Food Gets a Breather on the DPP. Its Packaging Doesn't.
Good news: the EU isn't forcing a Digital Product Passport onto food products themselves — food is excluded from the ESPR — and the deforestation rules for wood and paper packaging (EUDR) have been pushed to 2026/2027. So a maker of yoghurt, syrup or muesli can exhale for a moment. The catch: PPWR gives no such delay. The packaging every product comes in must comply from 12 August 2026 — and that's true in every sector, not just food.
The food waits — the packaging doesn't
The Ecodesign for Sustainable Products Regulation (ESPR) explicitly excludes food and feed, so there's no direct product passport bearing down on a food SKU. And the EU Deforestation Regulation (EUDR) was postponed again: large and medium operators from 30 December 2026, micro and small ones from 30 June 2027.
But the Packaging and Packaging Waste Regulation (PPWR, EU 2025/40) has been in force since February 2025 and applies from 12 August 2026 — with no transition period for newly placed stock. Your product may wait; the bottle, cap, label, tray and pallet around it do not. Packaging is part of what you place on the market, and PPWR treats it as such.
One QR code, three audiences
The neat part: the same passport, reached by a single QR code on the product, speaks to everyone who needs it.
- The consumer sees the product composition, that it contains no allergens, that it's high in good fibre — and that the packaging is safe.
- Authorities get proof that the packaging carries no hazardous substances above the limits — heavy metals, PFAS, bisphenols, SVHCs and total fluorine.
- B2B partners (retailers, distributors) get an instantly shareable Declaration of Conformity — in 20+ EU languages, as PDF or Word, in one click.
One source of truth for the shelf, the auditor and the buyer — instead of paperwork and email attachments.
Not just food — every sector
This isn't a food story. Every physical product is packed in something, and that packaging falls under PPWR whatever the sector:
| Sector | Typical packaging |
|---|---|
| Cosmetics & chemicals | Bottles, dispensers, blisters |
| Electronics & batteries | Cartons, inserts, blisters, pallets |
| Textiles & footwear | Pouches, hang tags, transport packaging |
| Furniture, toys, building materials | Cardboard, wood, films |
Same principle, same platform: turn the product into a passport, add the packaging as layers, and the Declaration of Conformity assembles itself.
Same engine, whatever you make
Packaging is layered — primary (the bottle), secondary (the carton), tertiary (the pallet) — and because substance limits, recyclability and EPR apply per material (a glass bottle isn't a cardboard tray), each layer is recorded on its own and the layer DoCs compose into one for the whole pack. You see what it's made of (glass 200 g · metal 3 g · paper 1 g), not a single averaged number.
We cover the mechanics of that — layer-level declaration and the Annex VIII model — in a dedicated piece: PPWR packaging layers and the EU Declaration of Conformity. The point here is different and simpler: this is the same engine in any sector. A beverage brand and a laptop maker declare their packaging through the identical flow — the food or the electronics inside is a separate question; the packaging around it is one shared job.
The part that surprises non-packaging producers
You may make food, cosmetics or electronics — not packaging. But under PPWR you are still a packaging producer for what you put your product in. That obligation lands on 12 August 2026, regardless of where your product's own passport timeline sits.
Wood and paper: EUDR and ISPM 15 "to share"
If a layer is made of wood or paper, two more rules apply: EUDR (deforestation) for paper (HS 4819) and wooden (HS 4415) packaging, and ISPM 15 (phytosanitary) for wooden packaging in international transport (heat treatment plus an IPPC mark).
Good news again: these are assessed by the maker of the empty packaging. Once you fill it, you don't re-assess them — in your DoC you simply share and merge the supplier's declaration. dpp.gs does this through a link to the supplier's passport, so their EUDR/ISPM conclusions are carried over and displayed rather than re-done.
Build a layer-level packaging passport in minutes
Per-layer materials, substances, recyclability and EPR — with an EU Declaration of Conformity in every EU language, for any sector.
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The food gets a breather. The packaging doesn't. PPWR applies from 12 August 2026 and affects everyone who packs anything — across every sector. One QR shows the consumer composition and safety, the authority the substances, the B2B partner a finished DoC. And you build the packaging layer by layer, the way it actually looks. Don't wait for a delay that, for packaging, isn't coming.