Here we inform you as compactly as possible about the implementation of the PPWR in practice. Please note This information has been compiled to the best of our knowledge and belief and does not constitute legally binding information.
The theory
- PPWR = Packaging and Packaging Waste Regulation
- Formal designation: EU Packaging Regulation VO (EU) 2025/40
- Replaces the previous Packaging Directive RL 94/62/EC
- Realisation in steps, First duties from 12 August 2026
- Valid throughout Europe, national peculiarities possible
Which packaging is affected?
- All packaging:
- Shipping packaging e.g. shipping parcels
- Sales packaging e.g. games box, cosmetics box
- Transport packaging e.g. shipping carton, pallet
Who is obliged to do something?
In the PPWR there are five rolls. The role determines which duties must be fulfilled.
Unfortunately, the role allocation is not always clear. In addition, the naming of the roles is not conclusive. For example, the producer is not automatically the person who manufactures the packaging. Double assignments are possible, e.g. a „manufacturer“ can also be a „producer“ at the same time. ....
Roles in the PPWR
Supplier
The person who uses packaging or packaging material to a producer.
Hertel cardboard packaging
Producer
The person who manufactures packaging or under his name can be produced.
Manufacturer
The one who packs for the first time for the finalr in Germany or the EU. Can be a supplier, producer or importer.
Importer
The person who packs from a third country is placed on the market.
Distributor
The one who packs on the market, except producer or importer.
Obligations in the PPWR
Supplier
- Providing the information
Producer
- Conformity assessment
- Technical documentation
- Declaration of Conformity
- Labelling of the packaging
Manufacturer
- Extended producer responsibility
- Manufacturer registration
Importer
- Ensuring the conformity assessment
- Maintaining conformity during handling
Distributor
- Duty of care
What specific obligations must be fulfilled from 12.08.2026?
Requirements for substances in packaging
- Limit values for heavy metals: The total concentration of lead, cadmium, mercury and chromium VI in packaging must not exceed 100 mg/kg.
- Limit values PFAS (only in food packaging)
Duty of suppliers to provide information
- For the purposes of the PPWR, you are the producer of the packaging we produce. We provide you with all the necessary information so that you can prove the conformity of the packaging.
Labelling of packaging
In terms of the PPWR, you are the producer of the packaging we produce and must ensure that the labelling is affixed to your packaging:
- Identification feature, e.g. batch number or serial number
- Contact information of the manufacturer (name, brand, address); optional QR code
EU Declaration of Conformity
The responsibility for this declaration lies with the producer.
Technical documentation
- The technical documentation must contain
- Identification Unique identification number, technical drawings/photos, description
- Intended use of the packaging
- Test reports
- Conformity assessment procedure
