PPWR and EPR:
where to start
- 12/08/2026 PPWR applicable
- 31/12/2026 Joining professional packaging EPR
- 01/01/2030 6 formats banned
PPWR applicable since 12 August 2026, professional packaging EPR from 1 January 2027: the 6 questions to address, in order, with dates and a budget.
A real projectBacardi-Martini: Bilan Carbone® and the impact of 2 references, including packagingSpirits, production site with 120 employeesRead about the project
Special caseAre you a microbusiness?If your packaging supplier is established in the EU, it is responsible for your packaging's PPWR compliance. You still need to join a producer responsibility organisation, at around €100 to €150 excl. VAT per year.The microbusiness case ↗
Special caseDo you sell from abroad, or in other EU countries?You need an authorised representative and registration in every country where you sell without being established there. In France, this has been mandatory since 10 July 2026.Check in 3 questions ↗They have commissioned Celsius
To address, in order.
Does this apply to me, even if I do not manufacture my packaging?
Yes. If the product is sold under your brand, including a private label, you sign the declaration of conformity, even for packaging bought ready-made. For standard unbranded cardboard boxes and films, the declaration is the manufacturer's responsibility.
Divide your packaging into 2 groups: what you sign for and what your supplier signs for.
What must I be able to provide today?
An EU declaration of conformity for each packaging type, supported by technical documentation. Nothing needs to be filed: you retain it for 5 years and supply it within 10 days if the authority requests it.
Ask your suppliers for the data for each reference (materials, substances, tests). They cannot refuse to provide it.
My packaging comes into contact with food: what should I check for PFAS?
Since 12 August 2026, food packaging exceeding the PFAS thresholds can no longer be placed on the market, including existing stock. On 10 October 2026, the PFHxA restriction in paper and cardboard also takes effect.
Require a total fluorine analysis report for each reference from every supplier, starting with greaseproof papers and moulded fibre.
EPR: what changes on 1 January 2027?
Your household packaging continues to be declared to Citeo, Adelphe or Léko. Professional packaging (pallets, films, cardboard boxes used between businesses) enters a separate scheme, announced for 1 January 2027.
Join Citeo Pro, Léko Pro or Twiice before 31 December 2026, with your 2026 tonnages by material.
What takes effect in 2030?
On 1 January 2030, 6 single-use formats leave the market and the first reuse quotas apply. Recyclability, recycled plastic and the empty-space ratio follow at the earliest on the same date.
Identify the affected references now: qualifying a recycled material supplier takes 6 to 12 months.
Where should I start?
With an inventory of your packaging, reference by reference: material, weight, supplier, food contact, countries of sale. It serves the declaration, EPR and the identification of references affected in 2030.
Allow a few weeks of internal work for a short catalogue, around 3 months for several hundred references.
The dates to remember.
- 202610/07EPR authorised representative mandatory in France for sellers established elsewhereIn force
- 202612/08PPWR applies: declaration of conformity, PFAS thresholdsIn force
- 2026 · in 2 days10/10PFHxA restriction in food-contact paper and cardboardNext deadline
- 202631/12Joining the professional packaging EPR scheme
- 203001/016 formats banned, first reuse quotas
What it costs.
Indicative costs for an SME or mid-sized company. Bpifrance's Diag Éco-conception can fund part of the cost.
- A supported inventory of your packagingDuration: around 3 months€15,000 to €30,000 excl. VAT
- Compare alternatives through LCA, for 3 to 5 referencesDuration: around 4 months€20,000 to €50,000 excl. VAT
- A redesign with supplier qualificationDuration: 6 to 12 months€30,000 to €100,000 excl. VAT
Bacardi-Martini:
Bilan Carbone® and the impact of 2 references, including packaging.
Spirits, production site with 120 employees
At this spirits production site, we carried out the Bilan Carbone® covering all 3 scopes and analysed the impact of 2 flagship references, including packaging. Glass emerged as the leading emissions category: the action plan prioritises progressively reducing bottle weight and increasing the share of recycled glass, taking account of the brand's premium positioning.
- 41%for glass, the leading emissions category
- 2flagship references analysed, including packaging
- 6 monthsproject, with 2 consultants
An initial assessment
of your packaging.
We start with an assessment of your packaging families: applicable requirements, missing documents, priorities. You can stop there or ask us to handle the next stages.
