PPWR: a guide to the EU Packaging Regulation — requirements, responsibilities and deadlines

Oct 19

20 min read

Updated: Oct 28

Updated on 28 October 2026.

EU Packaging and Packaging Waste Regulation (EU) 2025/40: A Practical Guide for Businesses Accessing the European Market

Audience: packaging manufacturers, material suppliers, businesses selling products in the European market, exporters, importers, distributors, and professionals in Regulatory Affairs, Product Stewardship, Sustainability and Compliance.

Purpose: explain PPWR requirements, identify the obligations of different economic operators, outline the main regulatory milestones and answer practical questions about demonstrating compliance.

1. Introduction: what is the PPWR and why should your business understand it?

The European Union has established new rules for packaging and packaging waste, with phased application.

The Packaging and Packaging Waste Regulation (PPWR), formally Regulation (EU) 2025/40, establishes harmonised requirements for packaging and packaging waste marketed in the European Union.

Published on 22 January 2025, the Regulation entered into force on 11 February 2025 and became generally applicable on 12 August 2026, although individual obligations have specific implementation dates.

The PPWR progressively replaces the framework established by Directive 94/62/EC, introducing broader requirements for chemical composition, recyclability, recycled content, minimisation, reuse, labelling and packaging waste management.

Why does the change from a directive to a regulation matter?

A European directive normally needs to be transposed into the national legislation of the Member States. A regulation, by contrast, is directly applicable throughout the European Union.

This supports greater regulatory harmonisation and reduces differences between national requirements, although certain obligations and implementation arrangements still depend on local systems and authorities.

For businesses, the consequence is clear: packaging compliance requires a more structured, documented approach integrated across the supply chain.

Does the PPWR apply only to European businesses?

No. The Regulation applies to packaging placed on the European Union market, regardless of its origin.

Its requirements can therefore affect businesses based in Europe, the United States, Brazil, China, Japan, India or any other country participating in the supply chain for packaging and packaged products destined for the European market.

Two situations must be distinguished:

Application of product requirements: packaging destined for the European market must meet the relevant PPWR requirements.

Legal responsibility for compliance: specific obligations depend on the business's role in the supply chain under the Regulation's definitions.

A supplier outside the European Union may need to provide technical information to European customers even when it is not the economic operator legally responsible for drawing up the EU declaration of conformity.

2. What changes under the PPWR?

The PPWR addresses more than packaging waste. Its requirements need to be considered throughout the packaging life cycle, from raw material selection to post-consumer management.

Regulatory area	Main requirements	Business implications
Chemical substances	Restrictions and minimisation of substances of concern	Composition controls and supplier information
Recyclability	Harmonised design-for-recycling criteria	Assessment of materials and structures
Recycled content	Minimum post-consumer recycled plastic percentages	Raw material management and traceability
Minimisation	Reduction of packaging weight and volume	Review of design and efficiency
Reuse	Requirements for reusable packaging	Assessment of reuse systems
Labelling	Harmonised identification and information requirements	Review of packaging information and identification
Documentation	Conformity assessment and technical documentation	Implementation of documented processes
Responsibilities	Specific economic operator obligations	Allocation of contractual and regulatory responsibilities

A particularly relevant change is the need to demonstrate compliance with appropriate technical evidence.

A general statement that packaging complies with the PPWR may not demonstrate compliance with every applicable obligation. Businesses need to identify the requirements assessed, the supporting documents and the responsible economic operator.

3. PPWR timeline: what are the main deadlines?

Although the Regulation became generally applicable in August 2026, many requirements will be introduced gradually.

Date	Article	Requirement or regulatory milestone
11 February 2025	71	Entry into force
12 August 2026	71	General application begins
12 August 2026	5	Relevant substance restrictions apply, including heavy metals and PFAS in food-contact packaging
31 December 2026	5	Deadline for the Commission's report on substances of concern in packaging
31 December 2026	7(8)–(10)	Statutory deadline for recycled-content methodology, sustainability criteria and equivalence of third-country operations
12 February 2027	10(3)	Deadline to request harmonised minimisation standards; this is not the application date of the 2030 obligation
12 February 2028	8 and 9	Review of biobased feedstock and application of specific compostability provisions
1 January 2028	6	Deadline for adopting additional design-for-recycling criteria
12 August 2028 or later	12	Certain harmonised labelling requirements begin, subject to implementing acts
1 January 2030 or later	6	Recyclability criteria apply under the transitional rules
1 January 2030 or later	7	Minimum recycled-content targets for plastic packaging apply
1 January 2030	10	Weight and volume minimisation requirements
2030 or later	24	Maximum 50% empty space: 1 January 2030 or three years after the Article 24(2) acts enter into force, whichever is later
1 January 2030	29	Reuse targets, with their respective scopes and exceptions
1 January 2035 or later	6	Recycled-at-scale requirements
1 January 2038	6	Minimum recyclability performance increases to grade B
2040	7	Higher recycled-content targets

Some dates depend on the publication and entry into force of delegated or implementing acts. Where a requirement applies on a specified date or after a period following a complementary act's entry into force, whichever is later, businesses must include that condition in their compliance timetable.

These are the principal milestones, not an exhaustive inventory of every PPWR obligation.

4. Analysis of the main PPWR articles

Article 5 — Requirements for substances in packaging

General application: 12 August 2026.

Article 5 addresses substances of concern in packaging materials and components. It aims to minimise risks to human health and the environment, including impacts on reuse, recycling and final disposal.

Two provisions deserve particular attention.

4.1. Heavy metals — Article 5(4)

The sum of the concentrations of the following metals must not exceed 100 mg/kg, equivalent to 100 ppm by weight:

Lead (Pb).
Cadmium (Cd).
Mercury (Hg).
Hexavalent chromium (Cr VI).

The legal requirement is not to exceed 100 mg/kg; this should not be restated as a limit strictly below 100 mg/kg.

The limit applies to the sum of all four metals, rather than 100 mg/kg for each substance individually. It applies to packaging and packaging components, subject to the legally established derogations.

Practical example: packaging consisting of plastic film, a label and a closure needs to be assessed with regard to the relevant components. A declaration covering only the film does not necessarily demonstrate conformity of the label or other components.

This limit already existed under previous European packaging legislation and remains relevant within the PPWR's documentation and conformity assessment framework.

4.2. PFAS — Article 5(5)

The PPWR introduces specific restrictions on per- and polyfluoroalkyl substances (PFAS) in food-contact packaging.

Since 12 August 2026, Article 5(5) prohibits placing food-contact packaging on the market when it contains PFAS at concentrations equal to or above:

Criterion	Limit
Any PFAS measured by targeted analysis, excluding polymeric PFAS from quantification	25 ppb (25 µg/kg)
Sum of PFAS measured by targeted analysis, with prior degradation of precursors where applicable and excluding polymeric PFAS	250 ppb (250 µg/kg)
PFAS, including polymeric PFAS	50 ppm (50 mg/kg)

Where total fluorine exceeds 50 mg/kg, the provision also requires evidence, upon request, of the quantity attributable to PFAS or non-PFAS substances for the technical documentation. Total fluorine and PFAS concentration are not interchangeable concepts.

Commission Notice C/2026/3084 recommends a stepwise analytical approach for enforcement. This guidance does not change the legal limits. It also clarifies that packaging placed on the market before 12 August 2026 may remain available; the date of first placing on the market must be demonstrated, rather than manufacturing date alone.

The specific PFAS restriction in Article 5(5) does not apply indiscriminately to all packaging. Its scope concerns food-contact packaging.

Industrial, transport and protective packaging not intended for food contact are not automatically covered by this particular restriction. They may nevertheless be subject to other European chemical restrictions, including REACH and persistent organic pollutant legislation.

4.3. How can Article 5 compliance be demonstrated?

Businesses must maintain appropriate technical information. Depending on the material and risks, this may include:

Supplier regulatory declarations.
Raw material and composition information.
Technical specifications.
Chemical risk assessments.
Laboratory test results where necessary.
Change-control and traceability evidence.

A supplier declaration can be relevant evidence, but its sufficiency depends on the information's quality and the risks associated with the material. This is discussed further in the FAQ.

Article 6 — Recyclable packaging

Main milestones: 2030, 2035 and 2038, with conditional dates for certain provisions.

Article 6 introduces harmonised criteria for assessing packaging recyclability. Different methodologies and assessment systems could previously produce different results for the same packaging structure. The PPWR seeks more consistent criteria.

4.4. Design for recycling — 2030

The milestone is 1 January 2030 or 24 months after the delegated acts under Article 6(4) enter into force, whichever is later. The statutory deadline for adopting these acts is 1 January 2028.

The Commission is to establish detailed methodologies through complementary legislation. Packaging will be classified by recyclability performance.

Grade	Recyclability performance
A	At least 95%
B	At least 80% and below 95%
C	At least 70% and below 80%
Below C	Below 70%

These percentages are not actual recycling rates. They describe performance under the PPWR assessment methodology, whose application depends on the complementary technical criteria.

Grades A, B and C will be permitted from the conditional application date above. Paragraphs 10 and 11 contain exceptions and specific rules that must be assessed by category.

From 2038, the minimum grade becomes B.

4.5. Recycled at scale — 2035

Beyond suitable technical characteristics, packaging must meet requirements concerning its effective collection, sorting and recycling at scale.

Collection and sorting under Article 6(2)(b) have a milestone of 1 January 2035. The recycled-at-scale requirement applies from 1 January 2035 or five years after the implementing acts under Article 6(5) enter into force, whichever is later. The statutory adoption deadline for these acts is 1 January 2030.

Technically recyclable packaging does not necessarily meet all recycled-at-scale requirements.

4.6. What should businesses do now?

Businesses can start preparatory work while following the complementary regulatory criteria:

Identify materials and components.
Map multi-material structures.
Assess the availability of composition information.
Identify relevant recycling technologies.
Monitor harmonised criteria.
Plan adaptations for potentially critical packaging.

The absence of a definitive recyclability grade today does not, by itself, mean packaging fails requirements currently applicable.

Assessments must consider provisions already applicable and the transitional rules. The general recyclability obligation in Article 6(1) must be distinguished from future harmonised grades; previous essential requirements retained by Article 70 also need consideration.

This distinction matters for protective packaging, foams and other structures whose future methodologies may require further technical clarification.

Article 7 — Minimum recycled content in plastic packaging

Application: 1 January 2030 or three years after the relevant implementing act enters into force, whichever is later.

Article 7 establishes minimum recycled content recovered from post-consumer plastic waste. Targets differ by packaging category and application.

Category	Minimum recycled content for 2030
Contact-sensitive packaging predominantly made from PET, excluding single-use plastic beverage bottles	30%
Contact-sensitive packaging made from other plastic materials, excluding single-use plastic beverage bottles	10%
Single-use plastic beverage bottles	30%
Other plastic packaging	35%

For 2040, the percentages for these four categories are, respectively, 50%, 25%, 65% and 65%.

These targets are subject to the Regulation's exceptions, conditions and methodologies and complementary acts. Paragraphs 4 and 5 cover, among other cases, certain medicinal-product and medical-device packaging, compostable packaging, dangerous-goods transport packaging and plastic parts representing less than 5% of the total packaging unit weight. These are specific conditions, not blanket sector exemptions.

How will recycled content be calculated?

The percentage is calculated as an average per manufacturing plant and year, for the relevant packaging types and formats. Calculation, documentation, traceability and proof of the recycled material's origin therefore require attention.

Is biobased material equivalent to post-consumer recycled content?

No. Biobased feedstock and post-consumer recycled materials have different origins and characteristics. Renewable feedstock does not automatically meet Article 7 recycled-content targets.

Mass-balance claims must likewise be assessed against the applicable calculation and verification rules.

What preparations can begin?

Identify packaging subject to the targets, applicable exceptions, current recycled content, suppliers' capacity to provide suitable post-consumer recycled material, and the information needed for traceability and verification.

Article 8 — Biobased feedstock in plastic packaging

The Commission must carry out the Article 8 review by 12 February 2028. It concerns technological development and environmental performance and may be followed by legislative proposals.

Article 8 does not itself establish a general minimum biobased-content percentage for all packaging.

Businesses using renewable feedstock should follow regulatory developments and avoid automatically treating it as equivalent to the post-consumer recycled content required under Article 7.

Article 9 — Compostable packaging

Article 9 sets specific requirements for certain compostable packaging categories.

The milestone is 12 February 2028, particularly for packaging under Article 3(1)(1)(f), such as permeable tea/coffee bags under the Regulation's conditions, and sticky labels on fruit and vegetables. These must be compatible with industrial composting and, where required by a Member State, home composting.

Other categories can depend on national options and collection/treatment infrastructure. Article 9(3) addresses material-recycling design for other packaging.

There is no general obligation for all packaging sold in the European Union to be compostable. Businesses using biodegradable or compostable materials must assess the category, relevant standards and specific performance requirements.

Article 10 — Packaging minimisation

Main application: 1 January 2030.

Packaging must be designed to minimise weight and volume while maintaining functionality, considering:

Product protection.
Safety.
Transport and distribution.
Storage.
Hygiene.
Legal requirements.
Material and packaged-product characteristics.

Does minimisation simply mean using less material?

Not necessarily. The aim is to avoid unnecessary material while preserving essential functions. Excessive reduction may increase damage, losses, returns and reshipments.

Assessment should therefore consider the packaging's function within the complete distribution system.

Practical example: protective packaging may need a certain volume of cushioning to transport electronic equipment without damage. The assessment should establish whether that volume is technically necessary or equivalent protection can be achieved with less material.

Decisions should rest on technical criteria rather than visual perceptions of excessive packaging.

Article 11 — Reusable packaging

Article 11 establishes criteria for classifying packaging placed on the market from 11 February 2025 as reusable. This express reference must be distinguished from the Regulation's general application on 12 August 2026.

The deadline for delegated acts on minimum rotations is 12 February 2027, under Article 11(2).

Occasional reuse differs from a formal reuse system. Using packaging a second time does not automatically make it reusable under the PPWR.

Classification depends on design, conditions of use and other regulatory criteria. Businesses should assess both packaging characteristics and the complementary obligations applicable to their reuse systems.

Article 12 — Packaging labelling and information

Harmonised labelling will be introduced progressively. Article 12(1) provides for material-composition labels from 12 August 2028 or 24 months after the relevant implementing acts enter into force, whichever is later.

Exceptions include non-e-commerce transport packaging and packaging subject to a deposit and return system.

For reusable-packaging identification, Article 12(2) sets 12 February 2029 or 30 months after the Article 12(6) act enters into force, whichever is later, with additional digital information under the prescribed conditions.

Paragraphs 6 and 7 specify 12 August 2026 as the adoption deadline for certain acts. A deadline addressed to the Commission does not itself establish that an act has been published or that labelling obligations already apply. The operational date must be calculated from the relevant act actually in force. This guide does not assign a definitive date to labels where the applicable act has not been individually confirmed.

Article 12(12) also permits certain packaging manufactured in the Union or imported before the deadlines to be made available during its specified transition period. Category, date and records must be checked; this is not a general labelling exemption.

Article 14 — Environmental claims

Claims about regulated packaging properties must satisfy Article 14: refer to performance exceeding applicable minimum requirements and identify whether they concern a packaging unit, part of it or all packaging placed on the market by the operator.

The supporting demonstration belongs in the technical documentation. A broad “sustainable” claim does not replace assessment of the specific requirement.

Articles 15 to 21 — Who is responsible for each obligation?

Manufacturer — Article 15. Must ensure conformity with applicable Articles 5 to 12 requirements, carry out or commission conformity assessment, prepare technical documentation and draw up the EU declaration of conformity. Must maintain conforming production processes, identification and traceability, manage changes and take corrective action where necessary.

“Manufacturer” is a legal role defined in Article 3, not necessarily the factory processing the raw material. It can include a person having packaging or packaged products manufactured under its name or trademark, with specific rules for certain packaging and micro-enterprises. A non-EU business may also fulfil this role; location does not automatically remove its obligations.

For generic, standardised, unbranded transport packaging, the manufacturer will normally be the business physically manufacturing the packaging and placing it on the market in that form. A box may already be in its final form when supplied flat; stretch film may already be packaging when sold on a roll and cut later. Merely using these items or adding a logistics label does not automatically make the user the manufacturer.

Where a business commissions bespoke packaging and determines its specifications, it may be the manufacturer for PPWR purposes even without printed branding. The contractual relationship and who decides the packaging's characteristics must be assessed, taking account of the specific rules for microenterprises.

Supplier of packaging or packaging materials — Article 16. Must provide the manufacturer with the information and documents necessary to demonstrate conformity, including relevant Annex VII documentation required under Articles 5 to 11. Information must be in a language easily understood by the manufacturer and supplied electronically or on paper. Where relevant, documents required under contact-sensitive packaging legislation form part of this information transfer.

Authorised representative — Article 17. Acts under a written mandate. Appointment does not automatically transfer all manufacturer obligations; the scope must respect the Article's limitations.

The manufacturer's authorised representative under Article 17 and the EPR authorised representative under Article 45(3) perform different functions. Appointing one does not automatically fulfil the obligations relating to the other. Cross-border sales require assessment of the producer's establishment, destination country and supply arrangement.

The Commission proposed suspending certain EPR representation requirements in proposal COM(2025) 982. Its small-business page recommends constructive and pragmatic enforcement while the proposal is examined. This does not amount to a legally applicable suspension. Measures aimed at producers established in the Union must not be presumed to cover exporters from third countries; any subsequently adopted text must be checked.

Importer — Article 18. Before placing packaging on the market, must verify the manufacturer's assessment, technical documentation, applicable labelling, required documents and identification. Packaging considered or suspected to be non-conforming must not be placed on the market. Importers also have identification, retention and authority-cooperation obligations.

Distributor — Article 19. Must exercise due care, check relevant requirements before making packaging available and preserve conformity during storage and transport. Must act upon identifying or suspecting non-conformity.

Fulfilment service provider — Article 20. Must ensure that storage, handling, packaging and dispatch conditions do not compromise applicable requirements.

Importer or distributor assuming manufacturer responsibilities — Article 21. Placing packaging under its own name or trademark, or modifying it in a way that may affect conformity, can trigger manufacturer obligations.

Contracts can organise data delivery, testing and change control. They do not displace responsibilities assigned by law.

Articles 24 and 25 — Excessive packaging and restricted formats

Article 24(1) limits the empty-space ratio to 50% for grouped, transport and e-commerce packaging within its scope, from 1 January 2030 or three years after the paragraph 2 acts enter into force, whichever is later.

The statutory methodology deadline is 12 February 2028. Filling materials are covered by the empty-space rules: filling a box with protective material does not automatically reduce legally calculated empty space.

Article 24 contains further obligations, including for sales packaging, to be assessed by operator role and packaging type. Product protection must be documented without assuming an automatic exemption from the limit.

Article 25 and Annex V restrict specific formats and uses from 1 January 2030, subject to their own conditions and exceptions. Classification requires identifying format, material and use; it is not a general ban on all plastic packaging.

Articles 26 to 31 — Reuse, systems and targets

Articles 26 and 27 address reusable packaging and reuse systems together with Annex VI. Article 28 addresses refill obligations.

Article 29 establishes different targets by format and activity. Transport formats covered by paragraph 1 have a 40% target for reusable packaging within a reuse system from 1 January 2030, subject to legal exceptions.

Paragraphs 2 and 3 require full reuse in specific flows between establishments/linked businesses and within the same Member State. These rules must not be applied indiscriminately to all transport or export operations.

An adopted update: Delegated Decision (EU) 2026/429 exempts operators using pallet wrappings and straps to stabilise and protect palletised products from the paragraphs 2 and 3 targets of 100%, for those formats.

It does not establish a general exclusion from Article 29 or itself remove paragraph 1's aggregate 40% target.

Articles 30 and 31 address calculation and reporting. Targets for 2040 described as an endeavour must be distinguished from binding minimum obligations. Plans should record the specific provision applicable to each format.

Article 29 sets reuse targets with a milestone of 1 January 2030. For the obligation to demonstrate achievement, Article 30(4) specifies 1 January 2030 or 18 months after the calculation implementing act under Article 30(3) enters into force, whichever is later. The statutory deadline to adopt this methodology is 30 June 2027. This demonstration deadline is not a general postponement of all reuse obligations.

Articles 38 and 39 — Conformity assessment and EU declaration of conformity

The procedure follows Module A: internal production control, in Annex VII. Manufacturers can perform the assessment or engage technical support while retaining responsibility.

The EU declaration follows Annex VIII, identifies the packaging/type and manufacturer, and declares conformity with applicable requirements under the manufacturer's responsibility. It must be kept updated and drawn up or translated into the languages required by the Member State where packaging is placed or made available on the market.

This does not create a universal requirement for third-party certification of all packaging. Equally, conformity cannot be declared without technical evidence.

For a packaging unit comprising, for example, a bottle, closure and label, one assessment and one EU declaration of conformity may cover the whole unit, provided they include the relevant information for all components. This does not remove the information suppliers must transmit.

Within one shipment, the pallet, box, film and straps may constitute distinct packaging requiring their own assessments and declarations. Components of one unit must not be confused with all packaging in a load.

Identification may refer to a type, model or batch if it links the packaging to its documentation and declaration. There is no general requirement to serialise every component individually.

Articles 44 and 45 — Registration and extended producer responsibility

The producer for extended producer responsibility (EPR) must be identified for each Member State, considering the packaging type and supply transaction. This role does not automatically correspond to the manufacturer responsible for the EU declaration of conformity.

There is no general EPR exemption for microenterprises. For producers making less than 10 tonnes of packaging available per year in a Member State, Article 44(8) provides for simplified reporting information. This threshold concerns the quantity of packaging on the national market concerned, not product weight, turnover or, by itself, microenterprise status. Administrative arrangements and proportionate fees depend on the national scheme.

These simplifications are not a general exemption from registration, EPR contributions or packaging conformity. Specific rules may assign the producer role to the supplier where the manufacturer is a microenterprise and the supplier is established in the same Member State: this identifies the responsible operator rather than removing supply-chain obligations.

Existing national rules continue to apply during the transition. Article 44(1) provides 18 months from the entry into force of the first implementing act under Article 44(14) to establish national registers. This register-adaptation period is not a general grace period for businesses; operational deadlines must be checked country by country.

An EU declaration of conformity does not replace registration or EPR obligations. Administrative EPR simplifications do not automatically waive the technical documentation required under Articles 15 and 18.

Articles 70 and 71 — Transition and application

Directive 94/62/EC was generally repealed on 12 August 2026, but Article 70 expressly retains certain provisions for specified periods.

Article 71 establishes entry into force and general application; other Articles establish specific milestones.

Commission Notice C/2026/3084 is interpretative guidance. It is not a delegated act amending the Regulation and does not replace legal requirements.

5. Documentation: how to assemble useful evidence

Annex VII technical documentation must allow conformity assessment and include adequate analysis of non-conformity risks. As applicable, it must include description and intended use, drawings and component materials, technical explanations, standards and specifications used, adopted solutions, relevant qualitative assessments and test reports.

A practical recommendation is to maintain a dossier for each packaging type covering:

Identification, revision and composition of every component, including relevant inks, adhesives, coatings and closures.
A matrix of applicable Articles, dates and the basis for any exceptions.
Supplier declarations and data linked to the materials and versions actually used.
Technical assessment, relevant test results and justification of the evidence adopted.
The EU declaration, identification of the responsible operator and change control.

Article 15(3) requires retaining technical documentation and the declaration for five years for single-use packaging and ten years for reusable packaging, from placing on the market.

A declaration that PFAS have not been intentionally added does not, by itself, demonstrate compliance with Article 5(5) limits: the restriction also covers unintentional presence. Assessment must consider the packaging unit and relevant auxiliary materials, including inks, varnishes, glues and adhesives.

The manufacturer and importer must retain the required technical documentation. It is insufficient for only the supplier to keep drawings and composition data and promise to make them available to authorities. Information sharing may protect commercially sensitive information but must enable compliance with documentation obligations.

As technical references, the official August 2026 FAQ recommends CEN CR 13695-1:2000 to demonstrate compliance with the metals limit and allows EN 13428:2004 to guide minimisation of substances of concern pending the updated standard. Its Annex C does not automatically confer a presumption of conformity with the PPWR's new substances scope. These references are neither universally mandatory certificates nor a general requirement to test every batch.

6. What information should be passed to customers?

When answering requests about Article 5, recyclability or material type, specify what was assessed, the product/component covered and the evidence used.

Distinguish current legal requirements from preparatory information for future requirements.

A technically useful response identifies:

Packaging or material code and revision, intended use and possible food contact.
Assessed requirement and limit, including the component scope.
Evidence type, date, test method and quantification limits where relevant.
Available composition, recyclability and recycled-content data.
Use restrictions, gaps, conditions and change control.

The supplier's legal duty is in Article 16. This list is a practical organisational recommendation, not a mandatory uniform legal form. Trade secrets should be managed through appropriate information-sharing arrangements without preventing compliance with documentation duties.

7. Frequently asked questions

Must I test every material, or is a supplier declaration sufficient?

The PPWR establishes neither a universal exemption from testing based on supplier declarations nor a uniform requirement to test every batch of all packaging.

Annex VII requires analysis of non-conformity risks and includes test reports among relevant documentation elements. Decisions should consider material, composition, use, legal limits, the quality and representativeness of available data, processes and changes.

A specific, traceable declaration supported by data can form part of the dossier. A general “PPWR compliant” statement does not itself demonstrate every requirement.

Where evidence is insufficient — for example, a method cannot verify the applicable limit, component information is missing or contamination is a concern — obtain additional information and perform relevant tests. The manufacturer must document the sufficiency of the overall evidence.

Must the supplier issue the EU declaration of conformity?

When acting solely as a supplier, its central Article 16 obligation is to provide information and documentation to the manufacturer. If it also qualifies legally as the manufacturer, the corresponding manufacturer duties apply.

The actual role in the operation, rather than the business's commercial designation, determines the answer.

Who signs and assumes responsibility for the declaration?

The manufacturer assumes responsibility. An authorised representative may perform tasks covered by an Article 17 mandate. Outsourcing analysis or document preparation does not remove the manufacturer's responsibility.

Can a business outside the European Union be the manufacturer?

Yes, depending on its legal role. The importer and other EU operators must also be identified, together with specific EPR obligations. Do not assume that an importer always issues the declaration instead of a foreign manufacturer.

Do PFAS restrictions apply to all packaging?

The specific Article 5(5) restriction concerns food-contact packaging. The obligation to minimise substances of concern, metal limits and other chemical legislation may apply beyond that scope.

Can I describe packaging as “PFAS-free”?

Compliance with concentration limits does not prove absolute absence. Claims must match the scope, methods and quantification limits of the evidence. Article 5(5) restrictions and claims requirements must be assessed separately.

Must I provide a recyclability grade A, B or C today?

Regulatory grades depend on the methodologies and application dates in Article 6. Customers may request composition and performance information ahead of those dates; identify such requests accordingly.

An existing voluntary grade must not automatically be treated as equivalent to the future legal grade.

Does a PPWR declaration replace food-contact documentation?

No. Relevant obligations under Regulation (EC) 1935/2004 and specific measures, such as Regulation (EU) 10/2011 for plastics within its scope, must still be assessed.

Documents may form an organised dossier, but a general declaration does not automatically replace each act's requirements.

Does a raw-material change require reassessment?

Article 15(4) requires consideration of changes in design, characteristics and specifications. If conformity may be affected, the manufacturer must perform or commission reassessment and keep documents updated.

Can one declaration cover packaging in different sizes?

Yes, where the differences do not affect conformity with applicable requirements and the covered scope is identified. Different products or structures must not be grouped indiscriminately under a generic declaration.

8. Next steps for businesses

Map packaging destined for the European Union; determine operator roles; check requirements already applicable first; organise supplier evidence and gaps; and establish projects for future obligations.

Maintain a calendar distinguishing three situations: currently applicable obligations, future obligations with express dates, and obligations whose dates depend on complementary acts.

Keep the Commission's deadline to adopt an act separate from the date businesses must comply.

9. Official regulatory references

The Regulation and applicable complementary acts are binding. Notices and FAQs guide interpretation; legislative proposals do not change obligations before adoption and application.

For questions about the PPWR, please contact Working Heroes.