Packaging · PPWR · (EU) 2025/40
Packaging conformity: clearing customs does not mean you are compliant
The European Union Packaging and Packaging Waste Regulation has applied since
12 August 2026. Packaging placed on the EU market after that date needs a Declaration of
Conformity and a technical file standing behind it. For a manufacturer in Türkiye the
difficulty is usually the same one: the packaging is not something they produce, they buy it
from a supplier, and so the data the declaration has to rest on is not in their hands.
Where the document is actually asked for
The conformity document is not paperwork requested at customs. It is asked for under market
surveillance, and the importer has to produce it within ten days when requested (Art. 18(8)).
For single use packaging the file is kept for five years. That distinction matters in practice:
packaging assumed to be compliant because shipments cleared without incident can come back
months later through a surveillance request, and ten days is not enough time to assemble a
technical file.
What binds today and what does not
12.08.26In force. Declaration of Conformity (Annex VIII), technical file (Annex VII) and heavy metal limit obligations apply.
31.12.26Expected. Deadline foreseen for the Commission implementing act on how recycled content is to be calculated.
12.02.27Expected. Deadline for Member States to set penalty rules. What enforcement looks like locally becomes clear after this date.
12.08.28Later. Harmonised packaging labels.
01.01.30Later. Recyclability classes, packaging minimisation and recycled content targets.
What can be done now
The declaration is not a formality, it is the output of an inventory. The sequence runs like
this: for every product going to the EU, a component by component breakdown of the packaging;
the material, weight and supplier of each component; written confirmation from the supplier of
material composition and recycled content share; a check against heavy metal limits; then the
technical file and the declaration. The hard part is collecting supplier data, and having a
standard form for what you ask the supplier shortens the process noticeably.
Talk to us about a packaging inventory and declaration →
Construction products · CPR · (EU) 2024/3110
GWP declaration: the obligation arrives with your product family
The new Construction Products Regulation has applied since 8 January 2026. The point most
often confused: GWP declaration did not become mandatory for all construction products at once
on that date. The obligation comes into effect as each product's harmonised technical
specification is renewed, so the timetable varies by product family.
Dates
The delegated act providing for System 3+ in the assessment of environmental characteristics
arrived in July 2026. The product family timetable spreads across 2026 to 2029; secondary
sources mention the last quarter of 2027 for cement and 2028 to 2029 for doors and windows,
and those dates are not yet settled. Core environmental indicators are foreseen to apply from
9 January 2030 and the full life cycle indicator set from 9 January 2032.
The reason to start early is data, not the calendar
For a construction product manufacturer to declare GWP, an EN 15804 compliant life cycle
model has to exist. The input to that model is a year of material and energy balance data from
the production site. The data usually exists, but it is kept on an accounting logic and is not
allocated per product. What takes time is not building the model, it is bringing the data down
to product level. Starting when the specification update is announced generally does not leave
enough time.
The same model is the basis of EPD preparation. Work done for the CPR therefore also
produces the input for the EPD a tender or a customer asks for; they are not two separate
exercises.
Life cycle assessment and EPD →
Export · CBAM · (EU) 2023/956
The gap between a default value and installation data is a cost gap
The definitive CBAM period began on 1 January 2026. Goods in scope can now only be imported
by authorised CBAM declarants, and there is a de minimis threshold of 50 tonnes net per
importer per year (electricity and hydrogen excluded). For 2026 imports, the first annual
declaration and certificate surrender falls on 30 September 2027. Certificate sales start on
1 February 2027, and the quarterly fifty per cent holding check applies from 31 March 2027.
Why default values are expensive
Where installation data is not supplied, the default values published by the Commission
apply. The values for 2026 were set by IR 2025/2621, and the correction in IR 2026/1740 was
published on 31 July 2026 with retroactive effect to 1 January 2026. By definition those values
sit above the real performance of a well run installation, and the difference feeds straight
into the number of certificates to be bought. For a producer exporting iron and steel,
aluminium, cement or fertiliser from Türkiye the practical question is whether it can
calculate and evidence its actual embedded emissions, and if it cannot, how it will share the
difference with its EU customer.
Deduction of a carbon price already paid
Article 9 of the Regulation allows a carbon price effectively paid in a third country to be
deducted. The draft implementing regulation was published on 13 May 2026 and is awaiting
adoption. Two limits in the draft text are decisive: only a price that has actually been paid,
is mandatory and is non-discriminatory counts, and free allocation is deducted. Unless a
payment is actually made under the Turkish Emissions Trading System, no deduction arises from
this article. The expectation that TR ETS will lighten the CBAM burden holds, on the current
text, only to the extent of the amount actually paid.
Scope extension
On 17 December 2025 the Commission put forward a proposal bringing downstream products into
scope, with application foreseen from 1 January 2028. The Council position arrived on
12 June 2026 and the ENVI report on 7 July 2026, with trilogue targeted for completion at the
end of 2026. The number of products that would fall in scope varies by source, and since the
proposal is not yet law it is early to plan against a definitive list. What is worth doing
today is having the installation data infrastructure in place for products already in scope;
when the extension comes, the same infrastructure applies to the new ones.
CBAM and TR ETS compliance →
Also tracking
Other dates coming up
27.09.26The Empowering Consumers Directive (EU) 2024/825 became applicable. Offset based "carbon neutral" and "climate neutral" claims, and unsubstantiated generic environmental claims, count as unfair commercial practices. A manufacturer using those phrases on a label or in a catalogue needs a product level calculation grounded in life cycle data.
27.10.26TR ETS monitoring methodology plan. The Turkish Emissions Trading System Regulation entered into force on 27 August 2026. Installations in the pilot scope submit a first monitoring methodology plan within two months of entry into force, and the Presidency can extend that to six months. The scope and timetable of the pilot phase were removed from the final text and left to a decision of the Carbon Market Board, so the 2026 to 2027 pilot dates circulating in the press are not binding today.
30.12.26EUDR applies to large and medium sized operators. Cattle, cocoa, coffee, palm, rubber, soy and wood are in scope, paper and pallets included. The EU importer files the declaration; the producer in Türkiye supplies geolocation and traceability data. For micro and small operators the date is 30 June 2027.
30.04.27TR ETS verified annual report. Deadline for the verified emissions and activity report for 2026. Installations below 50,000 tCO₂e do not enter emissions trading, but the monitoring and reporting obligation still applies to them.
The dates on this page reflect instruments in force
as at 29 September 2026. Regulations still at draft or proposal stage are marked as such in the text.
How a given date binds your product group depends on the customs tariff heading of the product
and on the target market.
