EU PACKAGING / BUYER REFERENCE
Reviewed 31 August 2026. Regulation (EU) 2025/40 is the EU Packaging and Packaging Waste Regulation (PPWR). It entered into force on 11 February 2025 and generally applies from 12 August 2026. Individual requirements have separate deadlines and conditions.
What to review for MSQ SAFE orders
For safety footwear and industrial PPE, packaging changes must preserve the product's protection, traceability and required instructions. PPWR packaging review is a separate workstream from PPE conformity assessment.
- Document footwear boxes, garment bags, glove dispensers, inserts, master cartons and pallet wrapping separately.
- Preserve legibility and access to required model, batch, safety and user-instruction information when changing packaging.
- Evaluate moisture barriers, seals and protective inserts against the storage and transport needs of the specific PPE.
- Record packaging material and mass by SKU and confirm importer and destination-market reporting responsibilities.
Timing: do not treat every requirement as a 2026 deadline
- Now: review the applicable obligations for the packaging and economic operator, including substance restrictions, traceability, technical documentation and the EU declaration of conformity where required. The PPWR PFAS limits applying from 12 August 2026 concern food-contact packaging; they are not a blanket ban on all plastic products.
- 12 February 2028: the sales-packaging empty-space minimisation obligation applies, taking necessary functionality and protection into account.
- Harmonised sorting labels: 12 August 2028 or 24 months after the relevant implementing acts enter into force, whichever is later. Scope exclusions apply. Confirm the applicable final rules before printing artwork.
- 2030 and later: recyclability, recycled plastic content and certain packaging restrictions are phased requirements. Design-for-recycling criteria apply from 1 January 2030 or 24 months after the relevant delegated acts enter into force, whichever is later. The 50% empty-space ceiling for grouped, transport and ecommerce packaging applies from 1 January 2030 or three years after the relevant implementing acts enter into force, whichever is later, with exemptions. It is not a universal 2026 shoebox limit.
Packaging information to include in an EU RFQ
Provide the destination Member State, intended placing-on-market date, product SKU, quantity, distribution channel, packing dimensions and proposed artwork. Identify the packaging manufacturer, brand owner, importer and the party responsible for each applicable obligation; these roles are not interchangeable.
- Component-level materials, weights and specifications, including coatings, adhesives and inserts.
- Applicable substance evidence, material supplier declarations and recycled-content evidence when a claim or requirement relies on it.
- Packaging identification and traceability; the applicable technical file and EU declaration of conformity, with their scope and responsible issuer.
- A destination-specific check of packaging EPR registration, reporting and representative obligations. Do not assume one registration covers every EU Member State.
- An approved packing sample and a record of changes after approval.
Evidence, not a blanket compliance promise
A CE marking or PPE test report does not establish packaging conformity. Do not remove necessary protective or hygiene packaging solely to reduce plastic weight.
No product or packaging is represented as PPWR-certified by this guide. Compliance must be assessed for the final packaging configuration, supply-chain role, destination and applicable date. Confirm requested documentation and its availability for the specific order before purchase.
This page is general procurement information, not legal advice or an EU declaration of conformity. The regulation, subsequent acts and applicable national requirements take precedence. Obtain qualified advice for product-specific legal decisions.