What is PPWR?
The act applies to all packaging placed on the market and outlines requirements for its entire lifecycle, with a particular focus on design, disposal, and material circularity. Its primary goal is to reduce the volume of packaging and packaging waste across all business activities. From now on, packaging must be designed in a way that facilitates recycling and material recovery, allowing materials to be reused as recyclate. Another significant change is the development and integration of reuse systems through the introduction of harmonized requirements across the entire European Union. This is intended to accelerate the gradual transition of member states to a circular economy model. The regulation applies to all economic operators that place packaging on the market or use it as part of their business operations within the European Union. This includes both companies that manufacture packaging and those that purchase it to package their products.
Roles under PPWR
It is crucial to identify your role regarding packaging, as your obligations are based on it. The regulation defines seven roles: supplier, manufacturer, importer, distributor, authorized representative, final distributor, and fulfillment service provider.
- Supplier provides the manufacturer with packaging or packaging material and supplies the documentation necessary to demonstrate compliance with PPWR requirements.
- Manufacturer is responsible for the packaging's compliance with the regulation, prepares technical documentation, and issues the EU declaration of conformity.
- Importer places packaging from outside the European Union on the market and must verify its compliance with the PPWR and ensure the required documentation is in place.
- Distributor makes packaging available on the market and is required to ensure that it meets the regulation's requirements.
- Authorized representative performs tasks on behalf of the manufacturer as specified in the mandate, but does not assume the manufacturer's responsibility for the packaging's compliance.
- Final distributor provides products in packaging to the end user and fulfills obligations related to reusable packaging, refilling, and informing users.
- Service provider ensures that the conditions under which packaging is stored do not compromise its properties.
Requirements to be met under the PPWR
Obligations resulting from the PPWR will be introduced gradually. The official effective date for the first requirements is August 12, 2026. From that moment on, every economic operator will be required to fulfill administrative obligations. Furthermore, from August 12, 2026, packaging that comes into contact with foodwill have to meet strict limits regarding the content of specific substances. This applies to the sum of concentrations of lead, cadmium, mercury, and hexavalent chromium, which must not exceed 100 mg/kg. The limits will also cover packaging containing per- and polyfluoroalkyl substances (PFAS).
To meet these requirements, packaging suppliers and manufacturers must verify – through laboratory testing – whether packaging and its components exceed the applicable standards. Who is responsible for conducting the tests depends largely on the contracts in place. Suppliers of packaging or materials are legally obligated to provide the manufacturer with the necessary information. The manufacturer, in turn, bears full responsibility for the packaging's compliance with the regulation and for exercising due diligence.
In practice, this requires cooperation and an open flow of information between these entities. This need exists not only between the supplier and the manufacturer but throughout the entire supply chain. Importers and distributors are also required to act in accordance with the principle of due diligence. They must take appropriate measures to ensure that the packaging they use complies with legal requirements.
Requirements in the coming years
The remaining elements of the PPWR will be implemented gradually over the next 15 years. In addition to the entry into force of some of the regulation's obligations, 2026 will also bring implementing acts regarding harmonized labels, methodologies for determining packaging material composition, and methods for labeling waste containers.
In 2027, a system of penalties for violating the regulation's requirements will be officially introduced. To date, the authorities responsible for verifying compliance with the regulation and imposing sanctions have not been clearly defined. The only information available so far concerns the UC100 draft, which was submitted on August 13, 2025, by the Ministry of Climate and Environment.
Delegated acts are also to be prepared regarding packaging formats intended for reuse and a digital identification system. This is related to the obligation to identify reusable packaging using a QR code or another information carrier. However, these obligations will not enter into force before 2028.
In 2028, reporting obligations related to reuse systems will also be expanded. That same year, rules will be introduced to limit empty space and to design packaging in a way that enables its subsequent recycling.
Two years later, in 2030, all packaging placed on the market will have to be designed to be recyclable in appropriate classes (A–C). From that same year, a minimum recycled content requirement will be introduced. Key provisions:
- packaging intended for sensitive products made of PET must contain a minimum of 30% recycled material,
- packaging made of plastics other than PET must contain a minimum of 10% recycled material,
- plastic beverage bottles must contain a minimum of 30% recycled content,
- other types of packaging will be required to contain a minimum of 35% recycled content.
Our PPWR services
We will prepare your company for the requirements of the PPWR regulation. We will conduct an audit and support you in implementing optimal solutions.
PPWR and the meat industry
The PPWR regulation is of particular importance to the meat industry because the packaging used serves to protect food and, in most cases, comes into direct contact with it.
As a reminder, the first obligations for entities associated with such packaging will take effect as early as August 12, 2026.
Companies use many types of packaging, including unit and grouped packaging, as well as separate and integrated components, such as vacuum films or latches that form part of the packaging. Each of these elements may be subject to a separate assessment regarding PPWR requirements. It will also be crucial to correctly define the role played by the company in relation to specific packaging. In practice, some entities act solely as packaging suppliers, while others are manufacturers within the meaning of the PPWR, which entails a different scope of obligations. In many cases, a single company may fulfill different roles in relation to different packaging or its components. A detailed verification of each type of packaging and the supply chain will be necessary to correctly assign roles and the resulting obligations. This approach will help minimize the risk of misinterpreting the regulations and ensure compliance with the requirements of the regulation.
Time to verify your obligations
July 2026 is the perfect time to go through the verification process to determine your organization's readiness for PPWR requirements. First, you should identify all packaging used and determine its types (the regulation distinguishes four categories of packaging: sales, grouped, transport, and e-commerce) and assign rolesthat your company plays in relation to each of them. The next step should be analyzing the supply chain, informing relevant business partners, and gathering the necessary information and documentation. It is also essential to conduct a detailed analysis of packaging compliance with PPWR requirements and develop internal procedures to manage your obligations on an ongoing basis. It is also worth analyzing the requirements that will be introduced in the coming years to prepare your organization for upcoming changes well in advance.
