PPWR UPDATE: Stay up to date
Since 12 August 2026, the EU Packaging and Packaging Waste Regulation (PPWR) has been generally applicable across all Member States. For companies, one of the first steps is to identify the role they play in relation to each packaging item and who is responsible for demonstrating its compliance.
Who is considered the manufacturer?
The manufacturer is not always the company that physically produces the packaging.
As a general rule, a company that has packaging or a packaged product designed or manufactured and markets it under its own name or trademark may also be considered the manufacturer. The PPWR provides for specific rules in certain cases, such as for micro-enterprises, so each situation should be assessed individually.
Correctly identifying the manufacturer is essential because it is the manufacturer who bears legal responsibility for the conformity of the packaging.
What are the manufacturer’s obligations?
Its main responsibilities include:
- Assessing compliance with the sustainability requirements applicable to the packaging.
- Preparing the technical documentation.
- Drawing up the EU Declaration of Conformity.
- Ensuring packaging identification and traceability.
- Keeping the documentation for the required periods.
- Reviewing it whenever the design, materials or any other characteristics that could affect conformity change.
Suppliers of packaging and packaging materials must provide the necessary technical information. However, this cooperation does not automatically transfer the manufacturer’s legal responsibility.
Importers and distributors must also verify compliance with the obligations applicable to them before placing or making packaging available on the market.
Does each individual packaging item need to be identified?
Not necessarily. The PPWR allows packaging to be identified by means of a type, batch or serial number, or another equivalent element. Traceability can therefore be established by packaging model or production batch without individually marking every unit.
What to do now: check that each packaging item can be linked to its technical documentation and Declaration of Conformity.
Who must provide the packaging documentation?
Suppliers must provide the manufacturer with the information and technical documentation necessary to demonstrate conformity. However, legal responsibility for compliance remains with the company considered to be the manufacturer under the PPWR.
What to do now: review with suppliers what information will be provided, in which format and how it will be kept up to date.
Is conformity assessment carried out by component?
The conformity assessment and Declaration of Conformity must cover the complete packaging unit. In a system consisting of a tray, lidding film and label, for example, a single declaration for the complete packaging system is sufficient, but it must include relevant information on each component.
The conformity assessment must cover the packaging subject to the declaration, taking into account its different components and materials where appropriate. The technical documentation must contain the necessary information on these components to demonstrate the conformity of the packaging.