The EU Packaging Regulation (PPWR) Now Applies: What to Do in Romania

21 October 2026 · ACSINTE & PARTNERS

Regulation (EU) 2025/40 on packaging and packaging waste (the "PPWR") entered into force on 11 February 2025 and has applied since 12 August 2026. As a regulation, it is directly applicable in Romania and replaces the framework built on Directive 94/62/EC. Its requirements are staggered, so the practical question for most companies is which obligations already apply and which ones need to be planned for now.

Who is concerned

The PPWR assigns obligations by role, and one company can hold several roles at the same time:

• Manufacturers carry the main responsibility for packaging design, sustainability and labelling requirements. According to the European Commission's guidance, there is only one manufacturer at EU level for each packaging or packaged product.
• Importers bringing packaging or packaged products into the EU must, among other things, indicate their name and contact details.
• Distributors must act with due care so as not to compromise compliance and must cooperate with market surveillance authorities.
• Producers are defined per Member State for extended producer responsibility (EPR) purposes: registration, reporting and financing of packaging waste management in each country where they make packaging available.

Correctly mapping these roles across a group, its suppliers and its customers is usually the first step, as it determines who signs which documents and who pays which fees.

What already applies

From 12 August 2026, packaging placed on the market must comply with the PPWR's general requirements. Two points deserve attention. First, food-contact packaging must respect the limits on PFAS (per- and polyfluoroalkyl substances); the Commission's guidance indicates that there is no stock-exhaustion period for packaging placed on the market after that date, although packaging already placed on the market before it does not need to be withdrawn. Second, manufacturers are expected to carry out the applicable conformity assessment, keep technical documentation and draw up an EU declaration of conformity, with documentation retained for five years for single-use packaging and ten years for reusable packaging.

Member States must also put in place national penalty regimes. Companies should follow the Romanian implementing measures, including the rules on sanctions and on national EPR schemes.

What comes next

• 2027–2028: obligations for the HORECA sector on customers' own containers and reusable take-away options.
• 12 August 2028 (or later, depending on implementing acts): harmonized labeling, including material-composition labels.
• 1 January 2030 (or later, depending on delegated acts): recyclability performance grades, minimum recycled content for plastic packaging, packaging minimization and empty-space limits, and restrictions on certain single-use packaging formats.

The Commission has published implementation guidelines and FAQs, and several secondary acts are still pending. Dates expressed as "or later" should be monitored, because they depend on when those acts are adopted.

Practical first steps

For companies placing packaged goods on the Romanian market, a reasonable starting point is to: (i) inventory packaging formats and materials by product line; (ii) determine the company's role for each flow (manufacturer, importer, distributor, producer); (iii) request from suppliers the information needed for the declaration of conformity and technical documentation, including PFAS data for food-contact packaging; (iv) review supply and distribution contracts so that compliance obligations, information duties and costs are allocated clearly; and (v) check EPR registration and reporting in each Member State where the company acts as producer.

Where goods are also imported, customs and commercial documentation should be aligned with these roles from the outset.

ACSINTE & PARTNERS assists companies with PPWR role mapping, documentation and contract review.

This article provides general information and does not constitute legal advice.