PPWR Compliance for EU Sellers: Practical Actions to Take Now

Regulation (EU) 2025/40 on packaging and packaging waste, commonly known as the Packaging and Packaging Waste Regulation or PPWR, introduces a new EU-wide framework covering packaging design, substances, recyclability, recycled content, reuse, labelling, documentation and packaging waste management.

The PPWR entered into force on 11 February 2025 and will generally apply from 12 August 2026, although many obligations have later application dates or depend on delegated and implementing acts. It applies broadly to packaging placed on the EU market, whether the packaging is empty or contains a product, and regardless of whether it was manufactured inside or outside the EU.

The European Commission provides an overview of the Regulation, its objectives and implementation timetable on its packaging waste and PPWR information page .

For EU sellers, the main challenge is that PPWR compliance is not limited to changing a recycling symbol or paying an environmental fee. Businesses need to manage two connected but legally distinct areas:

1. Packaging compliance, including design, composition, minimisation, labelling and technical documentation.
2. Extended producer responsibility, including national registration, reporting, waste-management financing and, in some cases, the appointment of an authorised representative.

This article explains the concrete steps sellers should take and provides a detailed overview of packaging extended producer responsibility, or EPR.

Who needs to prepare for the PPWR?

The PPWR affects companies involved in placing packaging or packaged products on the EU market, including:

• EU manufacturers selling products under their own brand
• Importers bringing packaged goods into the EU
• Private-label sellers
• Distributors that modify packaging or sell it under their own name or trademark
• E-commerce sellers supplying consumers across EU borders
• Non-EU businesses selling directly to EU consumers
• Companies importing bulk products and repacking them in the EU
• Fulfilment businesses that pack, address, warehouse or dispatch products
• Suppliers of empty packaging, service packaging and certain transport packaging

A business can hold different legal roles for different obligations. For example, an importer may be responsible for checking product and packaging conformity, while the same business may also qualify as the packaging “producer” for national EPR purposes.

The terms manufacturer, importer, distributor, producer, authorised representative, producer responsibility organisation and online marketplace are not interchangeable.

The practical PPWR action plan for EU sellers

1. Map every packaging component

Start with a complete packaging inventory. Do not assess only the retail box.

The inventory should include, where applicable:

• Bottles, jars, tubes and containers
• Caps, pumps, sprayers and closures
• Sachets and flexible films
• Labels and sleeves
• Plastic bags
• Paper inserts and instruction leaflets
• Moulded pulp or plastic trays
• Cardboard boxes
• Protective foams
• Tissue paper and wrapping
• Adhesive tape
• Void fill
• Shipping mailers
• E-commerce cartons
• Pallets, straps and stretch wrap

Materials that consumers or workers can manually separate should normally be recorded as separate components. Coatings, laminations, adhesives and printing inks should also be identified because they can affect substance compliance and recyclability.

For every component, record its function, material, polymer where applicable, weight, dimensions, supplier, colour, recycled content, coatings, printing, adhesives, disposal route and supporting evidence.

Action item

Create one controlled packaging bill of materials covering sales, grouped, transport and e-commerce packaging.

2. Determine your legal role for each sales route

Your role may change depending on where the product originates, who owns the brand, whether the product is repacked and whether it is sold directly to an end user.

A seller should analyse at least the following scenarios separately:

• Domestic sales within one Member State
• Business-to-business sales to another Member State
• Direct online sales to consumers in another Member State
• Imports from outside the EU
• Sales through an online marketplace
• Sales through a fulfilment centre
• Private-label or own-brand sales

Under the PPWR, an importer or distributor that places packaging on the market under its own name or trademark, or modifies packaging in a way that could affect compliance, may become subject to the manufacturer’s obligations.

The relevant definitions and economic-operator duties are set out in the full text of Regulation (EU) 2025/40 .

Action item

Prepare a role matrix identifying the manufacturer, importer, distributor, EPR producer and any representative for every market and sales channel.

3. Build a packaging technical file

Manufacturers will need technical documentation demonstrating conformity with applicable PPWR requirements. The Regulation also provides for an EU declaration of conformity.

A practical packaging technical file should contain:

• Packaging descriptions and photographs
• Component and material inventory
• Drawings and specifications
• Component weights and dimensions
• Supplier declarations
• Substance test reports
• Heavy-metal evidence
• PFAS evidence for relevant food-contact packaging
• Recyclability assessments
• Recycled-content evidence
• Packaging minimisation evidence
• Reuse-system evidence, where applicable
• Artwork and labelling records
• Applicable legal requirements
• Corrective actions
• Version history and approvals

The technical documentation should clearly connect each supplier declaration, specification or test report to the packaging component that it supports.

Action item

Assign every document a unique reference and link each conclusion to the exact component it supports.

4. Check restricted substances and material declarations

The PPWR maintains restrictions covering the aggregate concentration of lead, cadmium, mercury and hexavalent chromium in packaging and packaging components.

It also introduces restrictions on PFAS in food-contact packaging from 12 August 2026, subject to the conditions and thresholds specified in the Regulation.

Do not assume that a generic REACH declaration proves compliance with every packaging-related chemical requirement. Similarly, a test on uncoloured raw resin may not cover pigments, additives, printing, coatings, adhesives or processing effects in the finished packaging.

The European Commission’s PPWR Frequently Asked Questions provide additional explanations concerning substances of concern and the application of the Regulation.

Action item

Obtain component-specific substance declarations or test reports that identify the tested sample, material, laboratory, date, test scope, result and applicable limits.

5. Document packaging minimisation

Packaging must be designed so that its weight and volume are reduced to the minimum necessary to maintain functionality.

Sellers should examine:

• Oversized cartons
• Excessive empty space
• Double packaging
• Unnecessary plastic bags
• Decorative layers with no protective function
• Excessive inserts
• Excess void fill
• Duplicate shipping and retail cartons
• Packaging-to-product ratios

From 1 January 2030, grouped packaging, transport packaging and e-commerce packaging will generally be subject to a maximum empty-space ratio of 50 percent, calculated according to the PPWR’s rules. Certain packaging configurations and exemptions require separate analysis.

Action item

Record product and packaging dimensions, total packaging weight, empty-space calculations and the functional reason for each component.

6. Assess recyclability component by component

The PPWR establishes a pathway under which packaging must meet recyclability requirements from 2030, with recyclability-at-scale requirements applying later.

A statement that a material is “recyclable” is not enough. The assessment should consider:

• The main material
• Collection systems
• Sorting behaviour
• Colour and pigments
• Labels and sleeves
• Closures
• Adhesives
• Coatings and barriers
• Laminated structures
• Separability
• Contamination
• Material recovery yield
• Compatibility with recycling processes
• Recycling at scale

The Commission is preparing further measures on recyclability criteria, design-for-recycling requirements and recyclability performance grades. Businesses should monitor the Commission’s PPWR implementation page for new delegated acts, implementing acts and guidance.

Action item

Identify components that are multi-material, dark-coloured, heavily printed, metallised, laminated or difficult to separate and prioritise them for redesign.

7. Identify plastic recycled-content exposure

From 2030, minimum post-consumer recycled-content targets will apply to specified categories of plastic packaging, with higher or expanded targets applying later.

For each plastic component, record:

• Polymer type
• Packaging format
• Component weight
• Virgin content
• Pre-consumer recycled content
• Post-consumer recycled content
• Supplier verification method
• Chain-of-custody or certification evidence
• Applicable target and date

Bio-based, renewable or biodegradable plastic should not automatically be counted as recycled content.

Action item

Ask plastic-packaging suppliers to provide percentage-based post-consumer recycled-content declarations linked to the exact component and production specification.

8. Review reusable-packaging claims carefully

Packaging is not reusable merely because it is strong enough to be used again.

Reusable packaging must be conceived, designed and placed on the market to complete multiple rotations for the same purpose. Evidence should normally include a functioning reuse system, collection or return arrangements, logistics, inspection or reconditioning procedures and user instructions.

The Commission’s PPWR FAQ contains practical explanations concerning reuse, refill and the conditions under which packaging may qualify as reusable.

Action item

Remove unsupported “reusable” claims or document the complete operational reuse system.

9. Prepare for harmonised EU labelling

The PPWR introduces harmonised packaging labels intended to support material identification and waste sorting. The relevant labels and specifications are subject to implementing measures and later application dates.

Sellers should not invent or prematurely apply unofficial PPWR symbols. Existing national obligations may continue to require separate labels, such as France’s Triman and Info-Tri system.

The Commission has confirmed that further measures are being prepared on:

• Harmonised registration and reporting formats for EPR
• Consumer waste-sorting labels
• Recycled content in plastic packaging
• Recyclability criteria

Further information is available in the Commission’s announcement on PPWR implementation guidance .

Action item

Reserve suitable artwork space and establish a controlled artwork-update process, but wait for the applicable official format before applying a purported PPWR symbol.

10. Review environmental claims

Claims such as “100% recyclable”, “eco-friendly”, “fully sustainable”, “plastic-free” or “reusable” can create legal risk when they are vague, unsupported or inconsistent with the actual packaging structure and available collection systems.

A package should not be described as PPWR-compliant merely because its main material is technically recyclable.

Action item

Create an evidence file for every environmental packaging claim and qualify claims where practical recycling availability is uncertain.

Extended producer responsibility: what EU sellers need to understand

What is packaging EPR?

Extended producer responsibility applies the polluter-pays principle by making the producer financially, and in some systems organisationally, responsible for managing packaging at the waste stage.

The broader EU framework for EPR is established through the Waste Framework Directive , while the PPWR establishes packaging-specific producer registration, reporting, representation and responsibility requirements.

Under Article 45 of the PPWR, producers have EPR responsibility for packaging, including packaging around packaged products, that they:

• Make available for the first time in a Member State
• Unpack without being the end user

EPR is separate from the PPWR’s packaging design and conformity obligations.

A company can therefore have valid packaging specifications but still be non-compliant because it has not registered, reported or paid the applicable EPR contributions.

Who is the EPR producer?

The EPR producer is not automatically the factory that manufactured the product.

The responsible producer depends on factors such as:

• The type of packaging
• Where the business is established
• The Member State where the packaging is first made available
• Whether the recipient is an end user
• Whether the sale is domestic or cross-border
• Whether the sale is made by distance contract
• Whether the packaging is filled at the point of sale
• Whether the business unpacks imported packaging without being the end user
• The use of a company name or trademark

As a general principle, the producer is the business that first makes the packaging or packaged product available within the territory of a Member State.

For direct distance sales, including e-commerce sales, the seller can be the producer in the Member State where the consumer or professional end user is located, even where the seller is established in another Member State or outside the EU.

The European Commission’s PPWR FAQ provides practical examples concerning producer status, end users and cross-border sales.

Example: domestic EU sale

A company established in Germany imports packaged products from a non-EU manufacturer and sells them to German consumers.

The German importer will generally be the packaging EPR producer in Germany because it is the first business making those packaged products available in Germany.

It should check German registration, system-participation, reporting and labelling obligations.

Example: cross-border online sale

A company established in Germany sells a packaged product directly to a consumer in France.

For EPR purposes, the company can be the producer in France because the packaged product is supplied directly to an end user there by distance contract.

Article 45 of Regulation (EU) 2025/40 establishes authorised-representative requirements for certain cross-border EPR situations.

This means that EU establishment in one country does not create one EU-wide EPR registration.

Example: non-EU seller

A company established outside the EU sells directly to consumers in several Member States.

The company may become the EPR producer in each destination country. Member States may require a non-EU producer to appoint an EPR authorised representative in their territory.

The seller should assess each country individually instead of assuming that its importer, marketplace or fulfilment provider automatically assumes responsibility.

Registration responsibilities

The PPWR requires producers to register in each Member State where the relevant producer conditions are met.

Registration information may include:

• Producer name and address
• Brand names
• Contact details
• Company or trade-register identification
• Tax identification
• Details of the EPR authorised representative, where applicable
• Information on how EPR obligations are fulfilled
• Details and evidence of participation in a producer responsibility organisation where applicable

The registration requirements and information fields are addressed in Articles 44 to 47 and Annex IX of the PPWR .

The PPWR seeks to harmonise the format and core content of registration, but EPR does not become a single EU system. Producers will still deal with national registers, national authorities and national waste-management structures.

Reporting responsibilities

Producers must track packaging quantities by Member State and reporting period.

Depending on the applicable reporting format, packaging data may need to be divided by material categories such as:

• Glass
• Plastic
• Paper and cardboard
• Ferrous metal
• Aluminium
• Wood
• Other materials

Reduced reporting detail may apply to certain lower-volume producers, but a simplified reporting format should not automatically be treated as a complete exemption from registration, EPR fees or other national obligations.

The Commission is preparing harmonised EPR registration and reporting formats. Existing national EPR reporting requirements continue to apply while the PPWR framework is implemented.

Practical warning

Do not wait for the first harmonised PPWR report. Sellers should already collect packaging weights and country-level sales data because national EPR schemes are currently operating.

Financial responsibilities

EPR contributions finance the management of packaging waste. Depending on the national system, these costs can include:

• Separate collection
• Transport
• Sorting
• Treatment
• Recycling
• Consumer information
• Data gathering
• Litter-related costs where legally applicable
• Administrative costs
• Labelling of waste receptacles
• Required compositional surveys of mixed municipal waste

Fees are expected to become increasingly eco-modulated. This means packaging with stronger recyclability performance may attract different fees from packaging that is difficult to recycle.

Member States may also differentiate contributions using factors such as:

• Recycled content
• Reusability
• Material efficiency
• Design-for-recycling performance
• The presence of substances affecting recycling
• Packaging format
• Collection and treatment costs

Producer responsibility organisations

A producer may entrust an authorised producer responsibility organisation, commonly called a PRO, to carry out EPR obligations on its behalf. Member States may also make PRO participation mandatory.

A PRO may handle activities such as:

• Registration support
• Packaging declarations
• Fee calculation and payment
• Waste-management financing
• Compliance reporting
• Collection and recycling arrangements
• Producer certificates

However, using a PRO does not eliminate the producer’s responsibility to provide correct information.

The producer should maintain:

• The signed PRO agreement or mandate
• Registration confirmation
• Membership or participation certificates
• Submitted declarations
• Packaging data calculations
• Invoices and payment evidence
• Correspondence concerning corrections
• Copies of annual reports

EPR authorised representatives

An EPR authorised representative is a person or business formally appointed by written mandate to perform specified EPR obligations in a Member State.

This role should not be confused with:

• A product-compliance authorised representative
• A GPSR Responsible Person
• An importer
• A customs representative
• A producer responsibility organisation
• An online marketplace
• A fulfilment service provider

One organisation may perform more than one role, but each role must have its own legal basis, scope and mandate.

Cross-border distance sellers should assess whether an EPR authorised representative is required in each destination Member State. Non-EU producers should also check the national representative rules of every country in which they sell.

Marketplace responsibilities

Online marketplaces are not automatically the EPR producer and do not automatically take over a seller’s registration and reporting obligations.

The PPWR requires covered online platforms to obtain specified information from producers before allowing them to offer packaged products to consumers.

This may include:

• The producer’s registration information
• The relevant registration number
• Confirmation that applicable EPR obligations are fulfilled

A platform may provide EPR-related services or pay fees under a contractual mandate. However, the seller should not assume that this transfers all legal responsibility unless the platform has been formally appointed to perform the relevant role.

Sellers should expect marketplaces to request registration numbers, certificates and supporting documentation.

Fulfilment-service-provider checks

Fulfilment providers may also be required to obtain and verify producer registration and EPR information.

They may request supporting documents, verify information against public registers and require inaccurate or incomplete information to be corrected.

Where information is not corrected, the provider may suspend relevant services where required by the applicable rules.

Common EPR mistakes

• Registering only in the seller’s home country
• Treating a VAT registration as packaging EPR registration
• Assuming a marketplace handles all EPR duties
• Reporting only product-contact packaging
• Excluding shipping cartons and void fill
• Using estimated weights without documenting the method
• Reporting all EU sales in one country
• Confusing a PRO membership number with a national producer number
• Appointing a representative without a written mandate
• Failing to update registrations after changes to company or brand information
• Assuming small sales volumes always create an exemption
• Claiming registration is complete without official confirmation

A 12-point PPWR and EPR checklist for sellers

1. Identify every EU country in which packaged products are sold.
2. Map all sales, grouped, transport and e-commerce packaging.
3. Record the material and weight of every packaging component.
4. Determine the manufacturer, importer, distributor and EPR producer for each sales route.
5. Review current national EPR registrations and PRO agreements.
6. Appoint EPR authorised representatives where required.
7. Establish country-level packaging data collection.
8. Review substance, heavy-metal and PFAS evidence.
9. Document packaging minimisation.
10. Assess recyclability and recycled-content exposure.
11. Create a packaging technical documentation file.
12. Monitor EU implementing acts, delegated acts and national changes.

Final considerations

The PPWR creates more harmonised product and packaging requirements, but it does not replace the need for country-by-country EPR management.

For EU sellers, the most effective approach is to connect packaging engineering, supplier documentation, artwork control, product compliance, sales data and national EPR administration within one controlled compliance process.

Businesses that begin by mapping their packaging and sales routes will be better positioned to identify responsibility, request the correct supplier evidence, prepare technical documentation and avoid gaps in national registration or reporting.

This assessment reflects the legislation, official guidance and documentation available on the publication date. The packaging should be reassessed when relevant delegated acts, implementing acts, harmonised standards or material changes become applicable.

The client remains responsible for ensuring that the information supplied is complete and accurate, approving the final documentation, implementing the recommended actions, maintaining supporting records and completing registrations or declarations that must legally be submitted by the producer or another designated economic operator.

Official EU sources and references

1. Regulation (EU) 2025/40 on packaging and packaging waste
2. European Commission: Packaging waste and PPWR overview
3. European Commission: Guidance document on the Packaging and Packaging Waste Regulation
4. European Commission: Frequently Asked Questions on the PPWR
5. European Commission: PPWR implementation page
6. EUR-Lex summary: Packaging and packaging waste from 2026
7. European Commission: Waste Framework Directive
8. European Commission: Facts about the new EU packaging rules
9. European Commission press release on PPWR implementation guidance
10. European Commission: Implementing and delegated acts