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Requirement · CNF-03

Prove conformity without relying on a national standard: the route by which a notified national standard conferred a presumption of conformity where no harmonised standard existed is not carried over.

Economic operators in Member States that had notified national packaging standards must comply, and this is law in force.

Why it matters

This is law in force, not a proposal.

  • It is Art. 36(1), by omission of the 94/62/EC Art. 9(2)(b) route, in the Packaging and Packaging Waste Regulation. as of 2026-08-18
  • The act gives its timing as: From 12 August 2026 (Art. 71). as of 2026-08-18
  • It names 5 industries by name: Plastics converting, Paper and board, Glass, Aluminium and Wood. as of 2026-08-18
  • Compliance is checked by self-assessment, per assessment. as of 2026-08-18
Addressee Economic operators in Member States that had notified national packaging standardsAct Regulation (EU) 2025/40, base actArticle Art. 36(1), by omission of the 94/62/EC Art. 9(2)(b) routeClass Businesses

What changes

Operators in Member States with an established national packaging standards estate, who lose a compliance route they had under the directive. The Art. 37 common-specification power is the intended replacement, but it is a Commission power rather than an operator's entitlement and nothing obliges the Commission to exercise it.

Prior rule vs new rule

Prior rule
Trigger

packaging complying with a notified national standard in an area where no harmonised standard existed

Obligation

Compliance with a relevant national standard, communicated to the Commission and published in the Official Journal, conferred a presumption of conformity with the essential requirements wherever no harmonised standard covered the area.

New rule
Trigger

a requirement covered by no harmonised standard and no common specification

Obligation

No presumption is available. The operator demonstrates conformity directly under Art. 35, using state-of-the-art methods of low uncertainty.

Who is affected

Addressee
Economic operators in Member States that had notified national packaging standards
Class
Businesses
Sectors
Names Plastics converting, Paper and board, Glass and ceramics, Aluminium and metals, Wood and wood products · Reaches Food, drink and tobacco, Retail and distribution
Applies
From 12 August 2026 (Art. 71)

Burden drivers

D1 · D4 — 2 of 7 marks fire on this provision.

No size threshold.

Source text

Verbatim

Test, measurement or calculation methods referred to in Article 35 which are in conformity with harmonised standards or parts thereof, the references of which have been published in the Official Journal of the European Union, shall be presumed to be in conformity with the requirements covered by those standards or parts thereof set out in that Article.

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