EU compliance
Packaging and Packaging Waste Regulation (PPWR)
Regulation (EU) 2025/40 on packaging and packaging waste establishes directly applicable EU requirements for packaging design, conformity and documentation, alongside national EPR duties.
Overview
Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) establishes directly applicable EU rules for packaging and packaging waste. It entered into force on 11 February 2025 and applies from 12 August 2026 across the European Union.
PPWR creates product-level requirements for packaging alongside extended producer responsibility requirements. Packaging conformity, technical documentation and the EU Declaration of Conformity therefore form a different compliance layer from national EPR registration, producer-responsibility-organisation participation, records and reporting.
The Regulation contains phased requirements. Some provisions apply from 12 August 2026, while others apply from later dates or depend on delegated or implementing acts. The applicable requirements must therefore be assessed by packaging type, economic-operator role and relevant implementation date.
Who is affected
- Manufacturers of packaging
- Businesses having packaging designed or manufactured under their own name or trademark, subject to the applicable PPWR rules and exceptions
- Importers placing packaging or packaged products on the EU market
- Distributors making packaging or packaged products available on the market
- Suppliers of packaging or packaging materials asked for conformity evidence
- Producers responsible for extended producer responsibility in each Member State
- Businesses supplying packaging or packaged products cross-border by distance contract
- The economic operator responsible for packaging conformity is not necessarily determined by the same test as the producer responsible for national EPR. Both roles therefore need to be assessed separately.
Key obligations
- Determine which PPWR requirements apply to the packaging, including the relevant sustainability, substances, recyclability, minimisation, reuse and labelling provisions and their implementation dates.
- Carry out the applicable conformity assessment and establish the technical documentation required to demonstrate compliance.
- Draw up and maintain the EU Declaration of Conformity where required under the PPWR conformity framework.
- Maintain the required packaging identification, traceability and economic-operator information and ensure that importer and distributor verification duties are addressed where applicable.
- Determine the separate EPR producer status, registration, representation and fulfilment route for each Member State in which packaging or packaged products are supplied.
- Track requirements that phase in over time, including later recyclability performance criteria, recycled-content, packaging-minimisation, reuse/refill and labelling requirements where applicable.
Documentation and data requirements
PPWR conformity documentation is separate from EPR reporting records. Under the conformity-assessment framework in Article 38 and Annex VII, the manufacturer establishes technical documentation capable of demonstrating that the packaging complies with the applicable requirements.
Depending on the packaging and the requirement being assessed, the technical file may include the packaging description and intended use, design and material information, applicable harmonised standards, common specifications or other technical specifications, explanations of the compliance approach, relevant assessments, calculations and test reports.
Once conformity has been demonstrated, the manufacturer draws up the EU Declaration of Conformity in accordance with Article 39 and Annex VIII. The technical documentation and declaration are kept for five years after single-use packaging is placed on the market and for ten years after reusable packaging is placed on the market.
Applicability
PPWR entered into force on 11 February 2025 and applies from 12 August 2026. This does not mean that every substantive requirement has the same application date.
The general recyclability requirement applies from 12 August 2026, while detailed recyclability performance requirements are phased in later under the timetable set by the Regulation and the relevant delegated and implementing acts. Packaging-minimisation requirements under Article 10 apply from 1 January 2030.
For each packaging portfolio, the applicable timeline is therefore mapped requirement by requirement rather than treated as one single PPWR deadline.
Authorised representative: two separate concepts
PPWR distinguishes between an authorised representative for product-compliance tasks and an authorised representative for extended producer responsibility.
Under Article 17, a manufacturer may appoint an EU-established authorised representative by written mandate for specified product-compliance tasks. The mandate does not transfer the manufacturer's obligation to ensure that compliant packaging is placed on the market or the obligation to draw up the technical documentation.
Separately, Article 45 contains rules for an authorised representative for extended producer responsibility. For certain producers supplying packaging or packaged products directly to end users in another Member State, appointment of an EPR authorised representative in the destination Member State is mandatory. These representation roles must not be treated as the same mandate.
Relationship to national EPR
PPWR does not replace national packaging EPR compliance. National producer registration, representation, producer-responsibility-organisation arrangements, records and reporting continue alongside the applicable EU packaging-product requirements.
An EU conformity file does not replace Slovak registration, and it does not replace Czech registration. Slovak registration likewise does not replace Czech registration.
Product conformity and waste/EPR compliance are parallel compliance layers and are assessed separately for each market.
How we assist
- Determine the PPWR requirements relevant to a packaging portfolio
- Map application dates and phased requirements
- Review what packaging specifications, supplier declarations, material information and test evidence are already available
- Identify documentation and data gaps
- Structure the information needed for technical documentation
- Coordinate PPWR readiness with existing Slovak and Czech packaging EPR arrangements
- Identify when specialist testing or legal interpretation is required
- Where ongoing support is included in the agreed scope, we review regulatory developments relevant to that scope and identify where the compliance setup may need to be updated.
EPR Entry is the commercial coordination platform. EU product-compliance support is delivered through the legal service provider identified for the relevant engagement.
We do not certify packaging, perform laboratory testing, issue the manufacturer's EU Declaration of Conformity, assume the manufacturer's legal responsibility or provide formal legal opinions.
Frequently asked questions
Need this assessed against your own product range?
Tell us what you sell and where you sell it. We will come back with the obligations that actually apply — per country and per product stream.