01 / SCOPE AND RESPONSIBILITIES
Who Must Comply With PPWR?
PPWR is not limited to companies that manufacture empty packaging. Businesses selling cosmetics, household products, food, electronics and other packaged goods in the EU may also have obligations.
The first step is to establish the company's role for the packaging concerned. A business may have different responsibilities for different packaging types or sales arrangements.
Manufacturer, importer, distributor and supplier
- Manufacturer
- A company that manufactures packaging or packaged products, or has them designed or manufactured under its own name or trademark, subject to the definitions and exceptions in PPWR. For sales packaging, the manufacturer is often the product filler or brand owner rather than the supplier of the empty container.
- Importer
- A business established in the EU that places packaging from a third country on the Union market. Importers have specific verification, traceability and cooperation obligations.
- Distributor
- A business in the supply chain, other than the manufacturer or importer, that makes packaging available on the market. Distributors must carry out the checks required for their role and respond to identified compliance problems.
- Packaging supplier
- A supplier of packaging or packaging materials must provide the manufacturer with the information and documentation needed to demonstrate compliance with the applicable PPWR requirements.
Does the packaging supplier take responsibility for PPWR compliance?
Not automatically. Purchasing packaging from an established supplier does not, by itself, transfer the manufacturer's obligations to that supplier.
Under Article 16, suppliers must provide necessary information and documentation. The company identified as the manufacturer remains responsible for the conformity assessment and EU Declaration of Conformity. Article 15 also includes a specific manufacturer rule for qualifying micro-enterprises, so responsibilities should be checked rather than assumed.
It is also important to distinguish a manufacturer, responsible for packaging conformity, from a producer for EPR purposes. These terms describe different regulatory responsibilities and do not always refer to the same company.
Regulatory references: Articles 3 and 15–19; Commission Guidance C/2026/3084.
02 / IMPLEMENTATION
PPWR Requirements and Key Deadlines
PPWR entered into force on 11 February 2025 and generally applies from 12 August 2026. This does not mean that all packaging design, labelling and recycled-content requirements became mandatory on the same date.
The table below highlights important milestones for businesses preparing packaging compliance documentation.
Some dates are conditional. For example, the initial recyclability requirement applies from 1 January 2030 or 24 months after the relevant delegated acts enter into force, whichever is later. The recycled-content requirement has its own later-date mechanism. Individual provisions and exceptions must be checked before making a compliance decision.
Regulatory references: Articles 6, 7, 10 and 12; Annex II.
03 / ARTICLE 6
Packaging Recyclability Requirements
Article 6 requires packaging placed on the EU market to be recyclable. The Regulation introduces design-for-recycling assessments and, at a later stage, assessment of whether packaging is recycled at scale.
Recyclability cannot be determined solely from the main material. The assessment may also need to consider labels, closures, pumps, adhesives, coatings, barriers and other parts of the packaging.
Recyclability performance grades
PPWR Annex II establishes three recyclability performance grades, based on a weighted assessment:
These grades do not mean that a company can certify its packaging simply by calculating the percentage of one recyclable material. The assessment must follow the applicable design-for-recycling criteria, methodologies and packaging categories established under the Regulation.
How should packaging components be assessed?
Article 6 distinguishes between integrated and separate packaging components. Depending on the packaging design, components may need to be included in the assessment of the complete unit or assessed separately.
For example, a bottle, dispensing pump, label and removable carton should not automatically be treated as one homogeneous material. Their construction and behaviour during collection, sorting and recycling may differ.
Example: Cosmetic bottle with a pump
A cosmetic product is supplied in a plastic bottle with a pump, adhesive label and outer carton.
The bottle may be made from a widely recycled polymer, but the pump may contain several materials. The label and adhesive may affect sorting or recycling, while the outer carton is a separate packaging item.
A proper review identifies the relevant packaging units, checks the available material and construction data, and establishes what further evidence is needed. The packaging should not be declared compliant or non-compliant solely because the bottle is made from PET or HDPE.
What can businesses assess before the detailed criteria apply?
Companies can already collect material and component specifications, examine packaging construction, request recycling-related evidence and identify designs likely to require further assessment.
However, a preliminary review is not the same as a final PPWR recyclability grade determined under the applicable delegated and implementing acts.
Regulatory references: Article 6; Annex II, Tables 1, 3 and 4.
04 / ARTICLE 7
Minimum Recycled Content in Plastic Packaging
Article 7 introduces minimum percentages of post-consumer recycled plastic for specified packaging categories. The requirements distinguish contact-sensitive packaging from other plastic packaging, with different targets for PET and non-PET materials.
The initial targets apply from 1 January 2030 or three years after the relevant implementing act enters into force, whichever is later. Higher targets are established for 2040.
The percentages are calculated as an average per packaging type and format, per manufacturing plant and year, in accordance with Article 7. They are not automatically minimum percentages for every individual packaging unit. Specific exemptions and calculation rules apply.
What about cosmetic packaging?
Packaging for cosmetic products falls within the PPWR definition of contact-sensitive packaging under Article 3(1)(49), which refers to Regulation (EC) No 1223/2009. For plastic packaging, the recycled-content targets under Article 7 depend on the material, packaging category and applicable exemptions.
For a cosmetic bottle, a company should establish whether the packaging falls within the contact-sensitive category before applying the recycled-content percentages. Material suitability, product compatibility and obligations under cosmetics legislation must also be considered.
For imported packaging, recycled-content evidence may require particular attention to material origin, collection and recycling conditions, calculation methods and the documentation supplied by the manufacturer.
Regulatory references: Article 7; Annex II.
05 / ARTICLES 5, 9–12
Other Important PPWR Requirements
Packaging minimisation - Article 10
From 1 January 2030, manufacturers or importers must ensure that packaging weight and volume are reduced to the minimum necessary to maintain its functionality, taking account of the material and packaging design.
The assessment must consider the performance criteria in Annex IV. Packaging should not include unnecessary layers or design features whose purpose is merely to increase the perceived volume of the product, subject to the exceptions provided by the Regulation.
This does not mean reducing packaging at the expense of product safety, hygiene, protection during transport or other necessary functions. The reasons why further reduction is not possible must be supported in the technical documentation.
Packaging labelling - Article 12
PPWR establishes harmonised labelling requirements to help consumers identify packaging materials and sort packaging waste. The main material-composition labelling requirement applies from 12 August 2028 or 24 months after the relevant implementing acts enter into force, whichever is later.
Businesses should not assume that an existing national recycling symbol or material identification code will automatically satisfy the future harmonised rules. The final label must follow the applicable EU specifications and any relevant transitional provisions.
Requirements for reusable packaging and certain voluntary recycled-content labels have additional provisions and dates. A QR code is not a universal requirement for every packaging item.
Environmental claims
Statements such as "recyclable", "made from recycled plastic" or "environmentally friendly" need to be considered carefully. The supporting evidence must match the specific statement, packaging configuration and market.
PPWR includes provisions affecting certain packaging claims, but other EU consumer-protection and environmental marketing rules may also apply. A general supplier declaration or recycling symbol is not necessarily sufficient evidence for a broad environmental claim.
Substances in packaging - Article 5
Article 5 addresses substances of concern and includes restrictions on certain substances in packaging. Its specific PFAS concentration limits from 12 August 2026 concern food-contact packaging; they should not be described as a general PPWR prohibition on PFAS in all cosmetic packaging.
Other applicable EU chemical and product-specific legislation must still be considered where relevant.
Compostable and reusable packaging
Articles 9 and 11 establish requirements concerning compostable and reusable packaging. These are not general obligations requiring every company to replace single-use packaging with compostable material.
Additional reuse targets, restrictions on certain packaging formats and requirements for particular business activities appear elsewhere in PPWR. Their applicability depends on the packaging type, sector and use.
Regulatory references: Articles 5, 9–12, 24, 25 and 29; Annex IV and Annex V.
06 / CONFORMITY ASSESSMENT
PPWR Technical Documentation and EU Declaration of Conformity
Technical documentation is a central part of demonstrating packaging conformity under PPWR. Article 15 requires manufacturers to carry out the applicable conformity assessment procedure, or have it carried out on their behalf, and prepare the technical documentation described in Annex VII before placing packaging on the market.
Where compliance with the applicable requirements has been demonstrated through the prescribed procedure, the manufacturer must draw up an EU Declaration of Conformity in accordance with Article 39 and Annex VIII.
What should the technical documentation contain?
Annex VII establishes the conformity assessment procedure based on internal production control. The technical documentation must identify the applicable requirements and allow the packaging's conformity to be assessed, including an analysis and assessment of risks of non-conformity.
Depending on the packaging and requirements being assessed, the documentation may include:
- A general description of the packaging and its intended use.
- Packaging design, drawings and material composition.
- Details of components, closures, labels and other relevant elements.
- Applied harmonised standards, common specifications or other technical specifications.
- Descriptions of the methods used to demonstrate compliance where relevant standards are not applied.
- Assessments relating to recyclability, packaging minimisation and reusability, as applicable.
- Relevant test reports and other evidence supporting conformity.
Not every packaging type requires the same supporting information. The content must reflect the actual packaging, the applicable provisions and the assessment carried out.
EU Declaration of Conformity
The EU Declaration of Conformity must follow the structure in Annex VIII and identify the packaging to which it relates. Under Article 39, the manufacturer assumes responsibility for packaging conformity by drawing up the declaration.
Having a technical file prepared or reviewed by an external consultant does not transfer that legal responsibility to the consultant. A Declaration of Conformity should not be issued merely because a supplier has provided a generic statement of compliance.
How long must records be retained?
Under Article 15(3), manufacturers must retain the technical documentation and EU Declaration of Conformity for:
- Five years from the date single-use packaging was placed on the market.
- Ten years from the date reusable packaging was placed on the market.
Companies should also have a process for updating documentation when packaging materials, suppliers, designs or other compliance-relevant information change.
Articles 15(5) and 15(6) also require packaging identification, such as a type, batch or serial number, and manufacturer contact information. The Regulation specifies how this information must be provided, including alternatives where the size or nature of the packaging does not allow direct marking.
Regulatory references: Articles 15, 16, 38 and 39; Annexes VII and VIII.
07 / DOCUMENTATION FROM SUPPLIERS
What Packaging Documents Should You Request From Suppliers?
A common problem for purchasing and quality departments is receiving a collection of supplier documents without knowing whether they are sufficient for the applicable regulatory requirements.
A general statement that packaging is "EU compliant" does not necessarily explain which requirements have been checked, which packaging configuration was assessed or what evidence supports the declaration.
Documents that may be relevant
- Packaging specifications, including material types and composition.
- Component dimensions, weights and technical drawings.
- Supplier declarations and conformity-related statements.
- Available test reports and assessment results.
- Information about labels, adhesives, coatings and barriers.
- Supporting recyclability evidence and material-separation information.
- Recycled-content data and supporting records, where applicable.
- Information relevant to restricted substances or product-contact requirements.
- Packaging identification and traceability information.
The appropriate document list depends on the packaging material, its intended use, the supplier's role and the regulatory requirements being assessed.
What should you check when reviewing supplier documents?
Check that the documents refer to the actual packaging being purchased, not just a general material family. The information should be consistent across specifications, declarations, drawings and test reports.
Where documentation is incomplete, the next step is to identify precisely what is missing and request the relevant information from the supplier.
Having a document on file is not enough. It should provide evidence relevant to the requirement being checked.
Example: Missing documentation for an imported container
A company imports finished cosmetic containers and receives a material specification and a short compliance declaration from the supplier.
Those documents may be useful, but they may not establish the full packaging composition, component weights, relevant assessments or evidence required for the applicable PPWR provisions.
A documentation review can identify inconsistencies and missing records. A more detailed compliance gap assessment can compare the available evidence with specific regulatory requirements.
Regulatory references: Articles 15 and 16; Annex VII.
08 / OTHER PACKAGING OBLIGATIONS
Packaging EPR and Regulations Outside the EU
Extended Producer Responsibility in the EU
Extended Producer Responsibility (EPR) concerns obligations relating to packaging waste, including registration, reporting and the financing of waste management.
A company selling packaged products in several EU countries may have EPR obligations in more than one market. The responsible party depends on the applicable definitions, the countries concerned and how the products are supplied.
PPWR introduces common provisions, but EPR compliance also requires checking the relevant national systems, registration procedures, reporting categories and fee arrangements.
PPWR conformity documentation and EPR reporting are not the same task. A company may need both a technical file demonstrating packaging conformity and separate packaging data for EPR reporting.
United Kingdom
The United Kingdom has its own packaging regulatory framework, including Extended Producer Responsibility for packaging. Depending on the business and its activities, obligations may include collecting packaging data, reporting, registration and related payments.
EU PPWR conformity should not be treated as automatic compliance with UK packaging requirements.
United States
The United States does not have a single nationwide equivalent of EU PPWR. Packaging requirements vary by jurisdiction, and several states have enacted packaging EPR legislation.
Businesses supplying packaged products to the US should assess the applicable state requirements, packaging categories, producer definitions and implementation schedules rather than assuming that one assessment covers the entire country.
09 / PRACTICAL QUESTIONS
Frequently Asked Questions About PPWR
Does PPWR apply to imported packaging?
Yes. Packaging imported into the EU can fall within PPWR. The relevant obligations depend on the packaging and the roles of the economic operators involved.
Does a company selling finished products need packaging documentation?
Potentially, yes. A business selling finished packaged products may be considered the manufacturer for PPWR purposes, depending on the circumstances. It is important to establish who is responsible for conformity and which records are needed.
Is an EU Declaration of Conformity required for packaging?
Yes. Manufacturers generally must assess packaging conformity and prepare technical documentation before placing packaging on the market. Once conformity has been demonstrated, they must draw up an EU Declaration of Conformity.
Can supplier declarations be used as part of the technical file?
Yes. Supplier declarations and supporting documents can provide important evidence. However, they should be checked for relevance, completeness and consistency with the packaging being assessed.
Is all packaging required to be recyclable by 2030?
Article 6 establishes design-for-recycling requirements from 2030 or a later date linked to the relevant delegated acts. The Regulation also provides specific exemptions and transitional arrangements. The detailed criteria applicable to a packaging category must be checked.
Does every plastic package need the same percentage of recycled content?
No. Article 7 distinguishes between packaging categories and establishes different targets, calculation rules and exemptions. The required percentages are not applied as a uniform minimum to every individual packaging unit.
Does PPWR require every packaging item to have a QR code?
No. PPWR contains specific digital information and labelling provisions, but it does not impose a universal QR-code requirement on every packaging item.
What about packaging manufactured before 12 August 2026?
The manufacturing date alone does not determine which PPWR requirements apply. Packaging lawfully placed on the EU market before 12 August 2026 may generally continue to be made available without retroactively meeting the new requirements applicable from that date. Packaging merely held in a manufacturer's warehouse may not yet have been placed on the market. Specific transitional rules also apply to certain requirements.
Does PPWR require CE marking on packaging?
No. PPWR requires an EU Declaration of Conformity, but does not introduce CE marking as proof of packaging compliance. A CE mark appearing on packaging may relate to the packaged product under separate EU legislation.
Does PPWR compliance replace EPR registration?
No. Packaging conformity requirements and Extended Producer Responsibility are separate obligations. A company may need to address both, depending on its activities and the markets concerned.
10 / REGULATORY REFERENCES
Official PPWR Sources
The following official EU resources should be consulted when assessing specific packaging obligations, application dates or changes to implementation measures.
This page provides general regulatory information and does not replace an assessment of a specific packaging configuration. Applicability, exemptions and deadlines should be confirmed against the current legislation and relevant implementing measures. European Commission guidance and FAQs assist interpretation but do not amend the legal obligations established by the Regulation.