Starting August 12, 2026, Ukrainian companies exporting packaged goods to European Union countries must comply with the new uniform European packaging requirements set forth in EU Regulation 2025/40 on packaging and packaging waste—the Packaging and Packaging Waste Regulation (PPWR).
The new rules apply not only to manufacturers from EU countries. The European Commission explicitly states that the regulation applies to all packaging placed on the EU market, regardless of material or origin. Thus, the requirements also apply to goods from Ukraine, Serbia, Turkey, China, and other third countries.
The regulation entered into force on February 11, 2025, but its main provisions began to apply on August 12, 2026. It replaced the European directive on packaging and packaging waste, which had been in effect for over 30 years.
For Ukrainian businesses, this primarily affects manufacturers of food and beverages, cosmetics, household chemicals, consumer and industrial goods, as well as e-commerce companies that ship packaged products to customers in the EU.
The new regulations establish requirements for the composition and safety of packaging materials, the reduction of excessive packaging, and the potential for reuse and recycling. Manufacturers must assess the packaging’s compliance with the established requirements and issue an EU Declaration of Conformity.
For shipments from Ukraine, direct legal responsibility for placing imported goods on the European market often lies with an importer registered in the EU. According to the regulation, an importer is a company or individual located in the European Union that places packaging or packaged goods from a third country on the EU market. With regard to imported products, the importer is responsible for verifying compliance with established requirements.
However, this does not mean that Ukrainian manufacturers will not have to make any changes. In practice, the European importer will need to obtain from the supplier information on the packaging’s composition, confirmation of its compliance with requirements, and technical documentation. If a Ukrainian company is unable to provide these documents or if the packaging does not comply with the PPWR, the European partner will not be able to properly place such goods on the EU market.
One of the requirements, which will take effect as of August 12, 2026, concerns packaging that comes into contact with food. It must not contain PFAS—so-called “forever chemicals”—in concentrations exceeding the limits set by the Regulation.
At the same time, some of the widely discussed PPWR requirements are being phased in gradually.
For example, the requirement to ensure that all packaging is recyclable is set for 2030, and the new unified labeling rules will also be introduced later. Therefore, it would be incorrect to claim that, as of August 12, 2026, companies are already required to comply with absolutely all future PPWR standards.
For Ukrainian exporters, the practical significance of the reform is that packaging compliance is gradually becoming just as much a prerequisite for access to the EU market as the safety and quality requirements for the product itself. Companies in the food, light industry, chemical, and FMCG sectors, as well as manufacturers producing under the private labels of European retail chains, should pay particular attention to their packaging.
On August 3, 2026, the European Commission additionally published updated guidance for businesses on the application of the PPWR, while the general effective date for the main provisions of the regulation was set for August 12.
Source: EU Regulation 2025/40 and the European Commission’s guidance on the Packaging and Packaging Waste Regulation.
