A coffee roaster in Manchester reorders the bags it has used for three years. Same paper, same artwork, same size. The order goes out as usual and stops at the supplier, because the artwork can no longer be produced as it stands.

Regulation (EU) 2025/40, the packaging and packaging waste regulation that most people call the PPWR, started applying on 12 August 2026. Most of what has been written about it is aimed at compliance managers and reads like a filing exercise. The part that reaches a small food business first is more physical than that: it changes the print file.

Who this actually applies to

Worth being precise, because a lot of the panic reading is aimed at the wrong people. This is EU law. It bites on packaging placed on the EU market. A British café serving British customers is not brought under it by reading about it.

It reaches you if your goods travel into the EU, if you run a site inside the EU, or if you buy packaging that is being placed on that market. For a UK business, the domestic reporting duty is a separate story with its own thresholds and its own registration, which we covered in our piece on who actually pays packaging EPR. The point of this article is what to expect if any part of your packaging goes into Europe.

The marking lands in the artwork, not in a folder

The regulation requires the packaging itself to show who made it: the manufacturer name, registered trade name or trade mark, and a postal address, along with electronic contact details where they exist. It also has to carry something that identifies the item, such as a type, batch or serial number. That information can be given through a QR code or another digital carrier instead, as long as it stays visible, legible and reachable.

On plain unprinted stock, that is a question of the outer case and the paperwork. On printed stock it is a layout question. A small functional area has to exist somewhere on the bag, the box or the cup, and on a lot of designs no such area was ever planned, because the artwork runs across the whole face.

In practice the mark sits where it disturbs the design least: on the base fold, along the glue seam, on the reverse, or at the bottom of a side gusset. It is small, it is not decorative, and nobody is meant to read it the way they read a strapline. If you are touching the artwork anyway, plan that area now rather than squeezing it in later between the logo and an allergen note.

Whose name goes there

This is where the confusion costs the most time, and it runs in both directions. It is not about your brand name. Your logo on the bag does not satisfy the requirement, because what is asked for concerns the maker of the packaging rather than the business filling it.

The opposite worry is just as common: that a supplier wants to stamp itself across your design. That is understandable and it misreads the thing. The mark is a mandatory line at footnote size, not a sender address on a letterhead. No serious manufacturer enlarges it voluntarily, because it eats the print area you paid for.

The case worth pausing on is the third one. Where packaging carrying your own name and brand comes in from outside the EU, the roles in the chain shift, and you may not be a straightforward buyer any more. Own-brand, direct import and anything printed with your own company logo are the three situations to settle in writing before the stock reaches a shelf, not after somebody asks.

Two declarations that keep getting mixed up

Ask a supplier for the certificate and you get whichever document is nearest to hand. There are two, and they answer different questions.

The food-contact declaration belongs to the material. It says, in effect, that this paper with this coating may touch food under the conditions described, whether that is hot, greasy, or in contact for a certain time. The European basis for it is Regulation (EC) 1935/2004.

The EU declaration of conformity under the packaging regulation belongs to the packaging as a product. It says the packaging meets the requirements of that regulation. Neither document replaces the other, and a supplier who offers one when you asked about both has not necessarily done anything wrong; they have simply answered a different question.

The practical version is short. Ask for both, for the exact material and format you are ordering rather than for the supplier range in general. A declaration that names the paper and the coating is a document. A badge on a website is not.

PFAS: the part that changes the material

Running alongside the marking, limits on PFAS in food-contact packaging also started applying on 12 August 2026: 25 µg/kg for an individually measured PFAS, 250 µg/kg as a sum, and 50 mg/kg for total fluorine. The formats caught by this are mostly the grease-resistant papers, which is to say the ones that go over a counter all day.

That is a material question rather than a layout question, but it comes up in the same conversation. If you are already talking to a supplier about the marking, settle both at once. What is genuinely worth checking when a grease-resistant paper changes is set out in our piece on the PFAS limits.

What is not due yet

This is the section that will save you money, because a certain amount of work is about to be sold that nobody needs this year. The regulation is staged. Some of it has applied since August 2026; other parts are dated to later years, and several of those dates hang on implementing acts, so they can still move.

  • The harmonised material-composition label, the common sorting symbol on the pack, is dated to 2028.
  • QR labelling for reusable packaging is dated to 2029.
  • Recyclability grades and minimum recycled content are dated to 2030.

If somebody offers you a full redesign today on the grounds that something is about to hit, ask which article and which date. For the three points above the honest answer is that they are coming, but not this quarter. Reworking artwork so the manufacturer marking sits properly is sensible. Replacing a whole range in a hurry is not.

The reverse is also true. If your design is being touched in the next few months, leave room for the sorting symbol while you are in there. It costs almost nothing at the design stage and saves a second plate change in 2028.

What to ask your supplier

Five questions worth asking before the next reorder, none of which involve talking about money:

  • What exactly will the manufacturer marking look like on my artwork, where does it sit, and how large is it?
  • Will I see an updated layout before approval, or is the marking added during production?
  • Can I have both declarations, food-contact and packaging, for this specific material and format?
  • How is the identifying element handled, printed on the pack or through a digital carrier?
  • If I buy own-brand or import directly, who counts as the manufacturer in this chain and what do you need from me?

What this does not settle

A correctly marked bag is evidence about the packaging and not a clean sheet for everything else. National registration duties sit separately and are not answered by a line of small print. Whether a paper is recyclable is not answered by it either; that still depends on the fibre content, the coating and what the local sorting system will take.

An honest word about the calendar as well. Several of the later deadlines are tied to implementing acts and can shift, so decisions taken now are best limited to what has applied since August, with the rest watched rather than pulled forward. This is a manufacturer's practical account and not legal advice for your situation.

The useful ending is an unglamorous one. Open the artwork file for whichever pack you order most, whether that is the natural kraft bakery bag on the counter or a delivery box, and settle two things before your next approval: where the manufacturer marking goes, and which two declarations arrive with the pallets. After that, reordering is routine again.