Your packaging supplier is not handling your PPWR compliance. You are.

The 12 August 2026 deadline is no longer a distant warning. It is an immediate compliance requirement.

The EU Packaging and Packaging Waste Regulation — PPWR, or Regulation 2025/40 — came into force in February 2025 and becomes legally applicable across the EU on 12 August 2026. For refurbished tech operators, it is probably the most significant piece of packaging legislation in a decade. And most of the industry is either unprepared, misinformed, or quietly hoping someone else will deal with it.

RePack has been working on reusable e-commerce packaging since 2013. We were involved in shaping this regulation during its preparation phase, and we felt its consequences directly when the final text killed provisions we had built our original business model around. We know this regulation in detail. We are not neutral observers, but we are informed ones.

This guide explains what is actually required right now, what is coming later, and what the difference between EU-manufactured and Chinese-sourced packaging means for your compliance position.

What PPWR is

PPWR replaces the older Packaging and Packaging Waste Directive and upgrades it from a directive — which member states could interpret loosely — to a regulation, which applies uniformly across the EU from day one. It covers all packaging placed on the EU market, regardless of where it was manufactured. If you ship refurbished phones to consumers in Germany, France, or Finland, your packaging is in scope.

The regulation runs to 2038 in terms of its full ambition. But the obligations that land on 12 August 2026 are specific, immediate, and not optional.

What is enforceable right now — August 2026

There is a lot of noise about PPWR covering recyclability grades, reuse targets, and void fill limits. Most of that is real, but most of it applies from 2028 or 2030, not today. Here is what actually lands on 12 August 2026.

The Declaration of Conformity. Every unique packaging type placed on the EU market must have a signed Declaration of Conformity backed by a full technical dossier. This is a standalone obligation. It is not linked to CE marking. It is not something your supplier handles on your behalf by default. If your brand is on the packaging, or if you specified the design, the materials, or the dimensions, you are the manufacturer under PPWR, and the Declaration of Conformity is your responsibility.

Substance restrictions. Article 5 of PPWR sets hard limits on hazardous materials. For device packaging, the key requirement is that the combined concentration of lead, cadmium, mercury, and hexavalent chromium must not exceed 100 mg/kg across the packaging or any individual component. You need a lab test or Certificate of Analysis from your supplier confirming these levels. Without one, you cannot sign a valid Declaration of Conformity.

The manufacturer question — and why Chinese-sourced packaging is exposed

This is the part most refurb operators have not thought through.

Under PPWR, the manufacturer is not necessarily the factory that made the box. It is the entity that determined the packaging specifications. If you told a Chinese supplier to produce a white box to your dimensions with your logo, you are the manufacturer. The Declaration of Conformity is yours. The technical dossier is yours. The producer registration in every EU member state where your product is sold is yours.

This creates three practical problems for operators using Chinese-sourced OEM packaging.

Documentation. Chinese manufacturers are not uniformly prepared to provide PPWR-compliant technical dossiers. Getting the right test reports, material breakdowns, and manufacturing documentation from overseas suppliers is possible but takes time and active management. Many operators have not started.

Producer registration. You must register under Extended Producer Responsibility (EPR) schemes in each EU member state where your packaging is placed on the market. EPR remains national despite PPWR harmonisation — each country runs its own register, its own fee schedule, and its own reporting cadence. Selling across Germany, France, Finland, and the Netherlands means four separate registrations, and in most cases you must register before the first unit ships into that market.

EPR cost structure. EPR fees are calculated on the weight of packaging placed on the market annually. This is where packaging choice has a direct commercial impact: a reusable box that completes four trips counts as one unit placed on the market, not four. At scale, the difference between single-use and reusable packaging becomes a meaningful line item in your EPR cost, not just an environmental argument.

None of these problems are insurmountable. But they require your procurement team to act now, not after August.

What happens if you do not comply

The fines on paper are large. For example Germany has indicated penalties up to €200,000. Authorities can also order product withdrawal from the market and block future shipments.

In practice, enforcement in the first months after August 2026 is likely to be uneven. Most member states are still finalising their national implementing legislation. Active fines for small and mid-sized operators in the first wave are possible but not certain.

The more immediate risk is commercial. B2B partners, marketplaces, and enterprise buyers are already asking for Declarations of Conformity as part of procurement qualification. If you cannot produce one when asked, the consequence is not a regulator at the door. It is a lost contract, a delisted product, or a paused shipment. For refurb operators selling through third-party platforms or into retail partnerships, that is a more proximate risk than a fine.

What EU-manufactured mono-material packaging means

The clearest path through PPWR compliance is packaging designed with the regulation in mind: EU-manufactured, built from a single recyclable material, with a supplier who can provide the complete technical dossier.

EU-manufactured packaging comes with a shorter and more legible supply chain. The supplier is subject to EU regulations directly. Material certifications, heavy metal reports, and harmonised standard documentation are standard outputs from compliant EU manufacturers.

Mono-material packaging, built from paper without plastic film inserts, laminates, or mixed adhesives, is well positioned for the 2030 recyclability grades. It does not guarantee an A or B grade, because the detailed methodology has not yet been finalised, but it avoids the multi-material complexity that is most likely to score poorly.

For refurb tech operators specifically, the reusability consideration matters beyond compliance. A packaging system used multiple times distributes the compliance cost across more journeys and reduces EPR fees proportionally. The investment made today counts toward 2030 obligations, and the economics improve with every additional loop the box completes.

Where to start

The operators who will find August 2026 manageable are the ones who have already been talking to their suppliers. The ones who will find it stressful are the ones who assumed their supplier was handling it.

A note on RePack Vie

RePack Vie is EU-manufactured and built from materials that are straightforward to certify under PPWR.

The tray component is made from a starch and cellulose compound, over 80% bio-based carbon content, derived entirely from plant-based sources. It is recyclable with paper, with a validated 99% fibre recovery rate, and the fibres it adds to the paper stream improve the quality of the recycled paper produced. Heavy metal content is well below PPWR Article 5 limits. The fibres are FSC certified. The carton sleeve is a standard mono-material paperboard. All components are designed for easy disassembly, supporting separation for recycling at end of life.

RePack Vie already carries a machine-readable QR code on the packaging, meeting the 2029 digital identifier requirement for reusable packaging ahead of the deadline.

Neither component requires REACH registration — starch, paper pulp, and cellulose premix components are explicitly excluded under REACH Appendix IV and V.

We provide our customers with the full technical documentation required for their Declaration of Conformity: material composition data, manufacturing specifications, and test reports.

RePack Vie is designed to work in both reusable and disposable systems. In a disposable setup, it meets all PPWR requirements as a mono-material, EU-manufactured box with full documentation support. In a reusable system, it also directly affects EPR costs. A box that completes four trips registers as one unit placed on the market, not four. At scale, that saving becomes a meaningful line item and strengthens the business case for reusable packaging beyond the environmental argument.

If you want to understand what PPWR compliance looks like in practice for your current packaging setup, we are happy to work through it with you.

If your supplier cannot answer these questions clearly and in writing, you have work to do before August.