Newsletter 08/2026: New Packaging Requirements: Everything You Need to Know About the PPWR
With the summer months still in full swing, some of you may think of other summer activities (such as packing a suitcase) when the word “packaging” comes up, but for our newsletter and for you, our readers and customers, what matters is the packaging of goods and packaging in general. What have lawmakers in store for us in this regard?
Packaging and Packaging Waste Regulation (PPWR)Â
In connection with the entry into force of the aforementioned regulation on August 12, 2026, manufacturers, importers, and distributors of packaging may now be considered producers of the empty service, transport, and primary production packaging itself. This means they may be required to keep records of this packaging and pay contributions to the EKO-KOM system for it.
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Going forward, suppliers of the aforementioned empty packaging will be considered producers—that is, the parties responsible for paying contributions to the EKO-KOM system.
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First, let’s look at how packaging is classified under the regulations:
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1. Service packaging:
The PPWR expands the scope of service packaging, for which the manufacturer, importer, or distributor of such empty packaging is now considered the producer. Service packaging is defined as packaging intended to be filled at the point of sale or taken away for the purpose of delivering the product to the end customer. The material from which the packaging is made is not the determining factor. Therefore, this does not apply only to plastic packaging, as was previously the case. Service packaging includes, in particular, plastic takeout containers, paper pizza boxes, beverage cups, bags for baked goods and other food items, and carry-out bags.
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If you are interested in more detailed information, we recommend visiting Ekokom’s website directly or contacting them directly.
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In our newsletter, we would like to focus more on shipping packaging; however, importers of service packaging should also pay close attention to this section.
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2. Shipping packaging:
Here we’re talking about good old pallets, strapping bands, stretch film, cardboard boxes, e-commerce boxes (intended for shipping), as well as packing materials, bubble wrap, and reinforced corners.
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For this type as well, it is necessary to identify the producer of the empty packaging, which is the entity that:
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• manufactures or imports unmarked shipping packaging,
• commissions the production of shipping packaging marked with its name, trade name, or trademark.
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3. Primary packaging:
These are packaging materials for unprocessed primary-production products and include, for example, potato sacks or apple crates. Essentially, the same principles apply to them as we mentioned regarding shipping containers.
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What should you prepare for and what will actually change for you?
For importers and companies engaged in cross-border trade, this all boils down to one “simple” thing: if you bring empty pallets, boxes, packing materials, or stretch film into the Czech Republic for your own use or for resale, the obligation to declare and register them (e.g., in the EKO-KOM system) now falls directly on you.
In addition to the reporting requirements themselves, there is one key administrative obligation—proving compliance (the so-called “paperwork”).
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- Two mandatory documents for packaging: For each type of transport packaging that you place on the market or import, you must have Technical Documentation prepared (in accordance with Annex VII of the Regulation) and an EU Declaration of Conformity issued (in accordance with Annex VIII of the Regulation).
- What should the analysis and documentation look like? You certainly don’t need to worry about having to send every piece of plastic film or cardboard to a lab for a complete chemical analysis of all substances. The documentation is based on declarations. All you need is confirmation and data sheets from your supplier (manufacturer) stating that the packaging meets the specified limits—for example, that the total content of heavy metals (lead, cadmium, mercury, hexavalent chromium) does not exceed 100 mg/kg and that the packaging does not contain any prohibited hazardous substances.
- Is there a template for this? The structure of the EU Declaration of Conformity is specified in Annex VIII of the PPWR Regulation, and a simplified template in Czech is available for free download on the Ekokom website:
https://www.ekokom.cz/wp-content/uploads/2026/08/Vzor_Prohlaseni_o_shode_CZ.pdf
- You must maintain your own records in your internal systems. You must archive the technical documentation and the issued Declarations of Conformity for 5 years for single-use packaging and 10 years for reusable packaging.
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Who will monitor this and how?
In the Czech Republic, routine market inspections are primarily conducted by the Czech Trade Inspection Authority (ČOI) (which checks documentation, formal requirements, and labeling) and the Czech Environmental Inspection Authority (ČIŽP) (which focuses on compliance with environmental limits).
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Customs officials will not automatically stop every container at the border to inspect the contents of the packaging. In this case, the Customs Administration operates on a risk-based approach. However, if it receives a tip regarding a high-risk supplier or commodity, it may suspend the release of goods into free circulation and request proof of the aforementioned Declaration of Conformity.
If you are asked to provide documentation, you must be able to respond very quickly (usually within 10 days), so it is a good idea to have everything ready in advance.
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What else lies ahead for us?
From the perspective of European plans, the August requirements are really just a kind of administrative warm-up. The European Union is rolling out stricter requirements gradually, and we recommend keeping an eye on the upcoming milestones of this initiative:

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If you have any questions, please contact your sales representative or Ekokom directly, which provides a detailed overview of the regulation on its website.
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