Navigating PPWR Compliance
The Packaging and Packaging Waste Regulation (PPWR) is reshaping the future of packaging in Europe. At Emballator, we are committed to meeting these requirements and helping our customers do the same. In this article, we outline what PPWR means for your business, how we ensure compliance, and the practical ways we can support you on your journey toward sustainable packaging solutions.
What is the PPWR?
The PPWR (Regulation (EU) 2025/40) is an EU-wide regulation, replacing the previous directive, that governs the entire packaging life‑cycle - from design and production through to waste management. Article 15 and 16 takes effect from 12 August 2026.
The following are some of the key objectives:
- Make all packaging recyclable by 2030: Packaging must meet minimum recyclability standards - packaging that fails to reach Grade C (≥ 70% recyclable by weight) will be banned after 2030. Latest 1 January 2028 the commission will present the criteria for recyclable packaging.
- Boost recycled content in plastic packaging: Mandatory minimum levels of post‑consumer recycled material in plastic packaging.
- Harmonize labelling and design requirements: Standardized design-for-recycling criteria, labelling, QR‑codes, and stricter controls on harmful substances (e.g., PFAS, heavy metals) to simplify recycling practices and ensure consumer clarity.
- Strengthen and Harmonise Extended Producer Responsibility (EPR): Producers become more accountable through eco-modulated fees tied to recyclability and waste reduction performance.
Identify Your Manufacturer Status
Understanding who is considered the manufacturer under PPWR is essential for compliance with article 15.
- Manufacturer Definition: Any person or company that makes packaging or packaged products.
- Brand Owner Rule: If packaging is produced under your name or brand, you are the manufacturer.
- Micro-Enterprise Exception: If the brand owner is a micro-enterprise and the packaging supplier is in the same EU country, the supplier is considered the manufacturer.
Key Obligations for Manufacturers (Article 15)
Under PPWR, manufacturers have specific responsibilities to ensure compliance. Here is what you need to follow:
Place only compliant packaging on the market
Packaging must meet requirements in Articles 5–12
- Article 5 avoid substances of concern (PFAS and heavy metals)
- Article 6 secure recyclability
- Article 7 secure minimum amount of recycled content
- Article 8 requirements for biobased feedstock
- Article 9 requirements for compostable packaging
- Article 10 minimize packaging size and packaging material usage
- Article 11 requirement for reusable packaging
- Article 12 requirements for labelling
Prepare technical documentation before market entry
By August 12, 2026, documentation (according to Annex VII), must be ready before packaging is placed on the market.
Keep the documentation records for the required period
- Single-use packaging: 5 years
- Reusable packaging: 10 years
Ensure ongoing compliance
Reassess if design or materials change during production.
Mark packaging clearly
Include type, batch, or serial number, and provide manufacturer name and contact details (on packaging or via QR code).
Act quickly if non-compliant
Take corrective action - fix, withdraw, or recall - and notify national authorities.
Key Obligations for Suppliers (Article 16)
Emballator as a packaging supplier will deliver documents showing that the packaging meets Articles 5–11. The information will be clear, in a standard format, and provided in English.
Conformity Assessment – What It Means for You
Under PPWR, every manufacturer must ensure that packaging complies with sustainability and safety requirements before it is placed on the market. This process is called Conformity Assessment, and it involves preparing and maintaining detailed documentation.
Technical Documentation (according to Annex VII) including:
- Description, design drawings, and material list
- Applied standards and specifications
- Test reports when applicable
- A declaration of conformity that production matches the documentation.
You as a manufacturer need to provide the declaration of conformity to the national authority upon request. For each packaging type, keep the declaration of conformity and the technical documentation for 5 years if single-use or 10 years if reusable.
