Many assume that all environmental thresholds apply immediately after 12 August 2026, but that is not the case.
The main requirements coming into effect from the date of application are: ① Documentation obligations—you must have a Declaration of Conformity and technical documentation ② PFAS limits for food contact packaging ③ General recyclability requirements
Most substantive thresholds come later, such as recycled material content requirements for plastic packaging, detailed standards for designing for recyclability, and harmonized material composition marking.
Important caveat: Public sources inconsistently state the exact application year for various requirements. For example, harmonized marking has two different stated years: 2028 and 2030. Please refer to the official EUR-Lex version.
Practical meaning for users: What you should be doing now is not rushing to redesign packaging, but building up documentation and supporting evidence. You have several years of buffer time before substantial changes to packaging materials, but customers will request documentation from now on.