{"id":1551,"date":"2026-09-14T21:21:11","date_gmt":"2026-09-14T19:21:11","guid":{"rendered":"https:\/\/helenaolbertova.com\/?page_id=1551"},"modified":"2026-09-14T21:21:12","modified_gmt":"2026-09-14T19:21:12","slug":"ppwr-packaging","status":"publish","type":"page","link":"https:\/\/helenaolbertova.com\/cs\/ppwr-packaging\/","title":{"rendered":"PPWR Packaging"},"content":{"rendered":"
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PPWR \u00b7 Regulation (EU) 2025\/40<\/p>\n\n\n\n

Packaging Compliance: What Applies, and to Whom<\/h1>\n\n\n\n

The Packaging and Packaging Waste Regulation has applied since 12 August 2026. Packaging placed on the EU market must meet substance limits, carry defined identification, and be backed by technical documentation and an EU declaration of conformity. There is no transition period for the roles, the substance restrictions, or the conformity framework.<\/p>\n\n\n\n

Many companies have not yet realised that these obligations may fall on them, not only on their packaging supplier. This page explains the basics and offers ready-to-fill templates. Packaging compliance is not a field I consult in beyond that.<\/p>\n<\/div>\n\n\n\n

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Four Things Worth Knowing First<\/h2>\n\n\n\n
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You May Be the Manufacturer Without Knowing It<\/h3>\n\n\n\n

Under PPWR you are the manufacturer of a packaging if you have it, or a packaged product, designed or made under your own name or trademark. That holds even if you never physically produce anything, and even if another trademark also appears on it. It covers brand owners as well as retailers selling private-label goods.<\/p>\n\n\n\n

As the manufacturer you are responsible for conformity with Articles 5 to 12, for the technical documentation under Annex VII, for the EU declaration of conformity under Annex VIII, and for the on-pack information under Article 15.<\/p>\n<\/div>\n<\/div>\n\n\n\n

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The Producer Is a Different Role Entirely<\/h3>\n\n\n\n

The producer handles extended producer responsibility: registration in the national Producer Register, and financing the collection and treatment of packaging waste in the Member State where the packaging becomes waste.<\/p>\n\n\n\n

The same company can be both manufacturer and producer. They are separate sets of obligations and neither one covers the other.<\/p>\n<\/div>\n<\/div>\n<\/div>\n\n\n\n

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PPWR Does Not Stop at the EU Border<\/h3>\n\n\n\n

If the manufacturer is established outside the EU, the importer in the EU must make sure the third-country manufacturer has assessed the packaging and provided the required information.<\/p>\n\n\n\n

If a European importer has pointed you toward templates like these, that is exactly why. Without your assessment and your information, they cannot meet their own obligation.<\/p>\n<\/div>\n<\/div>\n\n\n\n

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For IVD Manufacturers Specifically<\/h3>\n\n\n\n

Packaging conformity is separate from device conformity. It needs its own declaration and its own technical file, and it does not belong inside your device DoC.<\/p>\n\n\n\n

You are also not alone in this. The technical documentation is drawn up by the manufacturer hand in hand with the packaging supplier, for example the converter that die-cut and printed your carton. That is where most of the design and material data sits.<\/p>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n\n\n\n

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Workshop with Templates \u00b7 8 Languages<\/p>\n\n\n\n

PPWR: What Applies from 12 August 2026, and How to Handle It<\/h3>\n\n\n\n

PPWR is broad, new, and many of the supporting rules do not even exist yet. Rather than wait, I wrote the starting point I wanted to hand my own clients: a clearly written guide and templates that let you begin now.<\/p>\n\n\n\n

After purchase you immediately receive four documents:<\/p>\n\n\n\n