As of 12 August 2026, products can be supplied to the EU market only in packaging with documented compliance.

As of 12 August 2026, the European Union Regulation (EU) 2025/40 on packaging and packaging waste (Packaging and Packaging Waste Regulation, PPWR) has begun to apply. The regulation entered into force on 11 February 2025 and replaced Directive 94/62/EC, which had governed the sector since 1994. Unlike a directive, the regulation applies directly and uniformly across all EU Member States, without needing transposition into national legislation. For exporters, this means a single set of rules across the EU market.

The regulation covers virtually all types of packaging, regardless of material: consumer, grouped and transport packaging. For the dairy sector, this includes bottles, cups, lids, cheese films, butter parchment, corrugated boxes, stretch film and other packaging in which products reach consumers.

Requirements Already in Force
The main new requirement introduced in 2026 is a mandatory EU Declaration of Conformity for each type of packaging. It must be prepared based on technical documentation under the internal production control procedure. The regulation does not provide for a separate conformity mark on packaging: compliance is confirmed exclusively through documentation.
At the same time, restrictions on the content of per- and polyfluoroalkyl substances (PFAS) in food-contact packaging have come into force. For the dairy sector, the greatest risks concern grease-resistant butter parchment, paper cups and cardboard with protective coatings. Restrictions on heavy metal content in packaging also remain in place.
The regulation does not provide for a transition period for existing stocks. Documentation is required for packaging used for all products placed on the EU market from 12 August 2026, regardless of when those products were manufactured.

Allocation of Responsibility
The packaging manufacturer prepares and signs the Declaration of Conformity. Under the regulation, this generally means the company under whose name or trademark the product is placed on the market. For Ukrainian brands, this means the obligation to prepare the documentation often falls on the brands themselves rather than their European partners.

The importer must verify that the Declaration of Conformity and technical documentation are available, retain a copy of the declaration, and provide the documents to market surveillance authorities upon request within 10 days.

Exemptions for Dairy Products
The regulation takes into account the sector’s specific characteristics. Milk and dairy products are excluded from the mandatory deposit-return systems for bottles and cans that EU Member States must introduce by 2029, as well as from the targets concerning the share of reusable beverage packaging.

Next Steps
The remaining requirements will be introduced gradually. From 2028, a single EU label for waste sorting will be introduced, requiring packaging labels to be updated.

From 1 January 2030, requirements will apply to packaging recyclability, minimum recycled plastic content — 10% for food-contact packaging made from polyolefins and 30% for PET packaging — as well as the minimisation of packaging weight and volume.

From the same year, bans on certain single-use plastic formats will apply. These include film used to group products into multipacks, which affects yoghurts and desserts, as well as single-portion plastic containers for cream used in food-service establishments.

Recommendations for Producers
Dairy exporters should already conduct an inventory of all types of packaging and obtain from suppliers information on material composition and test results concerning PFAS and heavy-metal content.

On this basis, technical documentation and Declarations of Conformity should be prepared.

Companies should also separately agree with their European partners on the allocation of responsibilities, including registration in national extended producer responsibility (EPR) systems.

Companies should incorporate packaging redesign to meet the 2030 requirements into procurement plans for 2027–2028.

Timely preparation of the required documentation will help avoid supply delays and refusals to accept products, while also strengthening the position of Ukrainian producers on the European market.