What about already produced stock? Does it also need to be PPWR-compliant?

Regulation (EU) 2025/40 contains no retroactive obligation for existing stock. Products manufactured and lawfully placed on the market before 12 August 2026 may continue to be sold after that cut-off date — without retroactive labelling, without a PPWR-compliant QR code label, and without changes to the packaging design.

The decisive dividing line is the date of production, not the date of sale. Goods that leave the factory on 11 August 2026 are not subject to the new requirements, even if they are still on the shelf in October 2027. Packaging newly produced or newly introduced to the EU market from 12 August 2026 onwards must, however, be fully PPWR-compliant — including recycled content declarations, recyclability labelling, and a digital product passport via GS1 Digital Link.

Practical recommendation for your warehouse: document the production date of your stock carefully, ideally with production dates on delivery notes or batch records. For mixed inventories, physical separation by production date is advisable. Plan your production cycles so that new orders from mid-July 2026 onwards are already produced in a PPWR-compliant manner — allow sufficient buffer time for labels, print approval, and system integration.

For a binding legal assessment relating to your specific product category and supply chain, please contact your local Chamber of Commerce and Industry.