Last Updated on November 4, 2026

PPWR and Old Stock: What Happens to Packaging Made Before 12 August 2026?

You can keep it and sell it. Under the EU Packaging and Packaging Waste Regulation (PPWR), you do not have to destroy, remake or relabel packaging that was made before 12 August 2026.

The European Commission confirmed this in its updated PPWR FAQ in August 2026, answering a question many brands, importers and online sellers have about the boxes, bottles and pouches already in their warehouses.

Before you sell stock that was not on the market by 12 August, you still need to give a unique ID and the manufacturer’s details, but a separate document is enough.

Why “placed on the market” is the date that matters

PPWR rules apply when packaging is placed on the market, not when it was made. Article 3(10) defines placing on the market as the first making available of packaging, empty or filled, on the EU market.

Making available means any supply for distribution, consumption or use in the EU as part of a commercial activity, whether it is paid for or free.

For your stock, that means checking whether it had already been supplied into the EU market before 12 August 2026 or was still with you on that date.

For imported goods, placing on the market usually happens when the goods are released for free circulation at customs. Goods only passing through the EU in transit to a non-EU country are not placed on the market, so PPWR does not apply to them.

Packaging already on the market before 12 August 2026

Packaging placed on the EU market before 12 August 2026 can stay on the market, even if it does not comply with PPWR.

This matches Recital 14 of the regulation. Packaging should only be placed on the market if it meets the PPWR sustainability and labelling requirements. Packaging that was already on the market before a requirement applied, including packaging in stock, does not have to meet it.

In practice, this covers goods already with distributors, retailers and marketplace warehouses before the deadline. They can sell through as normal.

Packaging made before 12 August 2026 but still in stock

If your packaging was produced before 12 August 2026 but not yet placed on the market, you do not need to destroy it, remanufacture it or relabel it.

You do still need to meet two PPWR requirements before you sell it:

• Article 15(5): information that identifies the packaging, such as a serial number, batch number or another equivalent element
• Article 15(6): the manufacturer’s name and contact address

For this older stock, you can give this information in a document that accompanies the packaging. You do not have to print or stick it on each item. The same applies to reusable packaging already placed on the market.

The ID does not need to be unique to every single unit, because its job is to link the packaging to its technical documentation and EU Declaration of Conformity. A packaging type, model or production batch is enough.

What the old stock relief does not cover

The accompanying document route only helps with marking: the unique ID and the manufacturer’s details. It does not exempt unsold stock from the rest of PPWR.

If stock is placed on the market on or after 12 August 2026, it must still meet the requirements that already apply from that date. Two matter most:

• PFAS in food-contact packaging (Article 5(5)): limits of 25 ppb for any single PFAS, 250 ppb for the sum of targeted PFAS, and 50 ppm for total PFAS including polymeric PFAS. These are concentration limits, not an outright ban.
• Heavy metals (Article 5(4)): lead, cadmium, mercury and hexavalent chromium together must not exceed 100 mg/kg.

So if you hold unsold food-contact packaging made before the deadline, check its PFAS test results before you ship it. A paper label will not fix a substance problem.

Packaging made on or after 12 August 2026

New packaging has a stricter rule. The unique ID and the manufacturer’s name and address should be on the packaging itself.

An accompanying document is only allowed when the size or nature of the packaging makes this impossible. This is judged case by case, based on the physical size, shape and function of the packaging.

You also do not need to mark every component. Take a yoghurt cup with a lid and a sleeve: showing the information on one part of the sales packaging should be enough.

Treat the old stock route as a one-off transition measure rather than your standard way of labelling new packaging.

If you import packaged goods into the EU

Many brands selling into the EU are based outside it. If that is you, your EU importer has its own duties under Article 18 of PPWR.

Before placing the packaging on the market, the importer needs to check that the non-EU manufacturer has drawn up an EU Declaration of Conformity. It also needs to confirm the packaging carries the unique ID and the manufacturer’s name and address, as Articles 15(5) and 15(6) require. The importer’s own name and address must be given too.

The same old stock rules apply. Imported packaging released for free circulation before 12 August 2026 can stay on the market. Stock still outside the EU or in transit at that date must meet the rules when it is released, but it can use an accompanying document for the ID and contact details.

A worked example

Take a UK tea brand for example that sells into the EU. On 12 August 2026 it had three batches of packaged tea:

The brand does not need to repack batch B. But because tea bags and their wrappers are food-contact packaging, it should confirm the PFAS limits are met before the goods clear customs. Its EU importer also needs to check the Declaration of Conformity exists.

This is an illustrative example, not a real company.

What if your supplier information is missing?

Older packaging often comes without full design or material data. Maybe the supplier has changed, or a business was bought or merged.

In that case, the manufacturer must make best efforts to fill the gaps. That can mean asking the former supplier, asking the company that took over after a merger or acquisition, or carrying out your own assessment.

Keep a record of what you asked for and what you found. It shows a market surveillance authority that you took reasonable steps.

Will non-compliant packaging be pulled from the market?

Usually not at first. According to the Commission, enforcement from 12 August 2026 should not disrupt trade flows, supply chains or consumer access to goods.

Under Article 62 of PPWR, if a Member State finds non-compliance, it must first ask the business to fix it. You get a warning and a chance to correct the problem.

Only if the issue continues can authorities take further steps, such as banning, recalling or withdrawing the packaging. Authorities are also expected to support businesses with information requests and reasonable timelines, rather than leading with sanctions.

Old stock checklist

1. Split your stock into two groups: already placed on the EU market before 12 August 2026, and still with you on that date.
2. Keep proof of the date, such as invoices, delivery notes or customs release documents.
3. For stock not yet placed on the market, assign a batch or type ID that links it to your technical documentation.
4. Prepare an accompanying document with that ID and the manufacturer’s name and address.
5. Check you have an EU Declaration of Conformity for the packaging before it ships. It must be drawn up in, or translated into, the language required by each Member State where you sell (Article 39(2)).
6. Fill any gaps in older supplier data, and record your efforts. For food-contact packaging, confirm the PFAS limits are met.
7. Update your artwork so all packaging made from now on carries the ID and manufacturer details directly.
8. Plan ahead for the recycled content rules. They apply from 1 January 2030 at the earliest, and the FAQ says there is no stock sell-off period for packaging not yet placed on the market by then.

Get your packaging documents in order

For most businesses, dealing with old stock comes down to paperwork: a clear ID, manufacturer details and a Declaration of Conformity.

Euverify’s PPWR module helps you create your EU Declaration of Conformity and technical documentation in one place, in 24 EU languages. If you are based outside the EU, our PPWR Authorised Representative mandate is included in every plan at no extra cost, so your documents are held and ready when authorities ask. If you would like a hand sorting your stock, book a quick call with our team.

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