PPWR: A Practical Guide for Procurement and Compliance

The starting point for the assessment is the definition of “packaging” under the PPWR. Among other things, an item is considered packaging if it is intended to contain, protect, handle, deliver or present a product and is not an integral part of the product. Based on this definition, our assessment can generally be described as follows: The glue can be transferred into another container. The can is therefore not an integral part of the product and would be considered packaging. In the case of spray adhesive, however, the spray mechanism is required for the intended use of the product and cannot readily be separated from the product. It would therefore generally be considered an integral part of the product rather than packaging. Further examples can be found in Annex I of the PPWR. The examples listed there are helpful for this assessment. For instance, “glass bottles for injection solutions” are listed as packaging, whereas “cartridges for printers” are explicitly listed as non-packaging.

The supplier’s European entity does not automatically place the goods on the EU market. If the goods are supplied directly from the USA to you and the US entity is the contracting and invoicing party, your company may be considered the importer, provided that no other EU-based economic operator assumes this role. As the supplier is established in a third country, your company would generally assume the importer obligations. These include verifying that the required conformity assessment has been carried out and that the technical documentation is in place. You must also ensure that the manufacturer’s required information is provided on the product or packaging and that your own name and contact details are indicated, where required, on the product, packaging, or an accompanying document. Here are the relevant definitions (Article 3): (17) ‘importer’ means any natural or legal person established within the Union that places packaging from a third country on the market; (10) ‘placing on the market’ means the first making available of packaging, whether empty or with a product, on the Union market; (9) ‘making available on the market’ means any supply of packaging, whether empty or with a product, for distribution, consumption or use on the Union market in the course of a commercial activity, whether in return for payment or free of charge;

Under Article 3(1) No. 13 PPWR, a manufacturer is every natural and legal person who manufactures a unit of packaging or a packaged product itself, or has it designed or manufactured under its own name or trademark. That means your client is the 'manufacturer' as of the PPWR terms and needs to provide a Document of Conformity (DoC). But of course they'd need the technical specifications - ideally in the form of technical data sheets - for the packaging components from yourselves. Hope this helps.

The decisive point is the first placing on the market — i.e. import from a third country or the first making available on the EU market — not the subsequent sale by a distributor to the next party in the supply chain. Existing stock is explicitly excluded from the relevant requirements under the Regulation (see below). This also applies to the PFAS limits for food-contact packaging: food-contact packaging placed on the market after 12 August 2026 must comply with the PFAS limits. However, existing stock does not need to be withdrawn. Definition 14, PPWR: “Thus, packaging already placed on the Union market before the date of application of relevant requirements and in the stocks of distributors, including retailers and wholesalers, should not need to meet the sustainability and labelling requirements laid down in or pursuant to this Regulation.” EC Guidance, PPWR 5.: “As regards packaging containing PFAS, which has been produced before 12 August 2026, the PPWR does not foresee a transitional period for the exhaustion of stocks. Therefore, food-contact packaging placed on the market after 12 August 2026 must comply with the PFAS limits laid down in this Regulation, while packaging placed on the market before 12 August 2026 may remain on the market and does not need to be withdrawn. There are no exceptions regarding packaging containing recycled material.”

Dear Monika, The manufacturer must draw up the Declaration of Conformity (DoC) in line with Annex VIII of the Regulation and keep it available for 10 years. Traders and distributors are required to ensure that a DoC exists – in practice it is therefore likely requested and shared along the supply chain. But there is no legal requirement to pass on the technical details to customers. The DoC is the manufacturer's signed assurance that the packaging is compliant. It must describe the packaging in a way that allows it to be uniquely identified – blanket statements without packaging identification and material description are not sufficient. Behind the DoC sits the technical documentation pursuant to Annex VII PPWR, containing all detailed data: material composition, recyclability class (A/B/C), recycled content calculation, substances of concern, minimisation assessment, etc. The DoC itself carries the key data required to identify the packaging; the full technical documentation is provided upon request by market surveillance authorities. Annex VIII EU declaration of conformity No (*) ... 1. No ... (unique identification of the packaging): 2. Name and address of the manufacturer and, where applicable, the manufacturer’s authorised representative: 3. This declaration of conformity is issued under the sole responsibility of the manufacturer. 4. Object of the declaration (identification of the packaging allowing traceability): description of the packaging: 5. The object of the declaration referred to point 4 is in conformity with the relevant Union harmonisation legislation: ... (reference to the other Union acts applied). 6. References to the relevant harmonised standards or the common specifications used or references to the other technical specifications in relation to which conformity is declared: 7. Where applicable, the notified body ... (name, address, number) ... performed ... (description of intervention) ... and issued the certificate(s): ... (details, including the date of the certificate(s), and, where appropriate, information on the duration and conditions of validity). 8. Additional information: Signed for and on behalf of: (place and date of issue): (name, function) (signature):

The Packaging and Packaging Waste Regulation (PPWR) — Regulation (EU) 2025/40 — is the EU’s new law replacing the 1994 Packaging and Packaging Waste Directive. It sets binding rules for all packaging placed on the EU market, covering design, labelling, recycled content, reuse targets, and waste reduction. Unlike the old directive, it applies directly in all Member States without national transposition.

PPWR applies to any company placing packaging on the EU market — regardless of where they are headquartered. This includes non-EU manufacturers whose products are sold in the EU, importers, and distributors who are the "responsible party" in the supply chain.

The key compliance obligation falls on the "producer" as defined in the regulation — typically the brand owner, or where the brand owner is outside the EU, the authorised representative or importer. For supply chain teams, this creates a cascading obligation: you need material data from your packaging suppliers, who may themselves be outside the EU but supplying into EU-bound production.

At minimum, your supplier data collection for PPWR should cover: (1) Material composition — exact materials used, by weight and percentage; (2) Recycled content — percentage of post-consumer recycled content per material; (3) Recyclability certification — whether the packaging is recyclable in the target market; (4) Reuse potential — whether the packaging is designed for reuse and how many cycles it is rated for; (5) Packaging category — consumer, grouped, transport or service packaging under the PPWR taxonomy.

This data should come with supporting documentation: test reports, declarations of conformity, and ideally third-party certifications.

The PPWR covers all packaging and packaging waste on the EU market — every material, every sector. This includes manufacturers, importers, distributors, retailers, e-commerce fulfilment businesses, and food service operators. If you place packaged products on the EU market or use packaging in your operations, you are likely affected.

PPWR covers all packaging formats — consumer, grouped, transport and service packaging are all within scope, though with different requirements and timelines.

Transport packaging (pallets, stretch film, corrugated outer cases) faces specific reuse targets, particularly for B2B supply chains. The Regulation distinguishes primar, secondary, and tertiary (/transport) packaging.

You need to provide the necessary information to evaluate and confirm that all packaging complies with the PPWR's requirements. This might include, for example, your non-EU suppliers obtaining specifications and technical information from their pre-suppliers. Your process has to work with how they actually operate — typically email, PDF, and spreadsheets, or maybe a digital system. The effective approach: (1) design a simple questionnaire that can be completed in a browser or returned as a PDF; (2) keep the initial request minimal; (3) build a central system on your side to ingest, validate, and store responses; (4) automate reminders for missing or expiring data.

Yes. The regulation applies to all packaging placed on the EU market, regardless of where it was manufactured. Importers and fulfilment service providers are responsible for ensuring that packaging from third countries meets PPWR requirements.

The PPWR does not provide a general exemption for small enterprises. All companies placing packaging on the EU market, regardless of size, must comply with the regulation's core obligations, including reporting, design requirements, and registration. However, micro-enterprises are exempt from the obligation to meet re-use and refill targets, if during that calendar year they made not more than 1 000 kg of packaging available on the territory of a Member State. According to Commission Recommendation 2003/361/EC, a micro-enterprise is a business that employs fewer than 10 persons and has an annual turnover or balance sheet total not exceeding €2 million.

The PPWR formally entered into force on 11 February 2025. Most provisions will be enforced from 12 August 2026, allowing businesses time to prepare. Beyond that, recyclability grade requirements apply by 2030, practical recyclability at scale by 2035, and only top grades by 2038.

The Packaging and Packaging Waste Directive 94/62/EC (PPWD) will be repealed 18 months after the PPWR enters into force — i.e. on 12 August 2026. However, certain provisions from the existing framework will continue to apply even after that date during transitional periods.

By 2030, only packaging with recyclability grades A–C can be marketed, and plastic packaging must meet recycled content thresholds. By 2035, packaging must prove practical recyclability at scale, and by 2038, only top grades (A/B) will be permitted. For contact-sensitive plastic packaging (food contact): 10% post-consumer recycled content. For non-contact plastic packaging: 35% for single-use formats. These step up in 2030 and 2040.

Note: "recycled content" must be post-consumer — pre-consumer industrial scrap does not count.

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Companies should consider reviewing packaging formats, materials, and suppliers in light of new design and recyclability requirements; assessing reusable shipping options; collecting supplier documentation on recycled content; and preparing IT systems for digital labelling requirements starting in 2027. The Extended Producer Responsibility (EPR) is a way of obliging companies to take responsibility for the entire life cycle of their products. And this includes not only the product itself, but also all packaging and (product) components.

supplycanvas helps you map your packaging supply chains, track material composition, assess compliance risks, and generate audit-ready documentation. Our platform makes it easy to collect data from suppliers, monitor regulatory changes, and demonstrate due diligence — all without complex enterprise software.