In this post, we will briefly describe the necessary steps for the efficient implementation of the PPWR Regulation.
The changed EU approach to packaging requires the validation of the entire supply cycle and a redefinition of the company's roles for each packaging used. This task typically requires the collaboration of several departments simultaneously to collect and analyze packaging data. To facilitate navigation through the PPWR requirements, we present below the steps necessary to implement these requirements and prepare an EU declaration of conformity for packaging.
New definistions:
- Importer: A natural or legal person residing or established in the EU who places packaging from a third country on the market.
- Manufacturer: Any manufacturer, importer, or distributor who—regardless of the selling technique—(1) makes packaging or packaged products available for the first time in the territory of a Member State, (2) sells directly to end users by distance selling, or (3) unpacks products without being the end user.
- Distributor: A natural or legal person in the supply chain, other than the manufacturer or importer, who makes packaging available on the market.
- Supplier: A natural or legal person who supplies packaging or packaging material to the manufacturer.
Step 1: Create a list of all packaging that may be present on the premises.
Step 2: Determine the company's role in the packaging supply chain for each identified packaging type to determine the scope of responsibilities.
Step 3: Identify the packaging subject to the obligation to prepare a declaration of conformity. Develop a PPWR implementation plan.
Step 4: Verify hazardous substances (Art. 5)
- Ensure that the sum of lead, cadmium, mercury, and hexavalent chromium concentrations in packaging does not exceed 100 mg/kg.
- If packaging is in contact with food, you must verify that the packaging meets the limits for PFAS substances (their use above strict limits is prohibited from August 12, 2026).
Step 5: Obtain data from suppliers (Art. 16)
Request full technical documentation and chemical composition certificates from packaging suppliers. They are obligated to provide this information so that you can prepare your own declaration of conformity.
Step 6: Conduct a conformity assessment (Art. 38)
You must conduct an internal production control procedure to demonstrate that the packaging meets sustainability requirements (recyclability, material minimization, void space).
Step 7: Preparation of Technical Documentation and EU Declaration of Conformity (Art. 39)
- Technical documentation: This must include, among other things, a description of the packaging, design drawings, a list of applied standards, and test results (e.g., for heavy metals, PFAS).
- EU Declaration of Conformity (DoC): You must prepare a written declaration (using the template in Annex VIII) confirming compliance with the PPWR. This document must be retained for 5 years after the packaging is placed on the market.
Step 8: Labeling and Traceability Contact Information:
- Your name, address, trade name, and contact information must be included on each package (or in a QR code).
- Batch/Type Number:
Packages must have a batch or serial number enabling their identification.
Sorting Labels (from August 2028): Harmonized pictograms will be required to inform consumers which bin to use for each component of the packaging. Until then, labeling as required by Polish regulations will be required.
Further obligations (deferred):
- Recyclability (from 2030): Packaging will be required to have a recycling class of A, B, or C. From 2038, only classes A and B will be permitted.
- Minimum recycled content (PCR) (from 2030): For some packaging, there is currently no fixed target (the Commission will monitor this). For plastic containers: if PET – at least 30% PCR; if other plastics – at least 10% PCR.
- Packaging minimization:
- The weight and volume of packaging must be limited to the minimum necessary for its functionality.
Visit our dedicated page on this topic: PPWR
