Welcome to iCM Quarterly Insights
Welcome to the Q2 2026 edition of the iCM Compliance Newsletter.
In this issue, we focus on recent developments related to the EU Packaging and Packaging Waste Regulation (PPWR), a regulation that will significantly impact organizations placing packaged products on the EU market.
With the European Commission recently publishing implementation guidance and FAQs ahead of the first major compliance milestone in August 2026, organizations now have greater clarity on their obligations and can begin preparing for upcoming requirements.
Our goal is to provide timely insights to help compliance, procurement, product stewardship, packaging, and supply chain teams stay informed and prepare effectively.
Regulatory Spotlight: Commission Guidance Published
The European Commission has released implementation guidance and a first FAQ package to support the consistent application of the Packaging and Packaging Waste Regulation (PPWR).
The guidance provides additional clarity on:
- Packaging definitions and scope
- Responsibilities of manufacturers, importers, and distributors
- Substance-related requirements
- Conformity assessment expectations
- Documentation and recordkeeping obligations
Why This Matters
The publication of the Commission guidance provides organizations with clearer direction on how PPWR requirements are expected to be interpreted and implemented as the August 2026 compliance deadline approaches.
August 2026: The First Critical Deadline
Although PPWR entered into force in February 2025, most obligations begin applying from 12 August 2026.
Organizations should use the remaining preparation period to assess packaging-related information, supplier readiness, and documentation processes.
| Date | Milestone |
| February 2025 | PPWR entered into force |
| August 2026 | First major obligations apply |
| 2028 | Harmonized packaging labeling requirements |
| 2030 | Recyclability performance and recycled-content requirements begin to phase in |
| 2040 | Additional recycled-content targets apply |
Why PPWR Is Different
PPWR represents a significant shift in regulatory expectations by treating packaging not simply as waste, but as a regulated product requiring supporting compliance documentation and traceable information throughout the supply chain.
A major practical change is that packaging itself now becomes subject to compliance processes that many organizations traditionally associate with products and materials.
Organizations may need to establish and maintain:
- Declaration of Conformity (DoC) documentation
- Technical documentation supporting compliance
- Conformity assessment records
- Supplier-provided compliance information
- Supporting evidence demonstrating regulatory compliance
As a result, packaging compliance is increasingly becoming a cross-functional responsibility involving compliance, procurement, packaging, engineering, quality, and supply chain teams.
The Emerging Challenge: Supplier & Packaging Data
Many PPWR requirements depend on information that is typically held by packaging suppliers, converters, or packaging manufacturers.
Organizations may need to collect and maintain:
- Packaging composition information
- Supplier declarations
- Packaging material information
- Technical documentation
- Compliance evidence and supporting records
The introduction of new requirements, including restrictions on certain substances in packaging applications, further increases the importance of obtaining accurate and up-to-date supplier information.
For organizations with complex supply chains, obtaining and maintaining this information may become one of the most significant PPWR preparation activities.
Recommended Actions for Q2 2026
Whether you are evaluating structured compliance processes or preparing for upcoming EU packaging requirements, the following steps are recommended this quarter:
1. Identify Packaging Materials and Components
Develop an inventory of packaging materials and components used across products placed on the EU market.
2. Map Packaging Suppliers
Identify suppliers responsible for packaging materials, packaging components, and packaging-related compliance information.
3. Review Documentation Processes
Evaluate how packaging-related declarations, supporting evidence, and compliance records are currently managed.
4. Establish Supplier Information Collection Processes
Develop a structured approach for obtaining packaging composition information, declarations, and supporting documentation from suppliers.
5. Plan for Future Requirements
Begin assessing future data needs related to recyclability, recycled content, and other packaging-related compliance obligations expected in the coming years.
How iCM Supports Your Compliance Workflow
iCM helps organizations stay organized and informed as regulatory requirements continue to evolve by supporting:
- Centralized storage of compliance documents and declarations
- Supplier engagement and information collection workflows
- Structured organization of compliance-related records
- Version comparison of regulations, helping teams understand what has changed
While regulatory interpretation and applicability decisions remain internal compliance responsibilities, iCM helps ensure that supporting information, supplier responses, and compliance records remain organized, accessible, and audit ready.
Looking Ahead
The publication of the Commission guidance marks an important milestone in the implementation of PPWR. While several packaging-related requirements will continue to phase in over the coming years, August 2026 represents the first major compliance deadline for organizations placing packaged products on the EU market.
Organizations that begin preparing now by establishing packaging inventories, engaging suppliers, and strengthening documentation processes will be better positioned to address both current and future PPWR obligations.
Stay informed. Stay compliant.
Your iCM Compliance Team
