PPWR: How does packaging legislation affect your business?

In most cases, the answer is yes.

The PPWR affects virtually every link in the chain that comes into contact with packaging, from manufacturers and importers to distributors and retailers.

The regulation builds on existing packaging rules but goes a step further. It not only specifies how packaging is designed but also how it is used, managed, and reported. For many companies, this entails additional obligations and a significant administrative burden.

Who is responsible under the PPWR?

An important point to note: responsibility does not lie solely with the party that designs the packaging. Even if you have little influence over the design, you may still be held legally responsible.

Do you import or distribute packaged goods within the EU? If so, you have certain responsibilities. These do vary depending on your role (see below).

Are you unsure whether the regulations apply to your organization? The answer is often “yes” if you:

• place packaged products on the EU market;

• sell packaged products;

• use packaging, including primary, secondary, and transport packaging;

• operate as a manufacturer, importer, or distributor.

Within a single supply chain, various parties may be involved, each with their own responsibilities. It is important to clearly distinguish between two key roles:

• The manufacturer ensures that the packaging complies with the PPWR requirements and must demonstrate this through, among other things, a declaration of conformity.

• The producer is responsible for registration and reporting obligations in the member state where the packaging is placed on the market.

The producer or “first placer”

The producer, also known as the “first placer on the market,” is the party that first places packaging on the EU market.

This can be a manufacturer, but it can just as easily be an importer, distributor, or retailer with a private label.

Starting August 12, 2026, this party must ensure that a declaration of conformity is available for each piece of packaging and, if necessary, be able to present it to the competent authorities.

Important: Do you sell products under your own name or brand? In practice, you are often considered a manufacturer, even if you do not design the packaging yourself.

Roles in the supply chain

The PPWR distinguishes four core roles. In practice, a single company may assume multiple roles simultaneously.

Manufacturer

As a manufacturer, you design or produce packaging and place it on the market under your own name. You are therefore responsible for its compliance.

• You are responsible for the design, the choice of materials, and demonstrating that the packaging meets the PPWR requirements.

• Before placing your packaging on the market, you must conduct a conformity assessment and draw up a declaration to that effect. You must be able to present this declaration to your customers.

• In addition, you must collect all the technical information necessary to support that declaration.

Starting August 12, 2026, all packaging must have such a declaration of conformity in order to be placed on the market.

Importer

Do you place packaged products from outside the EU on the market? If so, you bear an important responsibility for verification.

• You must verify that the manufacturer has complied with its obligations and that the declaration of conformity and technical documentation are available before placing the products on the market.

• You must also be able to present this documentation to the competent authorities.

• If you determine that a package does not comply with the regulations, you may not place it on the market and must, if necessary, take corrective measures, such as recalling or modifying the product.

Distributor

As a distributor, you sell or distribute products within the EU. Here, the focus is primarily on monitoring and vigilance.

• You must verify that the packaging you distribute complies with the PPWR requirements and that the necessary documentation is available, including the declaration of conformity.

• If you have doubts about the conformity of a package, you may not continue to distribute the product and must take action, such as recalling it and reporting the issue.

Final distributor

Do you sell directly to the end customer? If so, you must verify that the packaging is properly labeled and that the necessary documentation is available.

What are the PPWR requirements?

1. Prevention and reduction

The regulations place a strong emphasis on avoiding unnecessary packaging and reducing single-use plastics. Reuse and refill solutions are receiving more attention.

2. Recycled content

Plastic packaging must contain an increasing amount of recycled content. The regulation sets specific targets for this by 2030 and 2040.

3. Recyclability

Packaging must be sufficiently recyclable. Only packaging that meets these requirements may remain on the market.

4. Reuse

The regulations also encourage the reuse of packaging, particularly in transportation and logistics.

5. Labeling

New labeling rules are coming, including a uniform EU label starting in 2028 (with information on material composition and sorting instructions).

Please note: many technical details and guidelines are still being finalized. The focus right now is primarily on preparation and data management.

What needs to be in place by August 2026?

Starting August 12, 2026, you must, above all, be able to demonstrate that you have your packaging under control.

For manufacturers, this means, specifically:

• a Declaration of Conformity (DoC) for each type of packaging;

• access to technical documentation supporting compliance.

In practice, this requires clear processes and documentation, reliable data from suppliers, and sufficient insight into the entire supply chain.

How do you get started?

Step 1: Take stock of your packaging

Start by creating a complete overview of all the packaging you use or market. Consider factors such as material type, weight, size, and application (e.g., for transportation, e-commerce, or the hospitality industry).

For many companies, this is already the first challenge. Packaging information is often scattered across different suppliers and isn’t always fully documented.

This overview forms the basis for the next steps. It determines which PPWR requirements apply to you and what data you need to collect.

Step 2: Determine your role for each type of packaging

Under the PPWR, your role is determined on a per-product and per-packaging basis.

A single company can therefore have multiple roles at the same time. Without this insight, it is difficult to correctly determine which obligations apply to you.

Step 3: Collect data and documentation

Starting in August 2026, a declaration of conformity must be available for each package .

• The packaging manufacturer prepares and signs this declaration.

• Other parties must be able to request, verify, and retain it.

In practice, the biggest challenge often lies in the availability of data. The information is usually held by suppliers, while the responsibility ultimately lies with the manufacturer.