PPWR is now in force: What packaging manufacturers need to know
On 12 August 2026, the first requirements under the EU Packaging and Packaging Waste Regulation (PPWR) become applicable. The regulation covers all packaging placed on the EU market, regardless of material, and is designed to reduce packaging waste while supporting a more circular economy. While several requirements will be introduced gradually over the coming years, a number of important obligations apply from today. One of the key questions many businesses are asking is: Who is responsible for compliance, and what needs to be in place right now? We are here to guide you.
What Applies from 12 August 2026?
From today, the following requirements apply to packaging placed on the EU market:
- Packaging must comply with the applicable PPWR requirements before it is placed on the market.
- Manufacturers must prepare technical documentation demonstrating compliance with the regulation.
- Manufacturers must draw up an EU Declaration of Conformity.
- The total concentration of lead, cadmium, mercury and hexavalent chromium in packaging or packaging components must not exceed 100 mg/kg.
- Food contact packaging must comply with the PPWR restrictions on PFAS.
- Manufacturers must be able to demonstrate compliance and retain the required documentation in accordance with the regulation.
Manufacturer vs Supplier: Understanding the Difference
One important aspect of PPWR is understanding the distinction between a manufacturer and a supplier.
The manufacturer carries the responsibility
Under PPWR, a manufacturer is not necessarily the company physically producing the packaging.
A company that places packaging or a packaged product on the EU market under its own name or trademark is considered the manufacturer. In practice, this means that many brand owners and product companies are regarded as manufacturers under the regulation.
The manufacturer is responsible for:
- Carrying out or arranging the conformity assessment
- Preparing technical documentation
- Drawing up the EU Declaration of Conformity
- Demonstrating compliance before packaging is placed on the market
The supplier provides the supporting information
A supplier is a company that supplies packaging or packaging materials to a manufacturer.
While suppliers are not responsible for issuing the Declaration of Conformity, they play a vital role in supporting the manufacturer's compliance process by providing the necessary information and documentation.
This may include:
- Information on materials and packaging components
- Drawings and specifications
- Documentation supporting compliance with heavy metal restrictions
- Statements regarding PFAS compliance for food contact packaging
A simple way to understand the distinction is that the manufacturer is responsible for proving compliance, while the supplier provides much of the information needed to support that assessment.
Documentation Becomes Increasingly Important
For many companies, the biggest impact of PPWR today is not a change in packaging design, but a greater emphasis on documentation and compliance processes.
Manufacturers need access to reliable information about materials, components, and substances used throughout the packaging structure. Close cooperation between manufacturers and suppliers is therefore increasingly important.
More Requirements Are Coming
The requirements that apply from 12 August 2026 are only the first phase of PPWR implementation.
Additional requirements will follow, including:
- Packaging recyclability requirements from 2030
- Packaging minimisation requirements from 2030
- Minimum recycled content requirements for plastic packaging from 2030
Businesses that establish robust compliance processes now will be better prepared for future requirements as the regulation continues to be implemented.
How Emballator Can Support
PPWR introduces new responsibilities throughout the packaging value chain. At Emballator, we closely monitor regulatory developments and work with customers to provide relevant information and documentation that can support compliance efforts.
If you would like to learn more about how PPWR may affect your packaging solutions, feel free to reach out.
