PPWR – new packaging regulations

The EU PPWR Regulation (Packaging and Packaging Waste Regulation) introduces new requirements concerning the design, production, and placing of packaging on the market within the European Union. The first provisions will start to apply as early as 12 August 2026, which is why many companies are currently preparing for the new obligations.

One of the most frequently arising questions is: who is responsible for the packaging's compliance with PPWR? Is it the packaging manufacturer, or the company selling the product under its own brand?

In practice, the answer is not always intuitive.

What is PPWR?

PPWR (Packaging and Packaging Waste Regulation) is a regulation of the European Parliament and of the Council of the EU, the aim of which is to harmonise the rules concerning packaging across the entire European Union.

The new provisions cover, among other things:

• requirements concerning the material composition of packaging,
• restrictions on the use of certain chemical substances,
• obligations relating to the conformity assessment of packaging,
• requirements concerning technical documentation.

For many enterprises, this means the need to prepare new procedures and to gather the appropriate documentation.

What requirements will start to apply from August 2026?

One of the first significant stages of PPWR implementation will be the provisions concerning substances present in packaging.

From 12 August 2026, packaging placed on the market will have to, among other things, meet the requirements set out in Article 5 of the regulation.

This means that:

• the total content of lead, cadmium, mercury, and hexavalent chromium may not exceed 100 mg/kg,
• packaging intended for contact with food will have to meet the restrictions concerning the presence of PFAS substances.

Meeting these requirements will have to be appropriately documented.

Who is the manufacturer according to PPWR?

This is precisely where the most misunderstandings arise.

Within the meaning of PPWR, the manufacturer is not always the packaging producer.

The manufacturer is deemed to be the entity that places the packaging or the packaged product on the market under its own name or trademark.

This means that if a company sells cosmetics, dietary supplements, candles, sweets, or other products under its own brand, it is most often that company that holds the status of manufacturer within the meaning of PPWR — even if the packaging itself was designed and produced by an external supplier.

Who issues the EU declaration of conformity?

This is one of the most frequently asked questions by companies preparing for PPWR.

In accordance with the regulation, the EU declaration of conformity is drawn up solely by the manufacturer.

The producer or supplier of packaging does not issue a declaration of conformity for the finished packaging, because it is not the entity responsible for placing it on the market as an element of the final product.

What role does the packaging supplier play?

This does not mean, however, that the packaging producer does not participate in the process of demonstrating conformity.

On the contrary.

PPWR also imposes obligations on suppliers of packaging and packaging materials.

Their tasks include, among other things, providing the customer with the information and documentation necessary to demonstrate the packaging's conformity with the requirements of the regulation.

This may include, for example:

• information on the materials used,
• documentation concerning the composition of raw materials,
• declarations and certificates received from material suppliers,
• other documents required to prepare the technical documentation.

Thanks to this, the manufacturer can prepare the complete set of documents required by PPWR.

Why is it worth preparing in advance?

Although some of the provisions will only start to apply in 2026, many companies are already beginning to compile documentation and verify the materials they use.

This makes it possible to:

• avoid problems when placing products on the market,
• prepare declarations of conformity more efficiently,
• verify the conformity of the materials used with the new requirements,
• reduce the risk of delays after the provisions enter into force.

The sooner the product producer begins cooperation with packaging suppliers regarding documentation, the easier it will be to meet the requirements of the new regulations.

Summary

PPWR introduces new obligations for all participants in the packaging market; however, the scope of responsibility of the individual entities varies.

In most cases, it is the brand owner or the entity placing the product on the market that holds the status of manufacturer and is responsible for the conformity assessment and for drawing up the EU declaration of conformity.

The role of the packaging producer, on the other hand, is to provide the documentation and information necessary to demonstrate the packaging's conformity with the requirements of PPWR.

In connection with the entry into force of the new provisions, it is worth making sure already today that both the material documentation and the process of cooperation with packaging suppliers are appropriately prepared.

FAQ

When do the first PPWR requirements start to apply?
The first significant provisions concerning packaging composition will start to apply from 12 August 2026.

Who is the manufacturer according to PPWR?
Most often it is the company placing the product on the market under its own brand, rather than the producer of the packaging itself.

Does the packaging producer issue the EU declaration of conformity?
No. The EU declaration of conformity is drawn up solely by the entity holding the status of manufacturer within the meaning of PPWR.

Does the packaging supplier have obligations arising from PPWR?
Yes. It should provide the customer with the documentation and information necessary to demonstrate the packaging's conformity with the requirements of the regulation.