EU PPWR Three Months On: What Has Changed for Plastic Bag and Film Importers (November 2026)

Updated 4 November 2026. The EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) has applied since 12 August 2026. Three months in, the first obligations are live: substance limits including PFAS in food-contact packaging, conformity assessment with a declaration of conformity and technical documentation, and manufacturer marking. Several bigger items have slipped or still wait for Commission acts. For the full rules on plastic bags and film (scope, thickness classes, 2030 and 2040 targets), see our EU packaging rules guide.

Where things stand

What changed since August

The Commission FAQ, second edition

On 3 August 2026 the Commission published a second edition of its PPWR FAQ. For importers the key points are: packaging placed on the market before 12 August can stay there; for stock made before that date but sold later, name, address and batch details can go in accompanying documents; and responsibility stays with the manufacturer. Others can carry out the conformity assessment and sign the declaration, but the technical documentation cannot be delegated. The Commission also asked authorities to start with warnings rather than fines. The FAQ is guidance, not law, and law firms warn that authorities and courts may read the text more strictly.

Labelling is running late

The Commission had planned to adopt the implementing acts for harmonised sorting labels by 12 August 2026. It did not, as Packaging Europe reported on 20 August. The label becomes mandatory 24 months after the act, and not before 12 August 2028. Until then national schemes such as France’s Triman continue, so there is no point printing an EU sorting pictogram on bags yet.

Substances of concern

ECHA circulated a draft list of substances of concern in packaging, with comments due 24 August 2026. The Commission’s report is due by 31 December 2026 and may lead to further restrictions. Nothing new applies to bags yet, but expect fuller substance declarations to be requested next year.

The authorised representative debate

In December 2025 the Commission proposed suspending the duty to appoint an EPR authorised representative in each member state where a producer is not established. Parliament voted its position in October, limiting the suspension to micro and small EU-based companies, and the Council agreed its stance on 21 October 2026. Until the two agree, the current rule applies in full, and the proposals only concern EU-based producers. If you import from a Vietnamese factory yourself, you are normally the producer for EPR in your country.

Germany, France, the Netherlands

Germany replaced the VerpackG with the VerpackDG on 12 August 2026. Registration in the LUCID register is still required before placing packaging on the market. Changes to existing registrations can be notified until 12 November 2026, existing system contracts run until 31 December 2026, and fines for PPWR breaches start on 12 February 2027. In France the AGEC-based EPR system continues and we found no new French decree since August. In the Netherlands producer responsibility still runs through Verpact. We could not confirm any formal enforcement action in the three countries so far.

Documents to ask your Vietnamese supplier for

• Inputs for the declaration of conformity: product description, resin types, thickness, additives and masterbatches, and the factory’s name and address for each item.
• Material specifications per item and per lot, with the lot number printed on every pack so a batch can be traced.
• Heavy-metal statement (Pb, Cd, Hg, Cr VI under 100 mg/kg), ideally backed by a test report.
• REACH SVHC statement against the current Candidate List.
• Food-contact declaration of compliance under Regulation (EU) No 10/2011 for produce bags, food bags and food film, plus a PFAS statement.
• Recycled content evidence (source of recyclate, post-consumer or post-industrial, percentage by weight) if you buy recycled-content bags.
• Proof of origin for EVFTA preferential duty.

Hanpak makes bags and film to the buyer’s spec, works under ISO 9001 and JIS, prints a lot number on every pack, offers recycled content on request (mainly trash bags) and issues proof of origin for EVFTA preferential duty.

Frequently asked questions

Is the PPWR fully in force now?

It applies since 12 August 2026, but in stages. Substance limits, conformity documents and marking apply now. Harmonised labels, recyclability and recycled content targets come later and depend on Commission acts.

Can I still sell bags I imported before 12 August 2026?

According to the Commission’s FAQ, packaging placed on the market before that date can remain on the market. Check with your national authority if the stock is large.

Has the labelling deadline moved?

The implementing act was not adopted on time. Because the label applies 24 months after the act and not before 12 August 2028, the practical date may slip.

This page is general information, not legal advice. Check your own obligations with your national authority or a lawyer.

Need documents for an EU shipment? Send us your spec or WhatsApp +84 898 545 893.

Sources: European Commission, 11 Aug 2026; Commission PPWR FAQ, 3 Aug 2026; Hogan Lovells on the FAQ, 13 Aug 2026; Bergeson & Campbell, 12 Aug 2026; Noerr on PPWR and VerpackDG, 11 Aug 2026; Packaging Europe, 20 Aug 2026; Council of the EU, 21 Oct 2026; Regulation (EU) 2025/40.