PPWR packaging regulation in practice: from legal obligation to business process

Does our packaging comply? Are we a manufacturer, producer, importer or distributor? What information do we need from suppliers? And what must we be able to demonstrate if a regulator, customer or supply chain partner asks for substantiation?

These are questions that many packaging, quality, procurement and compliance departments are facing. The issue is not only whether the Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) is relevant, but above all what this Regulation specifically requires from the organisation, from when, and who is responsible for what within the supply chain.

1. What changes from 12 August 2026?

The PPWR entered into force on 11 February 2025. From 12 August 2026, important parts of the Regulation will start to apply to businesses. This does not mean that all obligations will be fully technically developed by that date. Some elements will follow later or depend on implementing acts, delegated acts, standards or guidance.

Even so, 12 August 2026 is not a date to wait for passively. For relevant obligations, businesses must be able to determine which role they have, which packaging falls within scope and what information is needed to substantiate compliance.

This includes, among other things, conformity assessment and the declaration of conformity, name and traceability requirements, food contact packaging and PFAS, supplier information and extended producer responsibility. The way in which roles in the supply chain must be assessed is also changing. This may have consequences for who is responsible for documentation, registration, reporting or declarations.

The key point is therefore this: 12 August 2026 is not an endpoint by which everything will be fully developed, but it is also not a non-committal date. The basic Regulation has been adopted. Organisations must now determine what is relevant to them and which choices they need to prepare for.

2. First determine scope and role

The PPWR has a broad scope. It applies to packaging placed on the EU market, regardless of material, sector or company size. It therefore affects not only traditional packaging producers. Importers, webshops, retailers, food companies, logistics service providers, fulfilment parties and businesses that purchase, fill or use packaging under their own name must also assess which role they have.

The scope question is therefore not only whether a company produces packaging itself. More relevant is which packaging it uses, in what form, for what purpose and who first places the packaging or packaged product on the market.

Question	Why is this relevant?
Which packaging do we use?	The PPWR distinguishes, among other things, sales packaging, grouped packaging, transport packaging, e-commerce packaging, service packaging, takeaway packaging and primary production packaging.
In which role do we act?	Obligations differ by role, for example manufacturer, importer, distributor, producer, final distributor or fulfilment service provider.
In which countries are products placed on the market?	Producer responsibility, registration and reporting may differ between Member States.
What information do we need?	Without material information, supplier data and technical documentation, compliance is difficult to demonstrate.
Which elements are still under development?	Not all technical details have been finalised yet. Ongoing monitoring therefore remains necessary.

A proper scope assessment is essential. Looking too narrowly may cause obligations to be missed. Looking too broadly may result in unnecessarily burdensome measures. A sound PPWR approach therefore starts with legal interpretation and scope assessment. Only after that does an organisation know what it must implement, document and embed. This helps prevent obligations from being missed, measures from being designed too broadly, or the PPWR from being applied incorrectly.

3. What role do we have in the supply chain?

Role assessment is one of the most important questions under the PPWR. The Regulation distinguishes, among others, between supplier, manufacturer, importer, distributor, final distributor, producer and fulfilment service provider. These roles are not only legally relevant; they also determine which obligations, documentation, information and reporting requirements apply.

Role	Practical meaning
Manufacturer	Relevant for, among other things, conformity, technical documentation, name requirements and traceability. This is not always only the party that physically produces the packaging.
Importer	The EU-established party that places packaging or packaged products from a third country on the market.
Distributor	The party that makes packaging or packaged products available further down the supply chain, without being the manufacturer or importer. For example, a party that purchases within the EU and supplies onwards.
Producer	Relevant for extended producer responsibility, registration, reporting and the financing of waste management.
Final distributor	The party that supplies packaged products to the end user, such as shops, webshops, hospitality or foodservice businesses.
Fulfilment service provider	Relevant where storage, packaging, addressing or dispatch plays a role without the service provider owning the products.

A company may have multiple roles. Its role may also differ by packaging stream. The position for sales packaging may be different from that for transport packaging, e-commerce packaging, service packaging or packaging sourced from a third country.

Role assessment can be particularly complex for transport packaging, service packaging and primary production packaging. In practice, questions arise about who places the packaging on the market in its final form, who assembles components, who has the packaging manufactured or branded, and in which Member State the packaging ultimately becomes waste. Precisely on these points, interpretation is still developing and further clarification may have consequences for declarations, reporting and supply chain agreements. Businesses should therefore avoid assuming too quickly that there is one standard answer.

4. What information must we be able to substantiate?

Complying with the PPWR is one step. Being able to demonstrate compliance with the relevant obligations is another. Regulators, customers or supply chain partners may ask for substantiation. In that case, it is not sufficient if information is scattered across emails, supplier documents, product specifications and separate spreadsheets.

The central question is what information must be available for each packaging item or packaging stream. This includes material types, components, weights, suppliers, applications, countries where products are placed on the market, food contact, technical documentation, declarations and data required for registration, reporting or EPR obligations.

The conformity assessment and declaration of conformity play an important role in this respect. The precise details may depend on the obligation, the type of packaging and further technical development. It is therefore advisable not to speak too quickly of one standard package that is the same for every type of packaging. What does apply is that organisations need to know which documentation is required, who prepares it, who keeps it and how changes are processed.

Supplier information is necessary for this purpose, but it is not sufficient. A general confirmation that packaging is “PPWR-compliant” says little in itself. An organisation must be able to assess what such a statement relates to, for which packaging or component it applies, how current the information is and what happens if the composition changes.

For food companies, this is particularly relevant. From 12 August 2026, food contact packaging may not be placed on the market if it contains PFAS above the relevant limit values. This requires insight into the packaging used and the relevant material components, such as coatings, barriers, adhesives, inks and grease-resistant layers.

5. What can already be done?

Part of the technical development of the PPWR is still to follow. This applies, among other things, to elements of labelling, digital marking, recyclability criteria, calculation methods and further harmonisation. That uncertainty is real, but it is not a reason to do nothing.

Step	What does this mean in practice?
Map packaging streams	Which packaging is used, for what purpose, for which products and in which countries?
Determine roles	Is the organisation a manufacturer, importer, distributor, producer, final distributor or fulfilment service provider — and does this differ by packaging stream?
Request supplier information	What data is needed on material, composition, coatings, adhesives, inks, barriers and food contact?
Assess packaging choices	Are packaging choices necessary, proportionate, properly substantiated and sufficiently future-proof?
Assign monitoring responsibilities	Who monitors implementing acts, guidance, standards and supply chain information, and who translates these into internal actions?
Embed in processes	How are responsibilities, reporting, changes and supply chain agreements documented?

Where questions of interpretation remain open, waiting is not the same as doing nothing. Precisely in those situations, it is important to map the organisation’s packaging streams, supply chain parties, contractual arrangements and available data, so that the organisation can respond quickly once further clarity becomes available.

6. From analysis to business process

The PPWR is not a topic that can remain with one department. Procurement is in contact with suppliers. Quality or food safety looks at food contact and product safety. Marketing and product development manage artwork, claims, labels and packaging design. Logistics uses transport and shipping packaging. Finance is involved in reporting and contributions. Legal and compliance monitor regulation, contracts and responsibilities.

If these areas operate separately, risks arise. Packaging may be changed without the correct information being requested. A supplier may change material without this being assessed internally. Reporting may be based on incomplete data. Or a new market introduction may have consequences for producer responsibility without this being identified in time.

That is why the outcome of the legal analysis must be translated into business processes. Which data is recorded? Who requests supplier information? Who assesses changes in material, coating, adhesive, ink or artwork? Who monitors registration and reporting? Who follows implementing acts and guidance? And who escalates when information is missing?

Sound PPWR implementation therefore requires not only knowledge of the Regulation, but also documentation in policies, processes, responsibilities and supply chain agreements.

Conclusion

The PPWR raises recognisable questions for businesses. Does this apply to us? What role do we have? Which packaging falls within scope? What information do we need? What must be done now, what will follow later and who monitors this internally?

The answers to these questions determine how the PPWR must be translated into business processes. Proper legal interpretation helps prevent obligations from being missed, measures from being designed too broadly, or the Regulation from being applied incorrectly.

For organisations that purchase, fill, use, import or place packaging on the market under their own name, a targeted scope and role assessment is therefore often the logical first step. Not to do everything at once, but to determine precisely what actually needs to be implemented, documented and embedded.

This is precisely the translation DUFINCO focuses on: from legal interpretation and scope assessment to workable processes, responsibilities and supply chain agreements.

Would you like to know what the PPWR means for your organisation, your packaging streams or your role in the supply chain? Please contact us at info@dufinco.nl or call +31 (0)6 512 47 217.