Who does the PPWR apply to: roles and duties

The question has a short answer: the PPWR applies to anyone who places packaging on the Union market or makes it available on that market. Regulation (EU) 2025/40 does not ask whether you manufacture packaging. It asks whether a packed product reaches a customer in the EU under your name or trademark. If it does, you are in scope, even when the film, the carton and the label are bought in full from someone else.

The EU declaration of conformity is issued by the packaging manufacturer within the meaning of Article 15, meaning the party that places packaging on the market under its own name or trademark. The practical consequence catches most companies out: an importer or distributor that sells under its own brand, or that modifies packaging already placed on the market, takes on the manufacturer's obligations (Article 21) and issues the declaration in its own name. The requirements apply from 12 August 2026, so this is not next year's project — the obligation already applies.

Roles and obligations under the PPWR#

Packaging manufacturer and company packing its own goods#

A packaging manufacturer in the narrow sense — a plant producing film, corrugated board, jars or closures — is responsible for the packaging it places on the market itself, and must pass on to its customers the information they need for their own assessment (Article 16). It is the origin of the data on material composition and heavy metal content.

A company that buys those materials and packs its own product into them sits in a very different position from the one it usually assumes. You place a product in packaging on the market, and you answer for the conformity of that packaging as a whole: the carton, the insert, the tape, the label and the ink. Your supplier is liable to you under contract, but it is your documentation that a market surveillance authority examines. That is why collecting supplier documents is not administrative housekeeping — it is the precondition for having anything to sign at all.

Importer and distributor: two levels of verification#

An importer (Article 18) brings packaging or packed goods in from a third country. It does not issue the declaration on the manufacturer's behalf, but it must verify that the manufacturer ran the correct conformity assessment procedure, that the packaging is labelled and that technical documentation exists. It must also keep a copy of the declaration and produce it for the authorities. An importer with reason to believe the packaging does not meet the requirements may not place it on the market.

A distributor (Article 19) carries a lighter load, but not a zero one. Before making packaging available, it checks that the packaging is labelled as required, that the declaration has been drawn up and that a producer covered by EPR appears in the producer register. A distributor that identifies a non-conformity must refrain from selling and inform the other parties in the chain.

The practical difference: the importer must hold the documents itself, while the distributor must be able to point to whoever holds them. Both obligations collapse when nobody in the chain ever drew up a declaration — still the most common outcome on small import lots.

Edge cases where the role is easy to get wrong#

Grouped and transport packaging#

Outer cartons, stretch film, layer pads, pallets and crates are packaging under the PPWR and carry the same substance requirements. The 100 mg/kg limit on the sum of lead, cadmium, mercury and hexavalent chromium applies to them too. The common failure: a company builds solid documentation for the sales packaging and skips the pallet and the tape because "that is only transport". To a market surveillance authority it is packaging like any other.

Plastic pallets and crates circulating in a closed, controlled loop are a separate question. Derogations from the heavy metal limit have historically applied to them, subject to detailed conditions. Before you rely on such a derogation, check that your loop genuinely meets its definition; the mechanism is set out in the post on the heavy metal limits in Article 5.

Sales packaging on imported goods#

You import a finished product in the non-EU manufacturer's packaging. That sales packaging is subject to PPWR requirements, and you are the party placing it on the Union market. If the manufacturer never drew up an EU declaration of conformity — and third-country manufacturers frequently have no such duty at home — the document cannot be borrowed from elsewhere. Two routes remain: obtain the document from the manufacturer together with the underlying evidence, or gather the material data yourself, run the assessment and issue the declaration as the party placing the packaging on the market.

Private label and own brand#

You sell someone else's product under your own logo, or you commission contract manufacturing. Article 21 is unambiguous: a party that places packaging on the market under its own name or trademark, or modifies packaging already placed on the market in a way that may affect conformity, assumes the manufacturer's obligations. Changing the label, adding a hang tag, repacking into a promotional bundle — each of these can trigger the full set of duties. A contract with the manufacturer can allocate who supplies the data, but it does not transfer public-law responsibility.

E-commerce from outside the EU#

A third-country seller shipping straight to an EU consumer does not fall outside the Regulation's field of view. A manufacturer without an EU establishment that sells into a Member State should appoint an authorised representative (Article 17), whose mandate covers keeping the declaration and technical documentation at the authorities' disposal and handing them over on a reasoned request. Fulfilment service providers (Article 20) — the warehouses and logistics operators handling such shipments — carry obligations of their own. Online platforms operate under a due diligence regime: they collect seller data and respond to requests from authorities.

Establishing your own role in five steps#

That list is enough to tell you how many declarations you actually have to issue. To see how it plays out on your own items — material data, mass fractions and evidence gaps — start with a single pack and watch how many fields stay empty. An empty field is not zero; it is missing data that has to be closed before anyone signs.

What this means for the person signing#

The role determines the scope of the documentation, but it does not change one thing: a named individual signs the declaration on behalf of a named company, and that person carries the statement of conformity. A tool — PPWR24 included — organises the data, calculates mass fractions and surfaces the gaps, but it does not take on that responsibility and it does not guarantee that the packaging is compliant. Evidence does: material data from suppliers, test reports and coherent technical documentation.

The next step depends on what you already have. If the roles are settled, move on to building the declaration step by step. If you are unsure which requirements bind you today and which arrive in three years, check the PPWR deadline calendar to 2030.