PPWR Compliance: Obligations of Every Economic Operator and a Step-by-Step Plan

PPWR compliance means that every economic operator in the packaging supply chain meets its own duties under Regulation (EU) 2025/40, which applies since 12 August 2026: the manufacturer proves conformity, the others check, pass on information and keep records. The Regulation (CELEX 32025R0040, OJ L, 2025/40, 22.1.2025) entered into force on 11 February 2025, and Chapter IV (Art. 15 to 22) gives each of seven operator roles a separate list of obligations.

Who has to comply? Every company that makes, supplies, imports, distributes or handles packaging or packaged goods on the Union market, whether established in the EU or selling into it from a third country. The operator duties of the PPWR, the EU Packaging and Packaging Waste Regulation, apply since 12 August 2026, and the corrective duties of a manufacturer reach back to packaging placed on the market from 11 February 2025.

This page defines PPWR compliance, sets out the obligations of each economic operator, names the two documents that prove conformity and the record every operator keeps, gives a 10-step plan with the dated rules, and explains how national authorities enforce the Regulation. Every rule cites its article; case-by-case questions go to the competent authority of the Member State concerned.

Compiled by the PackagingRegulation.org Editorial Team from the Regulation's text on EUR-Lex and the cited official sources. Every date and article reference is checked; see our methodology and fact-checking.

What Does PPWR Compliance Mean for a Business?

Under Article 4(1) of the PPWR, packaging may be placed on the market only if it complies with the Regulation, and placing on the market means its first making available on the Union market (Art. 3(1)(10)). PPWR compliance is the sum of the duties a company holds in its role for each packaging unit: proving conformity as manufacturer, or checking, informing and keeping records as any other operator.

The PPWR names seven economic operators in Article 3(1)(12), listed below.

• Manufacturer: makes packaging or a packaged product, or has it made and markets it under its own name or trademark (Art. 3(1)(13)).
• Supplier: supplies packaging or packaging material to a manufacturer (Art. 3(1)(16)).
• Importer: established in the Union and places packaging from a third country on the Union market (Art. 3(1)(17)).
• Distributor: any person in the supply chain, other than the manufacturer or importer, that makes packaging available (Art. 3(1)(18)).
• Authorised representative: acts for the manufacturer on product compliance under a written mandate (Art. 3(1)(19)).
• Final distributor: delivers packaged products to the end user, including through re-use or refill (Art. 3(1)(21)).
• Fulfilment service provider: as defined in Art. 3(11) of Regulation (EU) 2019/1020.

One company can hold several roles at once. A brand owner is the manufacturer for product compliance and, under Art. 3(1)(15), often also the producer for EPR in each Member State where it first makes packaging available. A micro-enterprise brand owner is the exception: where its supplier is in the same Member State, the supplier is the manufacturer (Art. 3(1)(13)(b)), and Art. 15(12) extends the shift to a supplier located in the Union. Which packaging falls under these rules is explained in PPWR scope.

Is there a PPWR certificate or CE marking?

No: PPWR conformity is shown by the manufacturer's own Module A internal production control under Article 38 and Annex VII, with no notified body, no PPWR certificate and no CE marking for the PPWR (recital 109). A CE marking on packaging therefore says nothing about PPWR compliance; it may relate to other EU product rules for the packed product. The manufacturer itself signs the EU declaration of conformity and, by drawing it up, assumes responsibility for compliance (Art. 39(4)). A third-party test report can feed the technical documentation as evidence, but it never replaces the declaration.

PPWR Obligations of Every Economic Operator since 12 August 2026

Since 12 August 2026 Chapter IV of the PPWR gives each economic operator its own duties: the manufacturer under Art. 15, the supplier under Art. 16, the authorised representative under Art. 17, the importer under Art. 18, the distributor under Art. 19 and the fulfilment service provider under Art. 20. Article 21 adds that an importer or distributor becomes the manufacturer when it places packaging on the market under its own name or trademark, or modifies packaging in a way that could affect compliance.

The table covers PPWR manufacturer obligations, the obligations of suppliers of packaging, the PPWR obligations of importers, the obligations of distributors and retailers, the PPWR for non-EU exporters, and PPWR penalties and market surveillance, each with its core duty.

Which Documents Prove PPWR Compliance?

Two documents prove PPWR compliance: the technical documentation under Annex VII, which holds the evidence, and the EU declaration of conformity under Article 39, by which the manufacturer assumes responsibility (Art. 39(4)). The technical documentation contains a general description and intended use, design and material details, the standards or specifications applied, a qualitative description of the assessments under Art. 6, 10 and 11, test reports (Annex VII point 2(a) to (f)) and an analysis of the risks of non-conformity.

The declaration follows the model of Annex VIII with 8 numbered points, is drawn up for each packaging type, is kept up to date and is written in or translated into the language the Member State requires (Art. 39(2)). Competent authorities endeavour to check the accuracy of at least part of the declarations each year on a risk basis (Art. 39(5)). The table covers PPWR technical documentation and conformity assessment, the PPWR EU declaration of conformity and the two records that support them.

A missing or incorrect declaration, or technical documentation that is missing, incomplete or erroneous, is formal non-compliance under Art. 62(1)(a), (b) and (d), and persisting cases lead to prohibition, recall or withdrawal (Art. 62(2)). How standards give a presumption of conformity is explained in PPWR harmonised standards.

How long must PPWR documents be kept and how fast produced?

Technical documentation and the EU declaration of conformity are kept for 5 years for single-use and 10 years for reusable packaging from placing on the market (Art. 15(3)), and manufacturers, authorised representatives and importers hand documents over within 10 days of a reasoned request (Art. 15(10), 17(2)(d), 18(8)). The same 5 and 10 years apply to the authorised representative (Art. 17(2)(a)), to the importer's copy of the declaration (Art. 18(7)) and to Annex VII point 4. Distributors also provide information and documentation on a reasoned request, but Art. 19(6) sets them no 10-day limit.

Identification of economic operators under Article 22

Article 22 of the PPWR obliges every economic operator to identify, on request of a market surveillance authority, the suppliers that supplied it with packaging and the economic operators it supplied, for 5 years (single-use) or 10 years (reusable). The duty applies to distributors and fulfilment service providers as much as to manufacturers.

The Art. 22 record lets an authority trace a non-compliant packaging type through the chain. Market surveillance runs under Regulation (EU) 2019/1020, to whose Annex I Art. 66 PPWR adds the PPWR, and a manufacturer's corrective action covers packaging placed on the market from 11 February 2025 (Art. 15(8)).

How to Comply with the PPWR: A Step-by-Step Plan

A company complies with the PPWR by identifying its role for each packaging unit, gathering supplier evidence, checking the requirements in force, documenting conformity, marking the packaging, registering for EPR where it is the producer and keeping records ready for the authorities. The 10 steps are listed below, each with its article.

1. Identify your role for each packaging unit and each Member State: manufacturer, importer, distributor or another Art. 3(1)(12) operator, and whether you are also the producer under Art. 3(1)(15); the PPWR applicability check walks through the roles.
2. List your packaging types; in the Commission's reading a type is a format or batch, and the declaration covers the whole packaging unit (Commission's PPWR FAQ, non-binding, section XV).
3. Request supplier documentation under Art. 16(1), including the contact-sensitive documentation of Art. 16(2); suppliers draw up no declaration but cannot refuse the documentation (Commission's PPWR FAQ, section X).
4. Check the requirements in force now: the sum of lead, cadmium, mercury and hexavalent chromium of at most 100 mg/kg in all packaging (Art. 5(4)), and the PPWR PFAS limits for food-contact packaging: 25 ppb for any single PFAS, 250 ppb for the sum of targeted PFAS and 50 ppm for total PFAS, since 12 August 2026 (Art. 5(5)).
5. Carry out the Module A conformity assessment and draw up the Annex VII file (Art. 15(2), Art. 38); the assessment may be done on your behalf, but the Art. 15(1) duty and drawing up the file cannot form part of an authorised representative's mandate (Art. 17(2)).
6. Draw up the EU declaration of conformity on the Annex VIII model, one per packaging type (Art. 39).
7. Mark identification and contact details: type, batch or serial number (Art. 15(5)) and your name, trademark, postal and electronic contact on the packaging, a data carrier or an accompanying document (Art. 15(6)); importers add their own (Art. 18(3)).
8. Register in each Member State where you are the producer and report by 1 June for the preceding calendar year (Art. 44, 44(7)); national formats apply because the Art. 44(14) act is not adopted as of 24 October 2026, as set out in PPWR producer registration and reporting.
9. Keep the file, the declaration and the Art. 22 supplier and customer record for 5 or 10 years, ready to hand over within 10 days of a request (Art. 15(3), 15(10)).
10. Track the dated rules in the table below and update the file and declaration as each applies.

The plan is a reading aid that follows the order of the Regulation, not a legal checklist; it does not confirm that a given packaging complies.

Which PPWR rules apply now and which come later?

The operator duties, the conformity documents, the PFAS limits and the heavy-metal limit apply since 12 August 2026, while the harmonised label, the recyclability grades, recycled content, the empty space ratio, the Annex V restrictions and the re-use targets follow from 2028 and 2030, several only after a Commission act. What applied on the general application date is set out in PPWR since 12 August 2026; the table lists each dated rule, oldest first.

The only PPWR delegated act adopted as of 24 October 2026 is Delegated Decision (EU) 2026/429, and no implementing act exists; the 2030 dates are explained in PPWR 2030 deadlines.

What happens to packaging already on the market or in stock?

Packaging placed on the market before 12 August 2026 may stay on the market, according to the Commission's non-binding reading, but there is no sell-off period for the PFAS limits. Packaging produced and in stock but not yet placed on the market by that date need not be destroyed or relabelled, and the Art. 15(5) and (6) identification and contact data may travel in an accompanying document (Commission Notice C/2026/3084 and the Commission's PPWR FAQ, section X). Corrective duties under the Regulation itself reach further back: a manufacturer brings into conformity, withdraws or recalls non-compliant packaging placed on the market from 11 February 2025 (Art. 15(8)). Reusable packaging placed on the market before 11 February 2025 is exempt from that corrective duty (Art. 15(9)).

How Do National Rules and Enforcement Fit In?

The PPWR is a regulation, so its operator duties apply directly in every Member State; a Member State may not prohibit, restrict or impede packaging that complies with Articles 5 to 12 (Art. 4(2) PPWR). National sustainability or information requirements must not conflict with the Regulation (Art. 4(3)), and no national implementing act is needed for the Chapter IV duties to bind operators.

Enforcement stays national. Member States notified their competent authorities by 12 July 2025 (Art. 40(3)), and market surveillance authorities act under Regulation (EU) 2019/1020. Formal non-compliance runs in two tiers: persisting documentation and identification failures under Art. 62(1)(a) to (f) lead to prohibition, recall or withdrawal (Art. 62(2)), while persisting breaches of Art. 6, 7, 24, 25, 27, 28, 29, 32 and 33 under points (g) to (n) lead to penalties under Art. 68 (Art. 62(3)). Member States lay down and notify their penalty rules by 12 February 2027, administrative fines are mandatory for breaches of Art. 24 to 29, and the PPWR itself sets no fine amount (Art. 68).

The EPR layer adds national registers: a producer registers in each Member State where it first makes packaging available (Art. 44) and, where it falls under Art. 3(1)(15)(c) or (d), appoints an EPR authorised representative there (Art. 45(3)). Registers, authorities and national EPR rules are compared in PPWR in the 27 member states.

How Does PPWR Compliance Connect to the Rest of the Regulation?

PPWR compliance rests on the product requirements of Chapters II and III, which the documents prove, and sits beside the EPR duties of Chapter VIII, which a producer meets in each Member State. The table connects compliance to the PPWR legal text, the PPWR timeline, the PPWR requirements for packaging, the PPWR reuse targets, EU packaging EPR under the PPWR, EU packaging waste and the comparison of the PPWR vs the Packaging Directive 94/62/EC.

This page covers the EU rule only; packaging regimes outside the EU are not explained here. Food-contact documentation under the EU food contact materials rules is covered on foodcontactmaterials.net.

Two authorised representatives: Article 17 and Article 45(3)

The PPWR has two authorised representatives: the optional product-compliance representative of Art. 17, established in the Union with a written mandate from the manufacturer, and the EPR representative of Art. 45(3), established in the Member State concerned. The Art. 45(3) representative is mandatory for producers under Art. 3(1)(15)(c) and (d). The Commission proposal COM(2025) 982 would suspend it; the European Parliament adopted amendments on 20 October 2026 and referred the file back to the ENVI committee, and nothing is suspended as of 24 October 2026. When the EPR one is mandatory is explained under authorised representative for EPR under the PPWR.

What the Commission guidance and FAQ say about compliance

Commission Notice C/2026/3084 (OJ C, 10.6.2026) and the Commission's PPWR FAQ (non-binding) explain the operator duties, the FAQ in sections X and XV; where either differs from the Regulation, the Regulation wins. The FAQ, 2nd edition (August 2026), covers manufacturer and supplier duties in section X and conformity assessment in section XV, while the Notice is the Commission's guidance document. Both documents are compared in PPWR guidance and FAQ.

PPWR compliance questions answered

Does a micro-enterprise have to comply with the PPWR?

Yes: there is no general exemption, but where a micro-enterprise has its packaging made under its own name by a supplier located in the Union, the supplier is the manufacturer for Art. 15 (Art. 15(12)). A micro-enterprise has fewer than 10 persons and a turnover or balance sheet total not above EUR 2 million (Recommendation 2003/361/EC); the supplier shift is explained in PPWR rules for micro-enterprises.

Can a consultant or laboratory carry out the conformity assessment?

Yes: the manufacturer may have the conformity assessment carried out on its behalf (Art. 15(2)), but stays responsible and cannot hand the Art. 15(1) duty or the drafting of the technical documentation to an authorised representative (Art. 17(2)).

Does transport packaging need its own declaration of conformity?

Yes, in the Commission's reading: transport packaging has no exemption, and pallets, collars, wrappings and straps each need an assessment and declaration (Commission's PPWR FAQ, section XV).

Is any packaging exempt from the technical documentation?

Only one case: Art. 15(2) and (3) do not apply to custom-made transport packaging for configurable medical devices and medical systems used in industrial and healthcare environments (Art. 15(11)). Sector rules are in PPWR for pharmaceuticals and medical devices.