The Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, has applied since 12 August 2026.
For companies placing packaged products on the EU market, this means that PPWR is no longer only something to prepare for in the future. Some requirements already need to be addressed, while others will be introduced progressively over the coming years.
For many companies, the main question at the moment is simply where to start. In practice, the first step should not necessarily be redesigning packaging or changing labels. It should be understanding the packaging portfolio, identifying the company’s responsibilities and checking whether the necessary supporting documentation is already available.
Start with your packaging inventory
A PPWR review should cover more than the bottle, jar, tube or carton that the consumer sees.
Closures, pumps, caps, labels, sleeves, leaflets, secondary cartons, multipack components and transport packaging can all form part of the packaging system. E-commerce packaging, such as mailers or cushioning materials, should also be considered where relevant.
For each component, it is useful to have some basic information available, including the material, weight, supplier and any relevant specifications or declarations.
This is often where the first gaps appear. A company may have good information for the main container, for example, but much less documentation for smaller components such as pumps, caps, labels or liners.
Building a clear packaging inventory therefore makes the rest of the PPWR assessment considerably easier.
Clarify who is responsible
Another important step is understanding which economic operator is responsible for the different PPWR obligations.
Under PPWR, the manufacturer is generally responsible for ensuring that the packaging complies with the applicable requirements, carrying out the conformity assessment and preparing the technical documentation and EU Declaration of Conformity.
Where products come from outside the EU, the importer also has responsibilities, including verifying that the manufacturer has completed the required conformity assessment and holds the appropriate documentation.
Separately, companies also need to determine who is considered the producer for Extended Producer Responsibility (EPR) purposes. This is particularly important because EPR requirements continue to be managed at Member State level.
The same company can therefore have different responsibilities depending on the product, supply chain and country concerned.
Check the evidence behind packaging compliance
One of the most useful things companies can do now is review what their packaging suppliers can actually provide.
For all packaging, the combined concentration of lead, cadmium, mercury and hexavalent chromium must not exceed 100 mg/kg.
This requirement is not new in substance, but the supporting evidence still needs to be available. In practice, existing supplier declarations may still refer to the previous Packaging and Packaging Waste Directive, or the information available may be too general to support the new PPWR technical documentation.
Supplier declarations, material specifications, composition information and relevant test reports should therefore be gathered and reviewed rather than relying only on a general statement that the packaging is “PPWR compliant”.
For cosmetic packaging in particular, it is useful to make sure that sufficient information is available for each component, including smaller parts such as pumps, closures, liners, labels and sleeves, as these are often where documentation gaps appear.
Technical documentation and the Declaration of Conformity
Another important change for many businesses is the documentation that needs to sit behind the packaging.
PPWR requires manufacturers to prepare technical documentation in line with Annex VII and an EU Declaration of Conformity following Annex VIII.
The technical documentation should describe the packaging and its intended use, the materials and components used, the relevant specifications or standards applied and the evidence supporting compliance with the applicable PPWR requirements.
The Declaration of Conformity is a self-declaration made under the responsibility of the manufacturer.
This does not mean that packaging needs a CE mark or that companies need to obtain a general “PPWR certificate”. Laboratories can provide testing and external specialists can support with the assessment and preparation of documentation, but the legal responsibility remains with the relevant economic operator.
For companies with a large number of products, it is also useful to determine which packaging types can reasonably be grouped together and where separate supporting documentation will be needed.
What about recyclability?
Recyclability is one of the most discussed areas of PPWR, but it is important to keep the implementation timeline in mind.
The Regulation introduces recyclability performance grades and future design-for-recycling requirements, but the detailed criteria are still to be adopted through delegated acts.
The market-access requirement linked to recyclability grades will apply from 2030, or later depending on when those delegated acts enter into force.
This does not mean companies should ignore recyclability until then. Packaging composition, multi-material structures and the ability to separate components are worth reviewing now, particularly where redesign could require significant lead time.
However, companies should be cautious about treating a definitive PPWR recyclability grade as something that can already be assigned with certainty today.
EPR remains a country-by-country exercise
PPWR creates a common EU framework for packaging, but Extended Producer Responsibility obligations still require a national assessment.
Depending on the country, companies may need to register, report packaging quantities, participate in an approved scheme and pay packaging-related fees.
The exact requirements depend on the Member State and on the company’s role in the supply chain. For non-EU companies, an authorised representative may also be required in certain cases.
For businesses selling across several EU markets, EPR should therefore be treated as a separate workstream rather than assuming that one registration will automatically cover the whole EU.
A quick note on environmental claims
There is another upcoming change worth keeping in mind.
From 27 September 2026, the Empowering Consumers for the Green Transition Directive, Directive (EU) 2024/825, will also apply.
This is particularly relevant for companies using environmental claims such as “green”, “eco-friendly”, “sustainable” or similar wording on packaging, websites or marketing materials.
Generic environmental claims, sustainability labels and claims about future environmental performance will be subject to closer scrutiny.
Although EmpCo is separate from PPWR, the two topics can overlap in practice, particularly when companies are already reviewing packaging artwork, sustainability messaging or future packaging changes.
It therefore makes sense to review environmental claims at the same time rather than updating packaging now and having to revisit the wording again shortly afterwards.
What should companies do now?
For most businesses, the immediate priority is not to change every piece of packaging.
It is to understand what packaging they have, confirm their role, gather the available supplier evidence and identify what is missing.
A practical first review should therefore cover:
- the packaging components used for each product;
- materials, weights and suppliers;
- available declarations, specifications and test reports;
- responsibility for the PPWR technical documentation and Declaration of Conformity;
- the EU markets in which EPR obligations may apply; and
- any environmental claims currently used on packaging or related marketing materials.
Once this information is organised, it becomes much easier to distinguish what requires action now from what can be planned as part of the next PPWR implementation stages.
How CE.way can support
At CE.way, we can support companies throughout this process, from the initial PPWR gap assessment and supplier documentation review to the preparation of technical documentation and Declarations of Conformity.
We can also assist with EPR assessments and registrations across EU Member States, as well as reviewing packaging-related environmental claims in light of the upcoming EmpCo requirements.
If you are not sure where to start, a packaging list together with the countries where your products are sold is usually enough for us to identify the main gaps and determine the next steps.
