New European Union rules governing packaging and packaging waste came into effect on 12 August 2026, introducing important requirements for businesses placing packaged products on the EU market.
Following guidance shared by the British Safety Industry Federation (BSIF), PPE manufacturers and importers acting as manufacturers are being encouraged to review their responsibilities under Regulation (EU) 2025/40 on Packaging and Packaging Waste, known as the PPWR.
Who does the regulation affect?
The PPWR applies to packaging placed on the EU market, regardless of the type of packaging or material used. For most aspects, this also includes products placed on the market in Northern Ireland under the Windsor Framework.
The regulation introduces requirements covering the manufacture, composition and management of packaging throughout its lifecycle.
What are the immediate considerations?
Under Article 5 of the regulation, packaging must comply with restrictions concerning substances of concern, including:
- Lead
- Cadmium
- Mercury
- Hexavalent chromium
Manufacturers are also required to minimise the presence and concentration of substances of concern in packaging materials wherever possible.
The distinction between the packaging and the product contained within it must remain clear, as the packaging itself has separate compliance and documentation requirements.
Conformity and technical documentation
Manufacturers must complete the appropriate conformity assessment and prepare technical documentation and a Declaration of Conformity for the packaging.
The Declaration of Conformity must be available electronically, with a paper copy supplied if requested. Relevant documentation must be made available to the appropriate authorities within 10 days of a request.
Technical documentation should be retained for:
- At least five years for standard packaging
- At least ten years for reusable packaging
What should businesses do now?
PPE manufacturers and importers should speak with their packaging suppliers to establish whether the packaging they use complies with the PPWR and whether the necessary technical documentation is available.
The requirements placed on manufacturers will continue to develop over the next five years, making it important for businesses to understand their responsibilities and begin preparing early.
Further guidance
Further information is available through the following resources:
- European Commission: Packaging waste
- EUR-Lex: Summary of the Packaging and Packaging Waste Regulation
- European Safety Federation: Information on Declaration of Conformity requirements for packaging
Eurosafe would like to thank the British Safety Industry Federation for sharing this important industry guidance.
This article provides a general overview of the regulation and does not constitute legal or regulatory advice. Businesses should consult the official guidance and seek professional advice where necessary.
