Packaging produced before 12 August 2026 and still held in stock does not have to be destroyed, remanufactured or re-labelled. The European Commission confirms the Article 15(5) and 15(6) identification and contact details may travel in an accompanying document instead. Packaging already placed on the market before that date may remain there.
Regulation (EU) 2025/40 applies from 12 August 2026 under Article 71, and it says nothing explicit about the warehouse. The European Commission answered the question in the second edition of its Packaging and Packaging Waste Regulation FAQ, published in August 2026 and flagged there as new material.
Three situations, three answers
| Where the packaging sits on 12 August 2026 | Position under the regulation |
|---|---|
| Already placed on the EU market | May remain on the market even if it does not meet PPWR requirements |
| Produced but still in stock, not yet placed | Need not be destroyed, remanufactured or re-labelled; Article 15(5) and 15(6) information may be supplied in an accompanying document |
| Manufactured after 12 August 2026 | An accompanying document may be used only where affixing the identifier and address to the packaging is not possible |
The distinction turns on placing on the market, defined in Article 3(1), point (10), as the first making available of packaging on the Union market. Stock in a warehouse has not been placed on the market, so the transitional easing applies to it.
What the accompanying document has to carry
Article 15(5) requires a type, batch or serial number or other element allowing identification. Article 15(6) requires the manufacturer name, registered trade name or registered trademark, and a postal address indicating a single contact point. For pre-existing stock both may sit in a document that travels with the packaged product rather than on the packaging itself.
For packaging made after the application date, that route narrows. Whether affixing is possible is assessed case by case against the physical dimensions, shape and functional characteristics of the packaging.
Sources: Regulation (EU) 2025/40, PPWR Frequently Asked Questions, second edition
The FAQ assists application and does not create obligations; the articles alone do that. Sorting existing stock from new production is the first inventory task in EU PPWR solutions, and the sequence of dates is set out in the PPWR compliance guide.