Legal Background
Overview
Legal Background is the first page of the PPWR module and your orientation point for the regulation itself. It shows where PPWR stands today, what applies when, and which thresholds and pitfalls matter, and it ends with the setup steps that take you into the rest of the module. Use it to get an overall picture before you work, and return to it whenever you need to check a date or a threshold.
The page opens with the essentials in one line: PPWR, Regulation (EU) 2025/40, replaces the 1994 Packaging Directive (94/62/EC) and is directly applicable in every EU member state. It covers all packaging, regardless of material, and every company that places packaged products on the EU market.
The headline tiles
Three tiles summarise the regulation's shape:
| Tile | Value | Meaning |
|---|---|---|
| General Application Date | 12 Aug 2026 | The date the regulation's obligations start to apply. |
| Scope | 100% of packaging | All packaging is covered, regardless of material. |
| Staged Obligation Waves | 2026 to 2040 (14 years) | Requirements phase in over waves; being conform in 2026 is the start, not the finish. |
Why it matters
Three cards capture the logic the whole module is built on:
- Binary obligations. Placing a single packaging on the market triggers company-level obligations. Quantities only matter for fees and reporting.
- Roles decide. Your activities determine your roles (manufacturer, importer, distributor, producer per member state), and your roles determine the obligation programme. The Check your applicability link takes you straight to the Applicability section.
- Per-unit conformity. Every packaging unit needs classification, substance compliance, technical documentation, and a declaration of conformity. The Classify your packaging link takes you to the Packaging section.
Timeline
The timeline shows the regulation's milestones from February 2025 to January 2040. Click a milestone to see its detail: what applies from that date and the articles behind it. For example, the 12 Aug 2026 milestone, PPWR applies, shows: market access only for conform packaging, the heavy-metals limit of 100 mg/kg, PFAS limits for food-contact packaging, economic-operator obligations (Chapter IV), and registration and EPR (Chapter VIII), referencing Articles 4, 5, 15 and following, and 44 and following.
Key thresholds
Six tiles list the numbers you will meet repeatedly, each with its legal basis:
| Threshold | What it is | Basis |
|---|---|---|
| 100 mg/kg | Heavy metals sum (Pb, Cd, Hg, Cr VI) in packaging. | Art. 5(4) |
| 25 / 250 ppb, 50 ppm | PFAS limits in food-contact packaging. | Art. 5(5) |
| At most 50% | Empty-space ratio for transport and e-commerce packaging, from 2030. | Art. 24(1) |
| A at least 95, B at least 80, C at least 70 | Recyclability performance grades. | Annex II |
| 40% | Re-use target for transport packaging in 2030. | Art. 29(1) |
| Below 10 t/a | Simplified reporting per member state. NOT an EPR exemption. | Art. 44(8) |
What to watch out for
Four warnings flag the mistakes companies actually make:
- Deadlines may shift with pending delegated and implementing acts (Art. 4 and various).
- The 10-tonne threshold eases reporting only. Registration and EPR remain (Art. 44(8)).
- National layers persist, for example the German VerpackG and LUCID register, and the EU regulation prevails where they overlap (Art. 4(3)).
- Own-brand and import fictions can make you the manufacturer (Art. 3(1)(13), Art. 21).
Living knowledge base
A callout explains that the module is continuously aligned with the current state of the law: the base regulation, its delegated and implementing acts (for example Delegated Decision (EU) 2026/429 on pallet wrapping films), and official Commission guidance. As the legal framework evolves, the rules in the software evolve with it. The page also carries the module's standing disclaimer: it is a working aid, not legal advice, based on Regulation (EU) 2025/40, and the English Official Journal text is authoritative.
Setup steps
The bottom of the page tracks your onboarding into the module with three steps and a progress count (for example, 0 of 3 complete):
- Assess applicability for your companies (status Open, with a count such as 2 of 6 companies checked). Run the PPWR applicability check for each of your companies so their standing obligations become visible. Start takes you to the Applicability section.
- Add packaging items (status Open, with a count of items added). Add every packaging item you place on the EU market. When you are done adding, mark the step as finished with All items added; it stays open until you do, because only you know when your list is complete. Manage items opens the Packaging section.
- Fulfill compliance obligations (status Blocked until step 2 is finished, with a count such as 2 of 8 items fulfilled). Bring every packaging item to Compliance Status Complete or Not relevant for PPWR: classify each item and fill in substances, supplier info, technical documentation, and the declaration of conformity where needed. Open packaging takes you to the item list.
Feature outlook
A closing card previews capabilities coming to kolum: connecting packaging to transactional data like imports, adding suppliers directly to kolum to share PPWR-relevant info, storing created Declarations of Conformity inside kolum, versioned applicability checks per company to track how a result evolves over time, registration and EPR tracking per member state, and labelling readiness for the 2028 harmonised label. These are marked Coming Soon and are not yet part of the module.
ℹ️ Regulatory context. Everything on this page is drawn from Regulation (EU) 2025/40: conformity and substances (Articles 4 and 5), economic-operator obligations (Chapter IV), packaging minimisation and re-use (Articles 24 and 29), registration, EPR, and reporting (Chapter VIII), and the recyclability parameters of Annex II. See Regulation (EU) 2025/40.