This material was prepared by the Plan Be Eco team working on ESG compliance and EU regulations. It is based on questions raised by clients, webinar participants and companies implementing PPWR processes in practice.

From 12 August 2026, Regulation (EU) 2025/40 on packaging and packaging waste — PPWR — applies across the European Union.

Because PPWR is an EU Regulation, it applies directly in Member States and does not require transposition into national law.

This does not mean, however, that every PPWR requirement started to apply on the same date. Different obligations follow different timelines. Some requirements are already relevant from August 2026, while others — including certain labelling, recyclability, recycled content and reuse requirements — will apply later.

For companies, the key tasks today are to determine their role in the supply chain, identify the packaging they use and collect the necessary technical data and documentation from suppliers.

PPWR in 60 seconds

PPWR covers packaging placed on the EU market — including sales packaging, grouped packaging, transport packaging and packaging used in e-commerce.

The scope of obligations depends on the company’s role, including whether it acts as a:

manufacturer,
importer,
distributor,
producer for extended producer responsibility purposes.

In practice, preparing for compliance means:

determining the company’s role for a given business model,
identifying packaging types and their components,
collecting technical data and documents from suppliers,
linking those data to the correct packaging types and products,
preparing and maintaining the required compliance documentation.

For most organisations, the real challenge is not creating one document. It is maintaining reliable and up-to-date data across hundreds or thousands of products, components and suppliers.

Key PPWR deadlines

Area	Legal basis	When it becomes relevant
Substances in packaging	Article 5	from 12 August 2026, depending on the specific requirement
Conformity assessment, Declaration of Conformity and Technical Documentation	Article 15 and Annexes VII–VIII	from 12 August 2026
Compostability of selected packaging categories	Article 9	according to the requirements for the relevant packaging category
Packaging labelling	Article 12	generally from 2028, according to the PPWR timetable
Packaging minimisation	Article 10	key requirements from 2030
Recyclability	Article 6	from 2030
Minimum recycled content in plastic packaging	Article 7	from 2030, with further targets in later years
Reuse and refill targets	Article 29 and related provisions	mainly from 2030, depending on the packaging category

Important: PPWR follows a multi-stage implementation timeline. For any specific packaging case, companies should review not only the Regulation itself, but also the relevant scope, exemptions and applicable delegated or implementing acts.

1. Does PPWR apply to my company?

What is PPWR?

PPWR stands for Packaging and Packaging Waste Regulation and refers to Regulation (EU) 2025/40 on packaging and packaging waste.

It replaces the previous framework based on Directive 94/62/EC and introduces harmonised requirements across the EU concerning, among other things:

packaging composition,
packaging design,
recyclability,
recycled content,
labelling,
reuse,
conformity documentation.

The key formal difference is simple:

PPWR is an EU Regulation, not a Directive.

That means its provisions apply directly across Member States.

Who is covered by PPWR?

PPWR applies to packaging placed on the EU market and assigns different obligations to different actors in the supply chain.

Depending on the specific case, a company may act as a:

manufacturer,
importer,
distributor,
producer within the meaning of extended producer responsibility rules.

A company’s role — not simply its size — determines the scope of its obligations.

That means the first question should not be:

“Are we a large company?”

but rather:

“What role do we play for this specific packaging and product?”

Can a micro-enterprise or sole trader also fall under PPWR?

Yes.

Being a small business does not automatically exempt a company from PPWR.

The relevant obligations depend mainly on what the business does with the packaging or packaged product and how that product is made available on the market.

For smaller companies, one of the biggest challenges can be obtaining reliable technical data from suppliers.

For that reason, PPWR data requirements should increasingly become part of standard procurement requirements and supplier qualification processes.

Example: we import cosmetics from outside the EU. Does PPWR apply?

“We are an 8-person e-commerce company. We import finished cosmetics in packaging from South Korea and sell them in Poland. We do not manufacture the packaging ourselves. Does PPWR apply to us?”

Yes — this business model may mean that the company acts as an importer under PPWR.

It is therefore not enough to assume that only the foreign packaging manufacturer is responsible.

The importer has its own obligations, including obligations related to verifying conformity and the relevant documentation.

We buy packaging and pack our own products. Who is responsible?

That depends on the specific business model.

If a company produces the packaged product under its own name or trademark, or is responsible for having the packaging manufactured, it may assume obligations associated with the manufacturer role.

This means companies should not rely on the assumption:

“We bought the packaging from a supplier, so all responsibility lies with them.”

The packaging supplier may provide technical data such as:

material composition,
weight,
recycled content,
test results,

but the company using those data must still understand the obligations arising from its own role.

2. PFAS, BPA and heavy metals — what does Article 5 cover?

Which substances are restricted under PPWR?

Article 5 PPWR introduces requirements concerning substances of concern in packaging.

Three areas attract particular attention:

PFAS — PPWR introduces limits for packaging intended to come into contact with food,
heavy metals — the combined concentration of lead, cadmium, mercury and hexavalent chromium is subject to a limit,
BPA — its use is also regulated under separate EU legislation concerning food-contact materials.

For PFAS, PPWR includes, among others, the following thresholds:

25 ppb for any individual PFAS measured by targeted analysis,
250 ppb for the sum of PFAS measured as the sum of targeted PFAS analysis,
50 ppm for PFAS expressed through total organic fluorine, subject to the conditions laid down in the Regulation.

For heavy metals, PPWR maintains a combined limit of 100 mg/kg for lead, cadmium, mercury and hexavalent chromium.

Example: a laboratory report shows 30 ppb of one specific PFAS. What does this mean?

If the packaging falls within the scope of the relevant PFAS restriction, the result should be compared with the applicable threshold in Article 5.

Companies should avoid relying solely on a general supplier statement such as:

“PFAS free”.

More useful evidence is documentation showing:

what exactly was tested,
which method was used,
what the result was,
which material or component the test relates to,
whether the document can be linked to the packaging currently in use.

What if the supplier refuses to disclose the full formulation?

PPWR does not automatically mean that the buyer must receive the supplier’s full proprietary formulation.

What is needed is sufficient evidence of conformity and enough information to document that conformity.

Depending on the requirement, this may include:

supplier declarations,
material specifications,
laboratory reports,
certificates,
documentation confirming origin and material properties.

The key is to link the evidence to the relevant component or packaging type.

3. Recycled content: PCR, PIR and minimum recycled content

What is the difference between PCR and PIR?

PCR — post-consumer recycled material — is recycled material derived from waste generated after a product has been used by the end user.

PIR — post-industrial recycled material, often discussed more broadly as pre-consumer material, refers to material recovered earlier in production or industrial processes.

This distinction matters because PPWR minimum recycled content targets for plastic packaging refer to recycled material originating from post-consumer plastic waste.

So a statement such as:

“The packaging contains 40% recycled material”

is not sufficient by itself.

The company should know:

what kind of recycled material it is,
how its share has been calculated,
how the declared percentage is evidenced.

Our supplier says the packaging contains 40% recycled material. What should we ask?

Do not ask only:

“How much recycled material does the packaging contain?”

Ask instead:

“What percentage is post-consumer recycled material, and what documentation supports this value?”

Depending on the supply chain, the evidence may include material documentation or documentation from an appropriate certification or traceability system.

When do minimum recycled content requirements apply?

The key mandatory recycled content targets begin to apply from 2030, with further targets set for later years.

That does not mean companies should wait until 2029 to start collecting data.

For organisations managing hundreds of suppliers and thousands of packaging components, it is already useful to collect information about:

material type,
PCR content,
source of the data,
supporting documentation.

4. PPWR Declaration of Conformity and Technical Documentation

What is the PPWR Declaration of Conformity?

The EU Declaration of Conformity — DoC — is the document through which conformity of packaging with the applicable requirements of Articles 5–12 PPWR is declared.

Its model is set out in Annex VIII to the Regulation.

The Declaration should allow the packaging covered by it to be clearly identified.

Do we need a separate DoC for every SKU?

Not necessarily.

The key requirement is the ability to clearly identify the packaging or packaging type covered by the Declaration.

In practice, one DoC may be linked to multiple products or SKUs if those products use the same packaging type and the company can clearly demonstrate that link.

This is particularly important for large product catalogues.

A company may have:

20,000 SKUs,
500 genuinely different packaging configurations,
a few hundred recurring components.

That is why an effective PPWR process should be built primarily around components and packaging types, rather than by manually duplicating the same data across every SKU.

Example: we have 2,000 beverage SKUs. Do we need 2,000 Declarations?

You should not automatically assume that the number of Declarations must equal the number of SKUs.

If many products use the same packaging configuration, the underlying data can often be reused.

For example:

500 ml PET bottle + HDPE cap + label

may be used across many flavour variants.

The key is to correctly identify the packaging type and be able to demonstrate which products are covered by it.

What is the difference between Technical Documentation and the DoC?

Technical Documentation — TD — provides the evidence supporting the conformity assessment.

It may include:

a description of the packaging,
its design and construction,
materials and components,
data required to assess compliance with PPWR,
standards or technical specifications applied,
test results, calculations and assessments,
supplier documentation.

The DoC is the declaration. Technical Documentation is the evidence behind it.

This means that generating a PDF alone does not solve the compliance problem if the company does not have the underlying data needed to support the declaration.

Does the DoC have to be signed with a Qualified Electronic Signature?

PPWR does not establish a general requirement for the Declaration of Conformity to be signed using a Qualified Electronic Signature — QES.

Annex VIII requires the Declaration to be signed on behalf of the relevant economic operator, but it does not prescribe a specific electronic signature technology.

A company may of course decide to use QES as part of its internal document approval process — for example to improve signatory identification, document integrity and governance.

How long should the documentation be retained?

The required retention period depends on the packaging type and on the role of the relevant economic operator.

Instead of applying one universal archiving rule to all cases, it is more effective to link retention requirements to the relevant packaging type, role and document history.

5. Recyclability, minimisation and reuse — what changes by 2030?

Do recyclability classes already apply in 2026?

No.

PPWR introduces design-for-recycling requirements whose key obligations will start to apply from 2030.

The Regulation provides for recyclability performance grades A, B and C.

Companies designing packaging today with a multi-year lifecycle should therefore already consider future recyclability requirements — particularly where changing packaging design, materials or suppliers involves long development lead times.

Is it worth collecting recyclability data now?

Yes.

Not because every 2030 requirement already applies today, but because much of the relevant information is held by the same suppliers from whom companies are already collecting data on:

materials,
weights,
composition,
recycled content,
adhesives,
labels,
barriers,
coatings,
other structural features.

Collecting those data through one process is far more efficient than repeatedly contacting the same suppliers whenever a new regulatory milestone approaches.

What about reusable packaging?

PPWR also introduces reuse and refill targets for specific packaging categories.

Their relevance depends strongly on the packaging type and business model.

They can be particularly important for selected:

transport packaging,
grouped packaging,
B2B packaging systems.

Companies should not assume that one reuse target applies equally to every type of packaging.

What about packaging minimisation?

PPWR also aims to reduce unnecessary packaging weight and volume.

For companies, this means being increasingly able to justify packaging design and avoid components or empty space that are not necessary for the packaging to perform its functions.

This is especially relevant when designing new packaging because decisions taken today may affect compliance in 2030 and beyond.

6. PPWR already applies. What should companies do now?

If you are only starting the process, do not begin by manually preparing hundreds of Declarations.

Start by structuring your data.

Step 1. Determine your PPWR roles

The same company may play different roles for different products and business models.

You should analyse, among other things:

who manufactures the packaging or packaged product,
under whose name or trademark it is marketed,
where the product comes from,
who first makes it available on a given market,
whether sales are made directly to end users,
whether the product is imported from outside the EU.

Without correctly identifying the role, it is difficult to determine the right compliance obligations.

Step 2. Build a component catalogue

Instead of starting with SKUs, go one level deeper.

Typical packaging components include:

bottle,
cap,
label,
folding carton,
insert,
film,
tray,
tape,
pallet.

Technical data and supplier documentation can be stored at component level and then reused across multiple packaging configurations.

Step 3. Create packaging types

Components can be combined into recurring packaging configurations, for example:

500 ml PET bottle + HDPE cap + PP label

That packaging type can then be linked to multiple SKUs.

This reduces duplication and makes change management much easier.

Step 4. Send standardised requests to suppliers

Avoid collecting PPWR information through dozens of separate email conversations.

A supplier should know exactly:

which component or SKU the request concerns,
what data are required,
which documents should be provided,
by what date,
which fields are still missing.

Step 5. Manage data completeness

The key question is not:

“Did we send the request?”

but:

“For which packaging do we already have enough data to demonstrate compliance?”

Answering this requires linking supplier information to specific components, packaging types and products.

7. What if the supplier does not provide the required data?

The supplier is not responding. Does that solve our responsibility problem?

No.

Missing supplier data is not evidence of packaging conformity.

Supplier responses should therefore be managed in the same way as other critical procurement processes — with:

deadlines,
reminders,
completeness status,
clear internal ownership.

For new contracts, companies should also define the required PPWR data and documentation at the commercial terms stage.

What if the supplier sent a document two years ago?

You need to know whether it still applies to the component currently being purchased.

A change in:

material,
formulation,
raw material source,
recycled content,
supplier,
production site,
component construction,

may mean that the documentation needs to be reassessed.

The important thing is therefore not only having a file, but also being able to track versions and determine which version of a component the document relates to.

8. Does PPWR replace BDO, EPR or the deposit return system?

No.

PPWR does not eliminate other packaging and packaging-waste obligations.

In Poland, companies continue to operate within a broader framework that may include:

BDO,
extended producer responsibility,
national reporting obligations,
the deposit return system where applicable.

PPWR adds and harmonises another layer of requirements at EU level concerning the packaging itself, its properties and conformity.

The positive side is that some data can be reused across several regulatory processes.

If the company has reliable data on:

component weight,
material type,
product quantities,
market,
volume,

those data may support more than one compliance workflow.

9. How does PPWR work in Plan Be Eco?

Managing a few packaging items manually may be possible.

The challenge begins when an organisation has:

hundreds of suppliers,
thousands of SKUs,
recurring components,
multiple document versions,
changing supplier data,
several people responsible for different product groups.

That is why Plan Be Eco structures the process around:

supplier → component → packaging type → SKU → documentation

Ask a supplier about a component or an entire SKU

Users can send requests concerning a specific component or a whole product.

Depending on the company’s PPWR role, the process can be used to:

collect technical component data,
collect supporting documentation,
obtain information required for the company’s own conformity process,
obtain existing Declarations for products purchased from suppliers.

Suppliers use a free supplier portal

The supplier receives an invitation to the free Plan Be Eco supplier portal, where they can see all requests addressed to them concerning SKUs and packaging components.

They can:

provide the required data,
add components,
create packaging types,
upload documents,
respond to customer requests.

This prevents critical information from getting lost across individual email inboxes.

Reuse component data across multiple products

If the same component is used in 200 products, there is no reason to collect the same information 200 times.

Data stored at component level can be used across multiple packaging types and SKUs.

If those data change, the system makes it possible to identify which packaging and products are affected.

The system takes the PPWR role into account

PPWR obligations are not identical for every company.

Plan Be Eco therefore allows the organisation to define its role and structure the process and tasks around the relevant products.

Assign products to team members

Individual SKUs or groups of products can be assigned to specific people.

This makes it easier to see:

who owns the product,
where data are missing,
which supplier has not yet responded,
which products require further action.

Share a document catalogue with customers

Documents do not need to be sent manually in separate emails.

Plan Be Eco enables companies to organise and share documents for selected products while controlling access to the relevant scope of information.

10. How long does it take to prepare a Declaration of Conformity in Plan Be Eco?

In most organisations, the time-consuming part is collecting and structuring the data, not creating the final document.

If:

components have already been described,
supplier data are complete,
the packaging type has been created,
the required information is available in the system,

generating a Declaration of Conformity can take less than 15 minutes.

That is why the Plan Be Eco process starts with structured source data rather than editing another Word or Excel file.

11. What does the Plan Be Eco PPWR module generate?

Based on the data collected in the system, Plan Be Eco supports the preparation of:

EU Declaration of Conformity — DoC,
Technical Documentation — TD,
component data and document catalogues,
documentation linked to packaging types and products.

Documents can be generated as PDFs and stored together with the underlying data used to prepare them.

If the organisation uses a Qualified Electronic Signature as part of its own internal approval process, the generated document can subsequently be signed in accordance with that procedure.

12. Can PPWR data be reused in other processes?

Yes — and this is one of the strongest reasons to create a single source of truth for packaging data.

Information about:

materials,
weights,
components,
suppliers,
volumes,

may be needed not only for PPWR.

If the organisation also uses Plan Be Eco modules related to WFD/EPR or GHG Product / PCF, the same source data can be reused across multiple processes instead of being collected again from scratch.

13. Frequently asked practical questions

Does PPWR apply to e-commerce?

Yes.

Online sales are not automatically exempt from PPWR.

Depending on the case, companies may need to consider both:

the product packaging,
packaging used for shipment and fulfilment.

The scope of responsibility depends on the seller’s role and business model.

Does PPWR apply to transport packaging?

Yes.

PPWR covers more than consumer-facing sales packaging.

It also applies to other packaging categories, including transport packaging.

However, different requirements, targets or exemptions may apply depending on the packaging type.

Does PPWR apply to pallets?

Pallets can fall within the definition of packaging under PPWR.

Their treatment depends on the specific model of use, including whether they are:

single-use,
reusable,
used in closed or open transport systems.

Does a distributor have to prepare its own DoC?

You should not assume that every distributor must prepare its own Declaration.

PPWR imposes obligations on distributors, including checking certain conformity conditions before making packaging available on the market.

If a distributor has reason to believe that packaging is not compliant, it should not make that packaging available until the non-conformity has been addressed.

Who prepares the underlying documentation and Declaration depends on the roles of the different actors in the specific supply chain.

Can an importer simply rely on the supplier’s Declaration from outside the EU?

An importer has its own obligations to verify conformity.

Receiving documentation from a non-EU supplier is an important part of the process, but the importer should ensure that:

the documentation relates to the correct packaging,
it is current,
it supports the requirements applicable in the EU.

Does changing the label mean we need completely new documentation?

It depends on the nature of the change.

A label is a packaging component, so changing its:

material,
weight,
adhesive,
surface area,
construction,

may affect the characteristics of the packaging as a whole.

A purely graphic change does not automatically mean that the entire compliance process must be repeated.

The key is version control and determining whether the change affects data relevant to conformity.

Can one DoC cover multiple products?

Yes, where the packaging type covered by the Declaration can be clearly identified and the company can demonstrate which products use that packaging type.

This can significantly reduce document duplication in large product catalogues.

14. Where should a company start with PPWR implementation?

If the entire process had to be reduced to five steps:

1. Determine the roles

Identify the PPWR role for each relevant procurement and sales model.

2. Inventory packaging components

Do not begin by creating thousands of unrelated SKU records if the same packaging elements are repeatedly used.

3. Build packaging types

Combine components into the actual packaging configurations used for products.

4. Collect supplier data

Gather technical data and documents in a standardised way and track missing information.

5. Prepare documentation only once the data are structured

The Declaration of Conformity should be the result of a controlled data process — not a document created in isolation from the underlying evidence.

PPWR is not just another PDF

The biggest PPWR risk is not the lack of a Declaration template.

It is a situation where the company:

does not know which packaging a document relates to,
cannot identify the source of the data,
relies on outdated supplier declarations,
stores different document versions across email inboxes,
cannot identify which SKUs use a changed component,
has to manually update hundreds of records after every supplier change.

That is why a robust compliance process should begin with one structured source of packaging data.

Plan Be Eco connects suppliers, components, packaging types, SKUs and documentation in one workflow — making PPWR operationally manageable even across thousands of products.

Do you have a specific case and are unsure what role your company plays or which data you should collect?

Sources and legal basis

Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste.
European Commission guidance concerning the application of Regulation (EU) 2025/40.
Related EU legislation concerning food-contact materials and restricted substances.

This material is provided for general informational purposes and does not constitute individual legal advice. Obligations should always be assessed in relation to the specific packaging, product, economic operator role and distribution model.