PPWR – New Packaging Regulations and Obligations for Packaging Manufacturers and Importers

The PPWR (Packaging and Packaging Waste Regulation) is a new EU regulation governing packaging and packaging waste. It applies directly to businesses in all EU Member States. The key obligations for packaging manufacturers and importers placing packaging on the market will apply from 12 August 2026.

This is not a regulation for some distant future. It sets a specific deadline, after which a lack of PPWR preparedness will become both a regulatory and a business risk.

Who is subject to the PPWR? A major transformation of the packaging market is approaching

The new PPWR rules cover a much broader range of entities than the existing packaging and waste-management legislation.

The new rules apply, among others, to:

• manufacturers of packaged products;
• importers of packaged products from outside the EU;
• companies placing packaged products on the EU market for the first time;
• private-label businesses;
• e-commerce businesses;
• distributors and packaging suppliers in certain circumstances.

If your product is placed on the market in packaging, the PPWR packaging requirements also apply to you. According to Poland’s Waste Database (BDO), approximately 113,000 entities in Poland are registered as placing packaged products on the market.

When do the PPWR requirements apply, and what changes from 12 August 2026?

A new definition of packaging – practical consequences for businesses operating in the packaging market

The PPWR introduces detailed definitions covering virtually all packaging placed on the market, including:

• packaging units;
• separate packaging components;
• transport, service and production packaging.

In practice, items previously overlooked—such as inserts, protective elements and functional components associated with packaging materials—may be classified as packaging within the meaning of the PPWR.

Incorrectly classified packaging means unfulfilled obligations and exposure to PPWR-related penalties.

PPWR obligations for manufacturers under Article 15

If you design a packaged product or commission the design of packaging, Article 15 of the PPWR requires you, from 12 August 2026, to ensure that:

• the PPWR conformity-assessment procedure has been carried out and the required documentation has been prepared;
• the packaging is designed to meet the PPWR’s environmental requirements throughout its life cycle;
• you can provide evidence of the packaging’s PPWR compliance at the request of market-surveillance authorities;
• an EU declaration of conformity has been drawn up for the packaging.

These are not merely strategic PPWR objectives. They are mandatory packaging-design requirements that must be met when packaging is placed on the market under the new rules.

PPWR obligations for importers under Article 18

If you import packaged products from a third country, Article 18 of the PPWR provides that, from 12 August 2026:

• you are responsible for the packaging’s PPWR compliance in much the same way as the manufacturer;
• you must hold documentation demonstrating compliance with the Regulation’s requirements—a supplier’s statement alone is insufficient;
• you must cooperate with market-surveillance authorities if non-compliant packaging is found to have been placed on the market;
• you bear the regulatory risk even where the packaging was designed outside the European Union.

An importer cannot transfer responsibility under the PPWR to a manufacturer established in a third country.

What does the PPWR cover when a product is placed on the market?

Even if you do not manufacture packaging, but sell products under your own brand or import finished products, the PPWR may impose obligations directly on you as the entity placing the packaging on the market.

The broad reach of the PPWR is illustrated by Article 22. From 12 August 2026, it requires economic operators—including manufacturers, packaging suppliers, importers and distributors—to identify every economic operator that has supplied them with packaging or packaged products.

Why is standard PPWR advisory support not enough?

Most services available on the market are based on:

• checklists;
• general interpretations of the new PPWR requirements;
• presentations explaining what the PPWR may mean in a particular case.

Effective PPWR implementation, however, requires packaging to be analysed at the level of individual products and underlying data, rather than through general recommendations.

Our PPWR service – data-driven PPWR advisory

We do not begin with questionnaires and declarations. Our approach to PPWR advisory is different:

• we analyse your portfolio of products and packaging materials;
• we determine which items qualify as packaging under the PPWR;
• we identify the relevant obligations of manufacturers or importers;
• we map regulatory risks ahead of 12 August 2026;
• we prepare the required PPWR documentation.

We provide manufacturers and importers with comprehensive PPWR support, including:

• a compliance review of packaging structures;
• identification of components that do not meet PPWR packaging requirements;
• preparation of the documentary basis needed in the event of an inspection, as part of a PPWR audit;
• identification of areas requiring organisational change as part of preparations for the PPWR in 2026.

How to comply with the PPWR – what do you gain?

• A clear map of your obligations under the PPWR.
• Identification of compliant products and packaging, as well as high-risk items.
• Time to make business decisions before the PPWR requirements apply from 12 August 2026.
• An advantage over organisations that act too late, achieved through professional PPWR implementation.

When will the PPWR affect your business, and why should you act now?

• The PPWR is already in force as an EU regulation.
• The key obligations will apply from 12 August 2026. Some requirements will apply at a later date, but this date marks the start of the Regulation’s core framework.
• Business partners may require evidence of PPWR packaging compliance before market-surveillance authorities begin doing so.

PPWR – prepare your company before the regulator steps in

Contact us to find out how the PPWR will affect your products, packaging and obligations as a manufacturer, importer or distributor. We provide comprehensive PPWR support for businesses, including advisory services, audits, implementation and consulting tailored to the specific nature of your operations.

According to Poland’s Waste Database (BDO), approximately 113,000 entities in Poland are registered as placing packaged products on the market.

The broad reach of the PPWR is illustrated by Article 22. From 12 August 2026, it requires economic operators—including manufacturers, suppliers, importers and distributors—to identify every economic operator that has supplied them with packaging or packaged products and to provide this information at the request of a market-surveillance authority.

PPWR implementation timeline – when will the individual requirements apply?

12 August 2026

Obligations of manufacturers – Article 15 of the PPWR:

• carrying out the conformity-assessment procedure;
• drawing up an EU declaration of conformity;
• maintaining technical documentation;
• ensuring the continued compliance of series production;
• identifying the manufacturer on the packaging or in the accompanying documentation.

Obligations of importers – Article 18 of the PPWR:

• importers may place only PPWR-compliant packaging on the market;
• verification that the manufacturer has carried out the conformity assessment;
• retention of the declaration of conformity and technical documentation;
• identification of the importer, including contact details;
• an obligation to take corrective action in the event of non-compliance.

Restrictions on substances

• limits on heavy metals in packaging;
• a ban on PFAS in food-contact packaging, in accordance with the PPWR.

Secondary legislation—preparatory stage, with no application requirement yet:

• expected implementing acts on harmonised labelling;
• a methodology for indicating material composition.

31 December 2026

Deadlines for EU institutions, rather than obligations applying directly to businesses:

• an ECHA report or study on substances of concern potentially present in packaging;
• expected implementing acts on recycled content;
• development of sustainability criteria.

12 February 2027

• Member States establish penalties for infringements of the PPWR;
• possible harmonised standards on packaging minimisation;
• expected delegated acts on reuse systems;
• expected guidance on food-contact packaging.

June 2027

• expected implementing acts on the method for calculating reuse targets.

1 January 2028

• possible harmonised standards on recycling;
• delegated acts setting out detailed reporting obligations.

12 February 2028

• implementing acts on calculating empty space;
• development of reuse systems, including in the hospitality sector.

12 August 2028

• mandatory harmonised packaging labelling;
• labelling of waste receptacles.

1 January 2029

• requirements concerning minimum recycled content.

12 February 2029

• labelling that facilitates reuse, such as QR codes.

1 January 2030

• all packaging must be recyclable under the design-for-recycling requirements;
• packaging minimisation criteria become mandatory;
• minimum recycled-content levels for plastic packaging;
• reuse targets for transport, sales and logistics packaging;
• a maximum empty-space ratio of 50% for e-commerce packaging;
• a ban on specified single-use packaging formats under Annex V;
• expected implementing acts concerning recycling at scale.

12 February 2030

• minimum requirements for public procurement involving packaging.

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FAQ – PPWR (Packaging and Packaging Waste Regulation)

Does the EU PPWR apply to companies in Poland?

Yes. The PPWR rules on packaging design and imports form part of an EU regulation that applies directly in all EU Member States, including Poland.

When will the PPWR be implemented in the European Union, and when will the new requirements apply?

The PPWR requirements relating to packaging design and compliance are scheduled to apply from 12 August 2026. After that date, placing non-compliant packaging on the market will involve regulatory risk.

What is the purpose of the new PPWR?

The PPWR is primarily intended to protect the environment by reducing packaging waste, increasing packaging recycling, promoting a circular economy and supporting sustainability in the packaging sector.

Does the PPWR apply to importers, and what are they responsible for?

Yes. Under Article 18 of the Regulation, importers are fully responsible for ensuring that packaging complies with the PPWR. This responsibility cannot be transferred to a supplier outside the EU: importers must ensure PPWR compliance themselves.

What are the new requirements for packaging manufacturers involved in packaging design?

Packaging manufacturers must comply with the packaging-design requirements set out in Article 15 of the PPWR. These requirements concern packaging weight, volume and performance, as well as recyclability. Packaging design must take account of the entire packaging life cycle.

What qualifies as packaging under the PPWR?

The PPWR broadens the definition of packaging. Separate components, inserts, protective elements, transport packaging and functional components may also qualify as packaging if they perform a packaging function during the packaging life cycle.

Does the PPWR apply to own-brand and private-label products?

Yes. An entity placing a product on the market under its own name or trademark may be regarded as responsible for the packaging’s PPWR compliance, even if it does not physically manufacture the packaging. Responsibility rests with the entity placing the product on the market.

Does the PPWR apply to e-commerce?

Yes. Products sold through e-commerce channels are also subject to the PPWR, including their primary, grouped and transport packaging, where that packaging is placed on the EU market.

Is a supplier’s statement confirming PPWR compliance sufficient?

No. Importers and manufacturers must hold their own documentation demonstrating that the packaging complies with the PPWR. A supplier’s statement does not release them from responsibility.

What are the consequences of non-compliance with the PPWR?

Non-compliance may result in a prohibition on placing the product on the market, action by market-surveillance authorities, administrative penalties and the risk of losing contracts with business partners.

How should a company prepare for and implement the PPWR?

Effective PPWR implementation requires the company to develop a packaging strategy, carry out a packaging review, identify the relevant manufacturer or importer obligations and prepare the necessary documentation. A professional PPWR audit can help identify gaps and develop solutions that comply with the new requirements.

Does the PPWR apply only to packaging for new products?

No. The PPWR applies to packaging placed on the market after 12 August 2026, regardless of whether the product is new or was already offered before that date.

What is extended producer responsibility in the context of the PPWR?

Extended producer responsibility means that producers are responsible for the entire packaging life cycle—not only for production, but also for the collection, recycling and management of packaging after use.

What types of packaging are covered by the PPWR?

The scope of the PPWR is very broad. It covers all packaging placed on the EU market, including primary, grouped and transport packaging, as well as reusable and single-use packaging. This applies to plastic packaging materials and to other materials derived from both renewable and non-renewable sources.

What does packaging labelling under the PPWR involve?

Packaging labelling is one of the PPWR’s key requirements. Packaging labels must provide information on material composition, waste sorting and recyclability.

What is recycled material, and what minimum recycled content is required?

Recycled material is material obtained through recycling. From 1 January 2030, plastic packaging must contain a minimum proportion of recycled content. Recycled materials will become a mandatory component of packaging, supporting the transition to a circular economy.

How can packaging waste be reduced?

The PPWR requires packaging to be minimised and packaging waste generation to be reduced. This can be achieved by designing packaging with the minimum necessary weight and volume, using reusable packaging and increasing the proportion of recycled content.

How does the PPWR support sustainability?

The PPWR forms part of the EU’s sustainability policy. It promotes environmental protection by reducing packaging waste, increasing recycling, using recycled materials and designing packaging in accordance with circular-economy principles.

How should a company develop a packaging strategy that complies with the PPWR?

A company’s packaging strategy should take account of the new packaging requirements, design-for-recycling rules, packaging-minimisation targets and the transition to reusable packaging. Professional PPWR implementation support can help create a packaging strategy tailored to the new regulatory framework.

Do you also need to comply with the PPWR if you use packaging designed by another party?

Yes. Even if you use packaging designed by an external supplier, you remain responsible—as the entity placing the product on the market—for ensuring that the packaging complies with the PPWR. You must hold documentation demonstrating that the packaging meets the new requirements.

Contact:
Łukasz Pamuła – Senior Manager
Email: lukasz.pamula@thedy.pl
Tel.: +48 519 504 779