PPWR and your online store: what to do on the site, and what not to do - August 12, 2026
This article starts from a real event: about a month ago, while working on the implementation of the new law regarding the right of withdrawal from June 19, 2026, we came across an article about PPWR. This prompted us to ask a few clients, including FruttaMax, Biruința, and Sweet Mountain, if they knew about the regulation.
On August 12, 2026, Regulation (EU) 2025/40, known as PPWR, the European regulation on packaging and packaging waste, came into effect. Being a regulation, not a directive, it applies directly in Romania, with the same text as in any other member state, without a separate national law.
For a private label online store, the legal change is easy to remember: you are treated as a packaging manufacturer, not just a product seller. This means that the liability for the packaging's compliance is yours, even if you do not physically manufacture the box, bottle, or label.
What is mandatory starting today
From August 12, 2026, four things are mandatory: the EU Declaration of Conformity for the packaging, the technical documentation behind it, the ban on PFAS in food contact packaging, and EPR registration for those who place transport, service, or e-commerce packaging on the market for the first time.
All four are documentation obligations. They are kept in the company's records and shown upon request to an authority or a business partner. None of them require publishing anything on the site.
What not to do on the site
There is an idea circulating that the declaration of conformity must be publicly displayed or linked on the online store. This is not correct. According to Article 39 of Regulation (EU) 2025/40, the declaration is drawn up by the manufacturer, kept updated, and retained for the control of market surveillance authorities. It is not submitted to a central portal and is not a public document. It is retained, not published.
The same logic applies to the following stages. From August 12, 2028, a harmonized EU label with pictograms showing what material the packaging is made of and how to sort it becomes mandatory. The label must physically be on the packaging, not on the site. A QR code can complement the label, but cannot replace it. From February 12, 2029, a separate label for reusable packaging is added, also physical. From 2030, recyclability classes, minimum percentages of recycled content, and a 50% empty space limit for transport and e-commerce packaging come into force. The latter relate to the choice of boxes and filling materials, not to the site's content.
The practical conclusion for a Shopify store
Throughout the 2026-2030 period, there is no point in the PPWR calendar where the regulation requires the publication of any document on the site. Each obligation is either an internally kept document or a physical mark on the packaging.
If you sell private label products, the real step to take now is not on the site, but in the relationship with packaging suppliers: collecting complete declarations of conformity, per component (bottle, cap, label, box), not just a generic letter from a single supplier.
Frequently Asked Questions
Does the PPWR declaration of conformity need to be put on the site?
No. It is a document kept internally and shown upon request to an authority or partner, not a public document.
Since when does the PPWR apply in Romania?
Since August 12, 2026, directly, without a separate national law, because it is a regulation, not a directive.
Is a private label online store considered a packaging manufacturer?
Yes. The liability for packaging compliance falls on the one who places the product on the market under their own brand, even if they do not physically manufacture the packaging.
This article is for informational purposes and does not constitute legal or tax advice. For an exact assessment of your obligations under PPWR, required documentation, and EPR registration, talk to a specialized legal or accounting consultant.
Official source: Regulation (EU) 2025/40, EUR-Lex, Article 39.