EU Packaging and Packaging Waste Regulation (PPWR) 2025/40

Practical Compliance Guidance for Businesses Selling into the European Union 

Regulation: EU Packaging and Packaging Waste Regulation 
Entry into force: 11 February 2025 
General application date: 12 August 2026 

Important: Businesses Selling into the EU Need to Act Now 

If your business sells products into the European Union, the new EU Packaging and Packaging Waste Regulation (PPWR) is likely to affect you. 

The overall objectives of the Regulation include: 

• Reducing packaging waste 
• Reducing unnecessary packaging 
• Improving recyclability 
• Increasing reuse and refill systems 
• Reducing environmental impacts 
• Supporting the circular economy 

The Regulation introduces legally binding packaging requirements covering: 

• Packaging minimisation 
• Recyclability and minimum recycled content 
• Reuseable and refillable packaging 
• Limitation of harmful substances – heavy metals and PFAS (polyfluorinated alkyl substances) 
• Prohibition of certain types of single use plastic packaging such as non-compostable tea bags and labels for fruit and vegetables 
• Labelling 
• Technical documentation 
• Producer responsibility obligations 

The PPWR applies to packaging and packaged products placed on the EU market, not simply to manufacturers located in the EU. This means non-EU manufacturers, Amazon sellers, e-commerce businesses, importers and distributors all have responsibilities under the Regulation. 

Many businesses currently assume packaging compliance is the responsibility of the packaging supplier alone. In reality, it is the responsibility of all suppliers who manufacture, import, specify, brand or place packaged products on the EU market. 

Contents 

1. What is the Packaging and Packaging Waste Regulation – PPWR? 
2. Who does the Packaging and Packaging Waste Regulation (PPWR) Regulation Apply To
3. Technical Documentation Requirements of Packaging and Packaging Waste Regulation (PPWR) –
4. Packaging and Packaging Waste Regulation (PPWR) Declaration of Conformity 

What is the Packaging and Packaging Waste Regulation PPWR? 

The Regulation applies to all packaging placed on the EU market, regardless of the packaging material used, that is intended for the containment, protection, handling, delivery or presentation of products.  

This includes: 

• Retail packaging 
• E-commerce packaging 
• Transport packaging 
• Industrial packaging 
• Grouped packaging 
• Primary, secondary and tertiary packaging 

With some notable exclusions in the regulation, packaging does not generally include items which are integral to the product.  

If you need support identifying whether your packaging is in scope of the regulation, please contact us for guidance.  

Who does the Packaging and Packaging Waste Regulation (PPWR) Regulation Apply To?

The PPWR applies to economic operators placing packaging or packaged products on the EU market. This includes manufacturers, suppliers, importers, distributors, authorised representatives, final distributors and fulfilment service providers. 

Manufacturers 

Anyone who manufactures packaging or packaged products under its own name or trademark bear the primary responsibility for the compliance of the packaging to the PPWR, regardless of any other trademarks visible on the packaging.  

Suppliers 

Suppliers of packaging have certain obligations under the regulation to pass on compliance information to the packaging manufacturer to enable them to fulfil their obligations as the manufacturer.  

Certain exemptions apply to microenterprises with low turnover and capitalisation who supply packaged products to pass on their compliance obligations to an EU-based packaging manufacturer, known as the supplier. This can only apply where the supplier and microenterprise are located in the same EU country however.  

Importers 

Importers are responsible for ensuring that packaging and packaged products imported from outside the EU comply with all applicable regulatory requirements before being placed on the EU market. This includes verifying that the manufacturer has carried out the necessary conformity assessment, ensuring that technical documentation and declarations of conformity are available, and taking appropriate corrective action where non-compliance is identified. Importers must also cooperate with market surveillance authorities and, where applicable, fulfil extended producer responsibility (EPR) obligations in the Member States where packaging is placed on the market. 

Manufacturer Obligations 

The manufacturer who is responsible for the compliance of the packaging must meet the following obligations: 

• Ensure packaging complies with all applicable PPWR requirements provided in Articles 5-12 of the regulation.  
• Design and manufacture packaging in accordance with sustainability requirements, including restrictions on substances of concern, recyclability, minimisation of packaging weight and volume, and recycled content requirements where applicable. 
• Carry out the required conformity assessment procedures. 
• Prepare and maintain technical documentation demonstrating compliance with PPWR requirements. 
• Draw up an EU Declaration of Conformity (DoC) and keep it available for the required retention period. 
• Implement procedures to ensure continued compliance for serial production. 
• Affix the CE marking to packaging where required under the Regulation. 
• Ensure packaging bears the required identification, labelling, and information markings, including providing a QR code indicating the manufacturer information. 
• Take corrective actions, including withdrawal or recall, where packaging is found to be non-compliant. 
• Inform market surveillance authorities of non-compliance that may pose a risk or breach regulatory requirements, and cooperate by providing documentation or evidence of compliance upon request. 
• Fulfil applicable Extended Producer Responsibility (EPR) obligations, either directly or through authorised schemes, in Member States where packaging is placed on the market. 

Technical Documentation Requirements for the EU Packaging and Packaging Waste Regulation (PPWR)

Technical documentation is likely to become one of the most important operational areas under the PPWR. 

Businesses should expect increasing requests from authorities, distributors and customers for documented evidence demonstrating packaging compliance. 

The technical documentation should provide evidence of the packaging design, function,  performance, and conformity with relevant regulatory obligations. It should also describe the methods, assessments, and supporting information used to verify compliance, together with records necessary to demonstrate ongoing conformity throughout the product lifecycle. 

If you require further guidance with this, please see our Packaging and Packaging Waste (PPWR) checklist which can be used to ensure you are meeting all of your documentation obligations. 

The technical documentation must be retained for at least 5 years for single-use packaging and 10 years for reusable packaging after the packaging is placed on the market and must be made available to market surveillance authorities upon request. 

Packaging and Packaging Waste Regulation (PPWR) Declaration of Conformity 

Manufacturers of packaging must draw up an EU Declaration of Conformity (DoC) which is their statement that the packaging complies with the applicable requirements of the legislation, has completed the conformity assessment procedure, and produce the necessary technical documentation.  

The DoC must identify the product, the economic operator(s), and the applicable legislation and standards which are being declared against.  

You can purchase a Packaging and Packaging Waste Declaration of Conformity template in our shop at Product Compliance Support Ltd.

We also have a Packaging and Packaging Waste Regulation (PPWR) FAQs page here