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On 12 August 2026, the PPWR (Packaging and Packaging Waste Regulation) officially came into force across all twenty-seven Member States of the European Union – the new regulation on packaging (Regulation (EU) 2025/40).
From that date, no packaging can be sold on the European market without meeting specific conformity requirements. Glass is no exception: every container must now be accompanied by technical documentation and an EU declaration of conformity, and must refer to a producer registered in the national register.
The regulation looks at function, not material: packaging is any item intended to contain, protect and deliver a product. The bottle and the jar that reach the shelf already filled are sales packaging – what habit still calls primary, although the PPWR no longer uses that term. Alongside it the regulation distinguishes grouped packaging and transport packaging, e-commerce packaging, service packaging – the container filled at the point of sale – and primary production packaging, reserved for unprocessed agricultural and fishery products.
For anyone buying glass packaging, the obligations introduced by the regulation are above all about paperwork. What changes are the documents and certificates that must now accompany every supply: without them, the product can no longer be sold within the borders of the EU.
The question every buyer should be asking today is simple: “has my supplier given me the declaration of conformity?” A check that applies to every type of packaging, from clear glass to decorated glass.
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What the PPWR Is and Who It Concerns
The PPWR is the new European legislative framework created to govern the entire life cycle of packaging and packaging waste. It covers every material, glass included, setting out the structural requirements and the documents needed to place packaging on the market in the EU.
It is important to understand that the regulation does not concern only those who physically make the bottle or the jar. It assigns specific obligations to five key roles along the supply chain, with each one responsible only for its own part:
- The packaging manufacturer: responsible for drawing up the technical documentation and the declaration of conformity.
- The supplier: must pass on to the manufacturer the technical information about the materials it provides.
- The producer: the party that first makes the already-packaged product available on the market in a given country (for example, the brand that bottles a beverage or fills jars with a preserve). This is the role that carries the obligations linked to collection and recycling.
- The importer: must verify the conformity of packaging arriving from outside the European Union before placing it on the market.
- The distributor: responsible for the correct conditions of transport, storage and handling of the goods.
Take the case of a food & beverage brand that buys empty jars from an Italian glassworks for food filling: in this scenario the brand almost always acts as the producer, not the manufacturer. Clarifying the boundaries of these roles from the outset is the first step to pinpointing exactly which obligations fall to the company and which to the supplier.
The Four Obligations in Force from 12 August 2026
With the regulation now in force, four requirements become essential straight away:
- Technical documentation and conformity assessment;
- EU declaration of conformity;
- Substance restrictions;
- Producer registration.
The most talked-about obligations – recyclability and minimum recycled content – will only come into play from 2030. These four, on the other hand, already apply today, and this is where it makes sense to start. Let’s look at them one by one.
1. Technical Documentation and Conformity Assessment
Every item of packaging must have its own technical documentation and pass a conformity assessment. The documentation sets out, precisely, all the information that describes the packaging:
- the material;
- the composition;
- the declared environmental performance;
- the evidence supporting it.
2. EU Declaration of Conformity
The EU declaration of conformity is the document with which the packaging manufacturer states, in black and white, that the packaging meets the applicable requirements. It is the certificate every buyer can – and should – request: it refers back to the technical documentation and identifies precisely which packaging it relates to. That is exactly why it is worth far more than a generic self-declaration.
3. Substance Restrictions
The regulation sets a number of limits that directly affect food contact:
| Substance | Limit | Which packaging it applies to |
|---|---|---|
| PFAS, individual substance | 25 ppb (targeted analysis, polymeric PFAS excluded) | Food-contact packaging |
| PFAS, sum of substances | 250 ppb (targeted analysis, polymeric PFAS excluded) | Food-contact packaging |
| PFAS, including polymeric PFAS | 50 ppm | Food-contact packaging |
| Total fluorine | Above 50 mg/kg the supplier must provide, on request, evidence of how much of it is PFAS | Food-contact packaging |
| Lead, cadmium, mercury, hexavalent chromium | 100 mg/kg as the sum of the four | All packaging |
The cap on heavy metals is nothing new: it already existed in the previous legislation, and so does the derogation that applies to glass. Where the limit is exceeded because of recycled cullet, and not because those metals have been added deliberately, the packaging can still be sold: the average has to stay within 200 ppm over twelve consecutive months for each furnace, and the exceedance has to be reported to the competent authority. This is Decision 2001/171/EC, which the PPWR keeps in force.
The ban on PFAS, however, is entirely new, and applies both to empty packaging and to packaging that already holds the food.
4. Producer Registration
Every EU country keeps its own national producer register. The party required to register is whoever first places an already-packaged product on the market in that country: in our sector this is usually the brand that fills and sells the bottle or jar, not the glassworks that produces it. Without registration, that product simply cannot be sold.
The register is not a formality: it is how each Member State checks that whoever places packaging on the market is meeting its collection and recycling obligations. Registration is per country, not per company – a business selling in five markets registers in five registers. And where the producer has appointed a producer responsibility organisation to act on its behalf, that organisation also discharges the registration obligations, unless the Member State holding the register provides otherwise.
On timing, though, nothing should be taken for granted: the regulation sets no single date for the national registers, which depend on the Commission’s implementing acts and on how quickly each Member State moves. Until then, the national obligations already in place continue to apply.
Alongside these obligations come the manufacturer’s marking – name or trademark and address, shown on the packaging, via a QR code or in an accompanying document – and a traceability system linking each item of packaging to its own technical documentation.
What Changes for Glass Packaging
For glass, the regulation brings limited changes, and mostly favourable ones. There are three reasons, all verifiable in the text of the regulation.
First: the obligation to use a minimum share of recycled material applies only to plastic packaging. The regulation does not require it for glass. The percentages so often quoted – 30% by 2030 for plastic beverage bottles, 65% by 2040 – therefore do not apply to glass, which is not required to demonstrate any minimum recycled content on the input side.
Second: the recycling target for glass rises from the 70% set for 2025 to 75% by 2030. This is a target placed on the Member States, not on the individual item of packaging, and glass already starts from a favourable position in terms of collection and recycling.
Third, and this is the aspect most often overlooked: the substance restrictions are not confined to the glass itself. A plain, undecorated container rarely exceeds the PFAS limits; however, inks, enamels, coatings, labels, gaskets and closures are also part of the packaging, and must be declared together with the container. A screen-printed glass or a frosted bottle is therefore not only glass: the decoration is an integral part of the packaging, and the documentation must account for it.
Two 2030 deadlines do apply to glass, as they do to every other material. The first requires the weight and volume of any packaging to be reduced to the minimum needed for it to do its job. The second falls on whoever sells to the consumer: at least 10% of beverages will have to be offered in reusable packaging, with a list of exemptions that matters a great deal for glass – wine, aromatised wine, other fermented beverages, spirits, milk and dairy products and highly perishable drinks.
This is why, in the case of decorated glass packaging, the structure of the supply chain takes on real documentary significance, rather than being a mere organisational detail.
The Deadlines That Follow
12 August 2026 is only the first operational step in a longer path, marked by deadlines to monitor in order to stay compliant with the PPWR. Those already set by the regulation are:
| Date | What comes into effect |
|---|---|
| 12 August 2026 | Technical documentation, EU declaration of conformity, PFAS and heavy-metal restrictions, marking and traceability, producer registration |
| 12 August 2028 | Harmonised packaging labelling with standardised pictograms for separate collection |
| 2030 | European design-for-recycling criteria, with packaging below class C excluded from the market; minimum recycled content for plastic; minimisation of weight and volume; 10% of beverages in reusable packaging; 5% reduction in packaging waste; 75% glass recycling target |
| 2035 | Recyclability at scale; 10% reduction in packaging waste |
| 1 January 2038 | Only packaging in recyclability class A or B may be placed on the market |
| 2040 | Further recycled-content thresholds; higher reuse targets, as an endeavour; 15% reduction in packaging waste |
A word of caution, though: some of the 2030 criteria – in particular those on design for recycling – will be defined by European Commission implementing acts not yet published. Anyone planning investments around that deadline would do well to treat them as a broad reference, and not yet as a definitive specification.
Operational Checklist for Glass Packaging Buyers
From rules to practice is a short step. For a buyer, the PPWR obligations translate into a series of concrete checks on suppliers and documentation. Here are the six main ones, in the order it makes sense to work through them:
- Establish your own role under the regulation – manufacturer, producer, importer or distributor – because everything else follows from it.
- Ask every supplier for the EU declaration of conformity, checking that it identifies the packaging precisely and not by generic family.
- Verify that the declaration covers the complete packaging: container, decoration, closure and accessory elements. This is where most gaps are found.
- Check registration in the national producer register for the markets where the packaged product is sold.
- Update environmental claims on labels, product sheets and websites: generic statements are no longer defensible today, either under the PPWR or under the Green Claims rules.
- Store the documentation received so that it can be retrieved by batch, and not only by supplier: the traceability required is to the packaging.
The Evidence Behind the Declaration
The conformity assessment the regulation requires is internal production control: the manufacturer guarantees and declares under its own responsibility, and Annex VII requires the technical documentation to include the test reports.
Vetreria di Borgonovo has had the glass tested against the requirements of the regulation by the Stazione Sperimentale del Vetro, an independent external laboratory. The test reports form part of the technical documentation and are the basis on which the declaration of conformity rests. The buyer can request them to verify, on documentary evidence, what the supplier declares.
Request the declaration of conformity and the test reports for catalogue glass packaging or for a custom project.
Regulatory source: Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste, repealing Directive 94/62/EC (OJ L, 2025/40, 22.1.2025). This article is for information purposes and does not replace a conformity assessment. Last updated: \[publication date\].
