Yes, in principle. The regulation applies to packaging placed on the market from 12 August 2026, and the documentary obligations fall on the party placing it there from that date. Existing stock is normally used up, and throwing away new packaging to comply would contradict the text's objective. The useful action comes when restocking: switching to a supplier established in France or the Union transfers packaging conformity to it under Articles 3 and 15(12). There is a qualification if your stock comes directly from a country outside the Union: the purchase made you the importer at the time, and this remains true for that stock. Restocking within the Union resolves the issue for the future.
Read the source article: PPWR small business obligations: the micro-enterprise rule