New European Packaging Regulation in 2026: What Changes and How AGR Can Help

On 12 August 2026, the new European Packaging and Packaging Waste Regulation (PPWR) will begin to apply in general.

Regulation (EU) 2025/40 will progressively replace the previous European framework and introduce new requirements related to sustainability, traceability, material composition, labelling, recyclability, and packaging reduction.

Not all obligations will take effect at the same time. Some will apply from 2026, while others will be phased in over the coming years, with key milestones scheduled for 2030, 2035, and beyond.

But how does this regulation affect a publisher, a first-time game designer, or a company that markets board games? What documentation will be required? And how can AGR help?

A Regulation in Constant Evolution

Packaging legislation within the European Union is evolving towards a circular economy model.

The objective is to reduce waste generation, eliminate unnecessary packaging, improve recyclability, and progressively increase the reuse of certain packaging formats. The new Regulation establishes requirements covering the entire life cycle of packaging, from design and manufacture to use, collection, and end-of-life waste management.

These measures are essential to reduce the environmental impact of packaging. However, they also introduce new technical, documentary, and operational obligations for businesses.

For a large company, maintaining dedicated departments for quality, sustainability, or regulatory compliance may be relatively straightforward. For a small publisher, an entrepreneur, or a designer publishing their first board game, understanding and managing all these obligations can be far more challenging.

Many of these requirements apply to businesses of very different sizes and sectors, without always taking into account the limited resources available to smaller operators. In some cases, the administrative time and costs involved in preparing mandatory declarations may significantly exceed the actual environmental fees payable for the packaging placed on the market.

At AGR, we believe that environmental compliance should be compatible with competitiveness, innovation, and entrepreneurship. That is why we are working to help our customers understand these obligations and make them far more manageable.

What Changes from August 2026?

The PPWR establishes a more harmonised and demanding European framework for packaging and packaging waste.

As its various provisions come into force, it will become increasingly important to identify:

• Which packaging and transport packaging have been used and the materials from which they are made.

• Whether they are single-use or reusable.

• Whether they comply with the applicable sustainability, labelling, and recyclability requirements.

The Regulation also provides for the preparation of technical documentation, assessments, and declarations of conformity to demonstrate compliance with certain requirements.

However, this does not mean that all the most demanding obligations will apply from 12 August 2026. Many measures relating to recyclability, recycled content, reuse, labelling, and empty-space reduction will be introduced progressively.

Therefore, 2026 should be seen as the beginning of a transition that will continue over the coming years.

The Importance of Knowing the Origin of Your Packaging

One of the key aspects of the new framework will be having reliable information about the materials used.

Whenever a company purchases or uses packaging, it should be able to identify the supplier, the material reference, its composition, and its main technical characteristics.

Purchasing packaging outside Spain does not automatically mean non-compliance. However, it may make it more difficult to obtain technical data sheets, material specifications, declarations, and other supporting documentation.

Although the PPWR establishes a common framework across the European Union, obligations relating to national registers, Extended Producer Responsibility (EPR), and waste management systems continue to follow different procedures in each Member State. As a result, collecting this information outside Spain may prove difficult unless sufficient time and robust processes are dedicated to obtaining it.

A lack of documentation can become problematic when a public authority, marketplace, distributor, or customer requests evidence demonstrating compliance with the legislation.

We are already seeing a similar trend to that experienced with previous packaging legislation and CE marking documentation: increasingly, organisations require documentary evidence before allowing certain products to be placed on the market.

How Can AGR Help?

At AGR, we are developing a system to identify and monitor the main packaging materials used in the products we manufacture for our customers.

The documentation provided by AGR does not automatically replace the publisher's own legal obligations. However, it helps prevent customers from having to reconstruct the entire supply chain documentation from scratch.

Our objective is to go one step beyond manufacturing: to deliver every production together with the documentation needed to place the product on the market.

The PPWR and Current Spanish Packaging Legislation Are Not the Same

It is important to distinguish between the technical and documentary requirements introduced by the PPWR and the obligations arising from Extended Producer Responsibility (EPR).

In Spain, companies placing packaged products on the market already have obligations primarily governed by Royal Decree 1055/2022, including:

• Registering in the Packaging Section of the Product Producers Register.

• Reporting the packaging placed on the Spanish market.

• Participating in a collective or individual Extended Producer Responsibility scheme.

These obligations are separate from the technical and documentary requirements introduced by the PPWR.

The two frameworks are complementary. Complying with packaging registration and reporting obligations does not necessarily mean that all PPWR technical requirements have been met, and having technical documentation relating to packaging materials does not replace the obligations associated with EPR.

A Particularly Difficult Burden for Small Publishers

Packaging reporting obligations and the progressive implementation of the PPWR may prove especially challenging for companies placing relatively small quantities of products on the market.

Registration, classification, and reporting systems are generally designed to accommodate companies from a wide variety of industries and sizes. As a result, a small publisher may need to interpret technical concepts, classify materials, collect packaging weights, review categories, and prepare documentation that is not always easy to understand.

When this information is not classified correctly, companies may end up:

• Declaring more packaging than they actually use.

• Applying incorrect material categories.

• Paying higher fees than necessary.

• Spending excessive time on administrative tasks.

In many projects, the actual environmental cost associated with the declared packaging may be relatively low, while the work required to interpret, collect, and submit the necessary information can be substantial.

How Can AGR Reduce the Impact of These Obligations?

At AGR, we are working to provide a straightforward system that helps customers improve the documentation and traceability of the packaging used in their board games.

In addition to supplying the available technical information relating to our productions, we also aim to offer complementary support services such as:

• Training and guidance regarding the Product Producers Register.

• Assistance in preparing the information required by an EPR compliance scheme (SCRAP).

• Preparation of document templates.

• Review of declared packaging information.

• Monitoring future PPWR implementation milestones.

Our goal is to reduce the time spent managing these obligations, minimise errors, and provide every customer with clearer, better organised documentation.

Prepare Now to Avoid Problems Later

Manufacturing a board game does not end when it leaves the production line.

Placing a game on the market requires maintaining technical, safety, and environmental documentation. This information may be requested by authorities, distributors, marketplaces, customers, or Extended Producer Responsibility organisations.

Furthermore, packaging legislation will continue to evolve over the coming years. The PPWR introduces new milestones relating to recyclability, labelling, recycled content, packaging reduction, and reuse.

At AGR, we want our customers to focus on designing, publishing, and selling great games. That is why we are working to ensure that both manufacturing and the accompanying documentation are clear, organised, and easy to manage.

Regulatory compliance should never become a barrier to publishing a board game.

With a well-controlled supply chain and the right support, it is possible to achieve compliance from the outset while avoiding unnecessary costs, administrative burdens, and future surprises.

For more information about how AGR can help you with the documentation and management of your game's packaging, please contact us at info@agrpriority.com

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