability, restricted substances, recycled content, reuse, refill, and compostability
Packaging minimization rules and their potential impact on packaging design
Key terminology, compliance obligations, and implementation timelines
Practical case studies showing how the regulation may apply in real-world business decisions
Audience questions from the live webinar Q&A

Who Should Watch

This recording is especially relevant for IFPA members involved in:

Exporting fresh produce or floral products to the EU
Packaging design, procurement, or sustainability
Regulatory affairs and compliance
Supply chain, logistics, or distribution
Importing, wholesaling, or retailing in the European market
Supporting growers, shippers, distributors, or suppliers that sell into Europe

If your products, packaging, or supply chain touch the EU market, PPWR may affect your business.

Featured Speaker

Jacqueline Mailly
Senior EU Regulatory Affairs Advisor
Hogan Lovells Cadwalader International, Brussels

Jacqueline provides practical insight into the EU Packaging and Packaging Waste Regulation, including its purpose, scope, implementation timeline, and potential business implications for companies across the packaging value chain.

Frequently Asked Questions About PPWR

Do all labeling requirements begin in August 2026? No. Manufacturer identification and traceability information apply from August 12, 2026. The harmonized material-composition and sorting pictograms are expected from August 2028.

Can companies use the pictograms shown in the webinar now? Not yet. The images came from a 2026 Joint Research Centre (JRC) technical proposal that is not final or legally settled. Companies should plan artwork space but should not present the proposed pictograms as confirmed requirements.

Do compostable-sticker rules apply to box labels? The February 2028 requirement specifically covers sticky labels attached directly to fruit and vegetables — including substrate, adhesive, and ink — not every label placed on a carton.

Does PPWR cover flowers, plants, and non-food products? Yes. PPWR covers packaging generally, not only food packaging. Some provisions are product-specific (e.g., food-contact PFAS limits, the fresh produce plastic-format restriction), but the overall framework also affects floral and other sectors.

Is there a standard Declaration of Conformity template? Annex VIII sets required content, but no official template exists yet. Companies should prepare a declaration for each packaging type, supported by technical evidence; additional guidance may refine the approach.

Can one declaration cover cartons, pallets, dividers, and film? The safest interpretation is to assess by packaging type. A broader dossier may contain multiple components, but each distinct packaging type must be traceable to applicable evidence and its own declaration.

Who is responsible for unbranded bulk shipments packed outside the EU? There is no universal answer. The parties must examine who specified or branded each packaging component, who controls design/manufacture, and who first places it on an EU Member State market. Document the agreed allocation before shipment.