PPWR takes effect today: New requirements for the entire plastics industry

The PPWR introduces more uniform packaging rules across the European Union

The Regulation is gradually changing requirements for composition, recyclability, recycled content, reuse and the responsibilities of individual operators in the supply chain.

The first set of new obligations starts to apply today. It is therefore important for companies to know not only what packaging they manufacture or use, but above all what role they play in the supply chain under the PPWR.

From 12 August 2026, manufacturers must demonstrate compliance with selected restrictions on the content of certain substances in packaging, including, for example, PFAS and heavy metals. The requirements also include the relevant declaration of conformity.

From 2027, additional obligations will be introduced relating, for example, to registration and producer responsibility. In subsequent years, requirements will follow concerning packaging recyclability, recycled content and the reuse of selected types of packaging.

For companies, the PPWR therefore does not represent a single specific change on a single date, but a gradual process that will affect packaging management until 2030 and beyond.

Correctly identifying a company's role under the PPWR is crucial

The Regulation covers several supply chain operators and distinguishes, for example, between suppliers, manufacturers, producers and importers. Their specific obligations then depend on correct classification.

• a supplier provides packaging or packaging material and supplies the information needed to assess its conformity
• a manufacturer manufactures packaging or a packaged product and is responsible for demonstrating that the relevant requirements have been met
• a producer is an operator that first makes a packaged product available on the market of a specific EU Member State. In future, this role will also carry obligations relating to extended producer responsibility.
• an importer places packaging or packaged products originating from countries outside the European Union on the EU market and must ensure their compliance with PPWR requirements.

A company does not necessarily have just one role. Depending on its business model, it may, for example, be a supplier, manufacturer and importer at the same time.

Companies should map their entire packaging chain

With the introduction of the PPWR, it is therefore no longer sufficient to consider only the material itself or a specific product. The entire process matters – who manufactures the packaging, who supplies it, who fills it or uses it for packaging, where it comes from and who first places it on a specific market.

Companies in the plastics industry should check in particular:

• what packaging and packaging materials they manufacture, use or import,
• at what stage the packaging takes its final form,
• who first places it on the market,
• what role the company plays under the PPWR,
• what documents and technical information will need to be provided.

Correctly identifying a company's position in the supply chain is essential, as it determines the scope of its specific obligations.

Transport packaging deserves particular attention

For rigid empty packaging, such as crates or pallets, the manufacturer is generally considered to be the company that manufactures it in its final form and first places it on the market. This makes the company responsible for conformity assessment and drawing up the EU declaration of conformity.

A different situation may arise with flexible materials, such as stretch films or strapping.

These materials often acquire their final function as packaging only when the product is actually packaged. The film or strapping manufacturer may therefore act as a supplier of packaging material, while the company that uses the material to package its product may assume the role of manufacturer and, depending on the specific situation, additional obligations as well.

For packaging or packaged products imported from third countries, it is also necessary to check whether the company is also acting as an importer.

The PPWR will gradually tighten packaging requirements

Over the coming years, further requirements will be introduced gradually concerning packaging design for recycling, the use of recycled materials, reusable packaging and extended producer responsibility.

For plastics manufacturers and processors, it will therefore become increasingly important to monitor not only the technical properties of packaging materials, but also their regulatory status throughout the supply chain.