The PPWR is here: Do you understand how it applies to your organization?

If you place packaging on the EU market, regardless of where you’re headquartered or how large your company is, the EU Packaging and Packaging Waste Regulation (PPWR) applies to you.

Given this, the first question every company needs to answer is: are you a manufacturer, producer, importer, or distributor (or several of these)? Your role(s), rather than your organization’s size or location, determines your obligations.

Get this wrong, and you risk not only hindering EU market access but also building a compliance plan around requirements that you don’t actually have to follow.

The regulation started to apply on August 12, 2026, meaning the time to act is now.

Core obligations that entered into force on this date include:

• Conformity assessment & declaration of conformity (DoC)
• Substance restrictions
• Extended producer responsibility (EPR) registration
• Restriction on environmental claims concerning packaging properties
• Reusable packing requirements

Harmonized labeling requirements, recyclability grades, recycled-content targets, empty-space caps, packaging minimization, refill and reuse targets, and single-use bans will be phased in over time.

This does not mean preparation is optional. Market surveillance authorities were authorized to start their enforcement activity on August 12, 2026, even though the deadline for member states to formalize penalties under the PPWR is set to mid-February 2027.

The compliance window is shorter than it looks.

Key questions and steps to take now

Do you understand your role in the packaging value chain?

• Manufacturers: These are entities making packaging or packaged products, or having them designed or built under their name/trademark. Rebranding and micro-enterprise exemptions apply.
• Importers: These are entities established in the EU that place packaging from non-EU countries on the EU market.
• Producers: These are entities, which could simultaneously be an importer, manufacturer, or distributor, who first make a packaging or packaged products available on the market of a given EU member state for the first time.
• Distributors: These are entities in the supply chain that are not manufacturers or importers and that make packaging available on the EU market.

What to do now?

• Identify your role or roles (you may have more than one) by mapping where your organization uses packaging and where you sit in that packaging’s supply chain.

Is your packaging reusable?

Authorities in EU member states can start checking that packaging meets the reusability requirements, such as the following:

• Packaging must be able to be emptied, unloaded, or repeatedly refilled without damage or loss of function, or risk to health and safety
• Packaging must be recyclable at the end of its life

What to do now:

• Assess which product lines could shift to reusable formats
• Confirm packaging placed on the market meets the reusability criteria before the authorities ask about it

Is your documentation sufficient?

Manufacturers must:

• Demonstrate compliance with substance restrictions and reusable packaging requirements
• Issue a DoC in the required format for each type of packaging

What to do now:

• Identify which entity in the supply chain qualifies as “manufacturer” for each packaging line
• Establish internal processes and assign responsibility for conformity assessments, technical documentation, and document retention

Do you understand the fees for packaging waste?

Producers are financially responsible for the full life cycle of their packaging (extended producer responsibility, or EPR). The EPR regime includes the costs of:

• Collection
• Sorting
• Recycling

What to do now:

• If you are a producer, ensure EPR registration is completed in the relevant member states
• Model your exposure to future EPR fees
• Improve packaging’s recyclability, recycled content, and reusability to lower fees
• E-commerce companies should review their responsibilities for shipping packaging

Do you need a complete PPWR compliance strategy? If you do, we can help. Contact Alessandra Oglino, ECOFACT’s Head of Client Solutions & Growth Services: alessandra.oglino@ecofact.com; +41 58 520 20 10.