The PPWR — the EU Packaging Regulation explained

What is the PPWR?

The PPWR is the Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste. It governs the entire life cycle of packaging: how it must be designed, which substances it may contain, how it is labelled, and how it is taken back and recovered.

It entered into force on 11 February 2025 and has applied since 12 August 2026. Individual requirements apply from later dates.

The decisive difference from the previous legal situation: the PPWR requires a company to be able to substantiate the properties of every packaging item. It is no longer sufficient to report quantities.

Who does the PPWR apply to?

The PPWR does not attach to company size, but to the role in the supply chain. Anyone placing packaged goods on the market in the EU is affected — regardless of whether the packaging is manufactured in-house or merely used.

Manufacturer

Anyone who manufactures packaging or places packaged products on the market under their own name bears the main burden: conformity assessment, technical documentation, EU declaration of conformity and labelling.

Importers

Anyone importing goods from third countries into the EU must satisfy themselves that the manufacturer has met the requirements and keep the documents available. If evidence is missing, the goods may not be placed on the market.

Distributors and online retailers

Distributors must check whether labelling and documents are in place before offering goods. Anyone selling directly to end customers from another Member State or from a third country is regularly regarded as the responsible party in the destination country — with all the obligations of a manufacturer.

Authorised representatives and fulfilment service providers

Companies without an establishment in the destination country generally need an authorised representative there for extended producer responsibility. Fulfilment service providers have their own duties to check vis-à-vis their clients.

Which obligations arise?

The obligations attach to the individual packaging item, not to the company as a whole. For every packaging item it must be traceable what it consists of and that it meets the requirements.

Conformity assessment and technical documentation

Before placing on the market, the conformity assessment procedure under Annex VII must be carried out. This includes the technical documentation evidencing structure, materials, weights and compliance with the sustainability requirements.

EU Declaration of Conformity

Once the assessment is complete, the EU declaration of conformity is issued in accordance with Article 39 ; its template is set out in Annex VIII. How a declaration of conformity is structured in general and which documents underpin it is explained on the page Conformity declaration. With it, the company assumes responsibility for the packaging meeting the requirements.

Design and recyclability

Packaging must be designed to be recyclable; from 2030 this applies to all packaging on the EU market, and in an economically viable way. Added to this are requirements on recycled content, on minimising weight and volume, and restrictions on certain substances — such as PFAS in food-contact packaging above defined thresholds.

Labelling

In future, packaging will carry harmonised labelling on material composition and separate collection. Environmental claims on packaging will only be permitted from 2030 insofar as they go beyond the statutory minimum requirements — stating a recycled content that is prescribed anyway thus becomes an inadmissible advertising claim.

Extended producer responsibility and registration

Anyone placing packaging on the market in a Member State must register there and report the quantities placed on the market. The registers are organised nationally — anyone supplying several countries has several registrations and several reporting routes. For Germany this is the LUCID packaging register.

Reuse and reusable packaging

Reuse targets apply to certain packaging types and distribution channels. Companies must be able to calculate and substantiate the rates achieved. In the take-away sector, customers must be given the option of bringing their own containers without being charged a surcharge for it.

Retention of evidence

Technical documentation and the EU declaration of conformity must be kept available and presented to the market surveillance authorities on request — five years for single-use packaging, ten years for reusable packaging.

What role do suppliers play?

A company that buys in its packaging usually does not know its composition precisely enough. Recycled content, material codes for each component and recyclability are details held by the packaging manufacturer.

Responsibility for accuracy, however, remains with whoever places the packaged goods on the market. Anyone issuing an EU declaration of conformity cannot rely on not having checked their supplier’s information.

In practice this means: supplier information must be requested, documented and assigned to a specific packaging item — with date, version and supporting document. An e-mail in the inbox is not evidence that can be presented to an authority.

What companies should prepare now

1. Clarify whether you are affected. Which role does the company take in each destination country — manufacturer, importer, distributor?
2. Take stock of packaging. Which packaging is actually used, and to which articles is it assigned?
3. Record components and weights. Not the packaging as a whole, but each component with material and weight.
4. Request supplier information. Recycled content, material codes and recyclability in writing and attributable.
5. Check registrations. In every destination country in which goods are placed on the market.
6. File evidence. Technical documentation and declaration of conformity in such a way that they remain retrievable for five or ten years respectively.
7. Define responsibilities. Who maintains the data, who approves, who reports?

The first two steps determine the effort of all the others. Anyone who does not know which packaging is in use can neither assess nor report it.

Frequently asked questions about the PPWR

Does the PPWR also apply to small companies?

Yes. The PPWR attaches to the role in the supply chain, not to company size. For micro-enterprises the Regulation provides individual reliefs, for example regarding certain reuse targets — they are not exempt from the fundamental obligations.

Does the PPWR replace the national packaging registers?

No. Registration and volume reporting remain nationally organised and continue to apply. The PPWR harmonises the requirements for the packaging itself and is added to the existing registration obligations.

Do I need an EU declaration of conformity for every packaging item?

The conformity assessment and the declaration based on it relate to the packaging as a product. Identical packaging can be grouped together; where material, structure or weight differ, a separate assessment is required.

What happens in the event of infringements?

The Member States determine the penalties; they must be effective, proportionate and dissuasive. In practice, market surveillance often matters more: if documents are missing, placing on the market can be prohibited. Marketplaces already block listings when a registration number is missing.

How does the PPWR differ from the previous Packaging Directive?

Directive 94/62/EC had to be transposed into national law by each Member State, which led to differing rules. As a regulation, the PPWR applies directly and identically in all Member States. In substance, conformity assessment, technical documentation and evidence obligations for each packaging item are added.

Where do I obtain the recycled content of my packaging?

From the packaging supplier. The information must be attributable and verifiable — with date and version, not as an informal statement. Responsibility for accuracy remains with the company that places the packaged goods on the market.