PPWR: What Changes for Your Bottles on 12 August 2026

The EU packaging rules change on 12 August 2026. What PPWR means for wineries, who counts as the manufacturer, what you must do now, and what is not due until 2028.

David Wippel Gründer von Glasswise

David Wippel

Founder of Glasswise

The EU packaging rules change on 12 August 2026. Unlike the e-label rules, this one is a Regulation, so it applies in every member state on the same day, with no national version and no transition period for packaging you place on the market from that date. Stock already on the market sells through.

Most of what you will read about PPWR concerns recycling quotas and reuse targets years away. The parts that touch a winery this year are narrower, and one of them is about information you already have.

What PPWR actually is

The Packaging and Packaging Waste Regulation replaces the packaging directive from 1994. The directive told member states what to achieve and let each write its own law, which is why packaging rules differed from one member state to the next. The Regulation applies directly instead, so the rules are the same everywhere you sell.

It covers every part of the pack: the bottle, the closure, the capsule, the label, the carton, the pallet wrap.

Who counts as what

PPWR calls the party with the identification duty the manufacturer. That word is misleading if you picture a glass works. The Regulation defines a manufacturer as anyone who makes packaging or a packaged product, and it adds that where something is made under a person's own name or trademark, that person is the manufacturer.

So if you bottle wine under your own label, you are normally the manufacturer, and your own details go on the bottle.

There is one exception, and it covers a great many European wineries. If you are a micro-enterprise, fewer than 10 staff and up to EUR 2 million turnover, and your packaging supplier is in the EU, then your supplier is treated as the manufacturer for this purpose. In that case it is your supplier's details that belong there, and the declaration of conformity is theirs too.

Two branches, and most wineries fall clearly into one of them. If your setup is less usual, private label bottling for a retailer, a négociant arrangement, or imports from outside the EU, get advice rather than guessing.

What changes on 12 August 2026

Identification. The manufacturer's name, registered trade name or trademark, postal address and electronic contact must be available to the person holding the bottle.

It does not have to be printed on the glass. The Regulation gives the manufacturer a free choice: on the packaging, or on a QR code or other data carrier. If you already have a QR code on the bottle for your e-label, you already have the carrier.

One caveat. If you are an importer, the rule is stricter. Importer details go on the packaging itself, and a data carrier is only allowed where printing them is not possible.

Declaration of conformity. The manufacturer needs a declaration of conformity for each type of packaging, with technical documentation behind it, available if an authority asks. Under the micro-enterprise branch above, that duty sits with your supplier rather than you.

Extended producer responsibility. Per-country registration is not new, whatever you may have read. The national schemes have required it for years. PPWR keeps the duty and will harmonise the registers later, once the Commission adopts the relevant act. Check that your registrations cover every country you sell into, not just your own.

What changes later

The harmonised labelling everyone is anxious about, the sorting pictograms and material composition codes, is not a 2026 problem. It applies from 12 August 2028, or 24 months after the Commission adopts the implementing act that defines the symbols, whichever is later. That act does not exist yet. The reuse marking runs on its own clock again, 12 February 2029 at the earliest.

So anyone selling you printed sorting pictograms today is selling you a guess. The sensible move is to have your packaging data in order and apply the marks when the symbols are published.

What to do now

  1. Work out which branch you are in. Own label, so you are the manufacturer. Or micro-enterprise with an EU packaging supplier, so they are.
  2. Collect the registered details that belong in the field, either yours or your supplier's.
  3. Check your EPR registrations cover every country you sell into.
  4. Sort out the declaration of conformity for each packaging type, or confirm your supplier holds it.
  5. Leave the pictograms alone until the implementing act lands.

How Glasswise helps

Your e-label is already a data carrier on the bottle, which is exactly the mechanism the Regulation allows for identification. The QR code you added for ingredients and nutrition can carry the packaging operator details too, without a second code and without a label redesign.

Glasswise already holds a structured picture of your packaging: each component, its material, its recycling code and its waste stream, from bottle to carton to pallet. Today that drives the sorting information your drinkers see when they scan. It is the same data PPWR asks you to have straight.

We are adding fields for the operator identification so it can travel through that same code, built to hold either your details or your supplier's depending on which branch you are in. When the harmonised symbols are finally published, the material data needed to generate them is already in your account.

What we do not do is file your EPR registration or sign a declaration of conformity. Those are not ours. What we can do is keep the information behind them in one place and current, rather than scattered across supplier emails.

The short version

12 August 2026 is real and close. The pictograms are not, they are 2028 at the earliest and the symbols do not exist yet. The work worth doing now is knowing which branch you are in, collecting the right registered details, and checking your registrations. If you already have a QR code on the bottle, you already have the carrier the Regulation asks for.

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