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Overview

On 12 August 2026 the PPWR becomes generally applicable. The most common worry: does packaging that is already produced, or already on the shelf, have to be destroyed, repacked, or relabelled? The European Commission’s answer is reassuring on every material point — this page summarises what applies to stock, to missing supplier data, and to market surveillance.
This page is based on Regulation (EU) 2025/40 and the European Commission’s PPWR FAQ (2nd edition, August 2026). Each section names the relevant FAQ reference so you can evidence it to authorities and auditors.

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Stock produced before 12 Aug 2026

Nothing has to be destroyed, remanufactured, or relabelled. (FAQ X.5)
Packaging that was already produced before 12 August 2026 and sits in stock, but has not been placed on the market by that date, does not have to be destroyed, remanufactured, or relabelled. The information required under Art. 15(5) and (6) — unique identification plus the manufacturer’s name and address — may be provided for that stock by means of an accompanying document. The same applies to reusable packaging already placed on the market. Packaging that was placed on the market before 12 August 2026 may remain on the market, even if it does not comply with the PPWR. No withdrawal is foreseen merely because of the cut-off date.
For packaging manufactured after 12 August 2026 the relief no longer applies: from then on an accompanying document may only be used where it is not possible to affix the unique identification and the name and address directly on the packaging (FAQ X.5, X.7).

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When the supplier no longer exists or will not respond

For packaging manufactured before 12 August 2026, the necessary information is sometimes missing or insufficient — the supplier no longer exists, or refuses. In that case the Commission expects the manufacturer to make best efforts (FAQ X.6), for example:
  • requesting the information from the former supplier,
  • in the case of a business takeover, merger, or acquisition: requesting it from the resulting company,
  • making its own assessments.
Document those efforts. In Polygon One you attach the correspondence and your own test reports as evidence documents on the component or unit — that puts the attempt on record, even where the data point itself stays incomplete.
This “best efforts” rule is expressly about packaging manufactured before 12 August 2026. For ongoing sourcing, Art. 16 applies: suppliers must provide the manufacturer with all information and documentation needed to demonstrate conformity, including all the relevant technical documentation. They cannot refuse to hand it over (FAQ X.4).

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How authorities will act from 12 Aug 2026

No immediate market ban. Warning first, then correction. (FAQ XVI.1, Art. 62)
Enforcement of the obligations applicable from 12 August 2026 is expressly not meant to disrupt trade flows, supply chains, or consumer access to goods. Under Art. 62, a Member State that becomes aware of non-compliance must first require the economic operator concerned to put an end to it — so the operator first receives a warning and an opportunity to take corrective action, before any further step is taken. Only where the non-compliance is not rectified but persists may Member States go further: prohibiting, recalling, or withdrawing the packaging. Market surveillance authorities are to support economic operators in complying with the new rules rather than follow a sanction-oriented approach — for instance through awareness-raising, requests for information, or requests for corrective action with a reasonable timeline for adaptation.

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No proactive notification duty

You do not have to notify the competent authorities proactively that you place packaging on their territory — not even in every Member State your packaging might end up in. The authorities will contact you in the event of a check (FAQ XV.8). A notification duty only arises where a manufacturer or distributor becomes aware that packaging it has placed on the market is non-compliant (Art. 15(8), Art. 19(5)). Where a manufacturer delivers to a distributor’s warehouse in another Member State and that warehouse serves several national markets, it is the distributor’s obligation to inform the competent authority in each of those Member States about the suspicion.
EPR registration is unaffected: it is mandatory per Member State in which you make packaging available for the first time (Art. 44) — see EPR registration. “No notification duty” concerns market surveillance only, not the producer register.

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Transit through the EU

Packaging or packaged products that are not declared for release for free circulation but remain in transit through the EU on the way to a non-EU destination are not considered placed on the market — the PPWR requirements do not apply to them (FAQ X.12). For imports, placing on the market is generally considered to occur when the goods are declared for release for free circulation. If a company imports packaged products into the EU and subsequently exports them to a third country, they only have to comply with the PPWR if they were placed on the EU market.
The two do not always coincide: in distance selling, placing on the market can occur before release for free circulation. So treat transit exemptions case by case and document the customs treatment.

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What this means for your work in Polygon One

  • Existing stock is not a blocker. Set up roles and master data properly anyway — the checklist then shows you, per unit, what is genuinely open as of 12 August 2026.
  • An outstanding duty is not grounds for a ban. The Action needed status in the obligation checklist means data is missing. It does not mean your goods have to leave the market.
  • Evidence your gaps. Where supplier data for legacy stock is missing, upload your efforts as evidence — that is exactly what the Commission describes as “best efforts”.

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Next steps

Obligation checklist

Which duties apply per unit and when they take effect.

Data collection

Request missing data and evidence from suppliers.