EU regulation
Packaging Directive: what remains after PPWR?
Overview
Short answer
Directive 94/62/EC was replaced by the Packaging and Packaging Waste Regulation, PPWR, from 12 August 2026. Certain Directive provisions continue under limited transitions. Existing documents may therefore remain relevant, but the Directive should not be treated as the complete current requirements framework. Articles 70 and 71.
Legal status
Repealed with transitional exceptions
Checked 11 October 2026. PPWR has generally applied since 12 August 2026; Article 70 identifies retained Directive provisions.
Part 1
What the Directive regulated
The Packaging Directive covered packaging and packaging waste regardless of material or sector of use. It combined essential product requirements with Member State responsibilities for waste management and recycling targets. Packaging could therefore be covered even where the product inside it was governed by a completely different regulatory framework. Articles 1–3.
Part 2
The previous foundation for packaging design
Annex II established requirements for composition and suitability for reuse or recovery. Volume and weight were to be limited while maintaining necessary safety, hygiene and acceptance. These earlier provisions help explain existing documentation, but each element now needs to be read alongside the explicit PPWR transition. Article 9 and Annex II.
Part 3
Minimisation continues until the end of 2029
PPWR Article 70 retains Article 9(1) and (2) only in relation to the minimisation requirement in the first indent of Annex II, point 1, until 31 December 2029. This does not preserve the whole Annex unchanged until that date. Check which part of an earlier declaration or assessment is actually being relied on. Article 70(1)(b).
Part 4
Marking follows a different transition
Directive Article 8(2) continues until 30 months after entry into force of the implementing act referred to in PPWR Article 12(6). Decision 97/129/EC is repealed from 12 August 2028. These are separate provisions. Avoid using a single date for every matter involving material identification and packaging marking. Article 70(1)(a) and 70(2).
Part 5
Separate product evidence from waste reporting
Article 70 also retains particular target, calculation and reporting provisions. Some continue until the end of 2028, while transmission of certain statistics to the Commission continues until the end of 2029. This is not a general extension of all earlier packaging obligations for businesses. National producer responsibility questions require separate checking. Article 70(1)(c)–(d).
Part 6
Make existing documentation useful
Recommended practice: list each packaging level, material, weight and supplier document. Mark which provision the document supports and whether it is historical, temporarily retained or replaced. Then compare against PPWR. Preserve the version history so an earlier decision remains understandable without appearing to be the complete current assessment.
Checklist
Key takeaways
- PPWR has been the main framework since 12 August 2026.
- Only expressly identified Directive provisions continue.
- Minimisation, marking and reporting have different transitions.
- Existing evidence must connect to the correct requirement and date.
Questions and answers
Frequently asked questions
Is 94/62/EC still the main framework?
No. It was repealed on 12 August 2026 with specific exceptions in PPWR Article 70.
Does the whole Annex II apply until 2030?
No. The explicit continuation until 31 December 2029 concerns the specified minimisation requirement.
Do all marking provisions end on the same date?
No. Article 70 distinguishes Directive Article 8(2) from Decision 97/129/EC and sets different conditions.
Should earlier supplier declarations be deleted?
No. Retain evidence and history, while assessing whether each document still supports the correct requirement, packaging and version.
Further reading
Official sources
How Verca helps
How Verca can support the process
Verca organises product evidence, documents and version history. The company remains responsible for assessment. Explore the platform.