This PPWR FAQ brings together the 25 most frequently asked questions about the European packaging regulation, grouped into six themes: understanding the text, scope and companies concerned, practical obligations, data and evidence, interaction with other frameworks, and finally risks and inspections. Each answer gets straight to the point, then ends with a “To check on your side” line: the operational checkpoint to review in your supplier data. Because on this subject, the difficulty is not knowing the rule, but proving that it is complied with, item by item.
By Gautier VeyssetIndustry specialist writer at Tracklab · LinkedInUpdated 13 Oct 202612 min read5 sources citedThe PPWR is the European regulation on packaging and packaging waste (Packaging and Packaging Waste Regulation, reference (EU) 2025/40). It sets common rules across the entire packaging life cycle: design, placing on the market, use, collection and treatment. It therefore does not only target packaging manufacturers, but any company that places a packaged product on the Union market.
List, by product family, the packaging you actually place on the European market - sales, grouped and transport packaging.
The PPWR replaces Directive 94/62/EC on packaging and packaging waste. The change is not cosmetic: whereas the directive had to be transposed by each Member State, the regulation applies directly and identically in all 27 EU countries. Divergent national interpretations disappear, but there is no longer a “more lenient country” to shelter in.
Take stock of the national rules your teams have applied until now and confirm that they are indeed replaced by the common European framework.
It is a European Union regulation, directly applicable in all Member States without transposing legislation. You therefore no longer depend on a national version for most packaging requirements. Implementing acts, and sometimes national provisions, supplement certain arrangements, to be checked depending on your market.
Identify the countries where you sell and check, for each one, whether national arrangements are added to the European framework.
Yes: as a Union regulation, it applies directly in France as in the other Member States. There is no national transposing “PPWR law”. It is the European regulation that applies, supplemented by implementing acts and, for end of life, by the national extended producer responsibility (EPR) scheme.
Distinguish, in your files, the design obligations (PPWR) from the reporting and financing obligations (French EPR).
The regulation entered into force in 2025 and, as a general rule, applies from 12 August 2026. Not all PPWR deadlines fall on that date: recycled content, recyclability, harmonised labelling and reuse follow their own timeline, spread over several years. The exact milestones depend on packaging categories and implementing acts: to be checked in the official text and according to your case.
Build a timeline of the deadlines applicable to your packaging categories, rather than a single compliance date.
Any player that places a packaged product on the Union market is concerned: companies placing products on the market, brands, importers, distributors, but also packaging manufacturers and suppliers of materials and components. The answer to “PPWR who is concerned” is therefore broad: responsibility runs up the entire chain, right down to supplier data. It makes no difference whether you manufacture the packaging or use it.
Map your chain - who designs, who manufactures, who imports, who places on the market - and identify who holds each piece of data.
No. The PPWR does not provide for any size threshold exempting a company: an SME that places a packaged product on the market is concerned in the same way as a large group. Nor is there a minimum volume below which data requirements would apply less.
Do not assume that a low volume excludes you from the scope - instead, check which packaging actually falls within the scope.
Yes. As soon as a packaged product is placed on the EU market, the requirements apply, whatever the origin of the packaging. The importer bears a responsibility comparable to that of the company placing products on the market, which means collecting data from suppliers that are sometimes located outside the EU. Two different levels of evidence, for the same obligation.
List your non-EU suppliers and check that you obtain the same quality of evidence from them as from your European suppliers.
Yes, transport packaging - pallets, cases, films, layer pads - falls within the scope of the PPWR. It is also subject to certain specific obligations, in particular on reuse, with exceptions provided for by the applicable framework for certain formats; some exemptions have been announced for specific formats. Transport packaging is therefore not “off-topic” on the grounds that it is not sold to the consumer.
Take stock of transport and grouped packaging, which is often tracked by logistics rather than by Quality or Regulatory teams.
The regulation covers the vast majority of packaging, but provides for categories or uses that are treated separately, as well as targeted exceptions, including for certain specific transport packaging. The exact list of packaging excluded from the PPWR and of exemptions depends on the text and its implementing acts. It must be checked in the official texts, according to your case, and never taken second-hand.
Never assume an exclusion without a source - confirm it in the text in force, for the packaging format concerned.
The PPWR requires packaging to be designed so as to reduce unnecessary weight, volume and layers, and to enable its recycling. The PPWR obligations on design are based on a recyclability classification that determines whether packaging may be placed on the market, depending on the applicable deadline. This means knowing the detailed composition and structure of each packaging item.
“All packaging placed on the market shall be recyclable.”Regulation (EU) 2025/40, Article 6(1) · EUR-Lex, official text
For each of your packaging items, do you have its layer-by-layer composition and its exact grammage?
The PPWR sets recycled content requirements for certain packaging categories, in particular plastics, with thresholds that change over time. The precise values, calculation scopes and categories concerned depend on the applicable framework and implementing acts: to be checked in the official text. A figure declared without a calculation method does not constitute evidence.
Several suppliers give you a recycled content percentage - do you know which method and scope it is based on?
The PPWR provides for harmonised labelling, indicating in particular the material composition of the packaging and the sorting instructions, by a deadline that follows the publication of the implementing acts. The aim is a common sorting language across the EU. Reliable labelling requires reliable composition data upstream: the information displayed is never better than the data collected.
Who, in your organisation, would be able to provide the exact composition to show on your labels, item by item?
The PPWR declaration of conformity is the document by which the packaging manufacturer declares, under its own responsibility, that a packaging item meets the applicable requirements. It is neither a certificate issued by a third party nor a CE marking: it is first and foremost a body of evidence - composition, recycled content rate, substances, tests, compliance of components. For its content, the evidence to gather and the errors that invalidate it, see the PPWR declaration of conformity.
Pick a packaging item at random and test whether you can produce its declaration and the supporting evidence, dated and versioned.
The PPWR sets reuse targets for certain packaging categories - beverages, takeaway food, e-commerce, transport - with exceptions provided for certain formats. Reuse requires tracking reusability and, where applicable, the rotation cycles of reusable packaging. The exact scopes and deadlines are to be checked according to your packaging category.
Clearly distinguish, in your master data, single-use packaging from reusable packaging and its tracking.
The core data set is stable whatever the supplier: product identity, material composition by component, recycled content rate with calculation method, substances of concern, food contact compliance, recyclability, weight and structure, reuse status. For each piece of data, require a defined form of evidence: technical data sheet, signed declaration, analysis report, material certificate.
For a given item, can you name the supplier, the date and the version of each piece of packaging data?
Evidence runs up the chain: material supplier, packaging manufacturer, component manufacturer, laboratory. The company placing products on the market must be able to produce the evidence for the packaging it places on the market, including for components it does not buy directly. Your level of evidence therefore depends on your suppliers' ability to document their own composition.
Identify, for each packaging item, who actually holds the evidence - and not just who sends you the document.
The packaging technical documentation - declaration, assessment documentation, evidence, version history - must be kept and made available to the authorities. The retention period laid down by the regulation differs depending on the type of packaging, with a longer period for reusable packaging. The precise period and its starting point are to be checked in the official text, as they determine your archiving policy.
Does your archiving keep the version in force on the date of the inspection, or only the last document received?
Three levers: write the declaration obligation into the contract, make listing conditional on the data being provided, and document the refusal. A supplier that cannot declare its composition transfers the risk to your file: it is a selection criterion, not just an administrative irritant. A supplier portal centralises these requests and leaves a record of who provided what, and when.
List the suppliers who are silent or recurring in your reminders - they are the ones concentrating the risk in your file.
The PPWR harmonises design requirements at European level, while EPR for commercial packaging (the French extended producer responsibility scheme) remains a national scheme that finances collection and recycling. The two overlap without replacing each other: the PPWR says what the packaging must be, EPR organises who reports and how much is paid. Packaging data - composition, tonnages, recycled content rate - serves both approaches. For EPR obligations and reporting, see EPR for commercial packaging.
Check that the composition and tonnages used for your EPR reporting are the same as those used for your PPWR compliance.
No, ideally just one. The PPWR and the EUDR (deforestation regulation) are two separate frameworks, but they converge on the same supplier data for wood, paper and cardboard packaging: provenance, legality, documentation of origin. Pooling data collection avoids duplicating requests to suppliers. The case of pallets and cases is detailed in the EUDR wood packaging guide.
Does the same cardboard or wood supplier provide you with a single set of data, usable for both regulations?
They are two separate frameworks that overlap on the same packaging. The PPWR regulates substances of concern and, in particular, PFAS in packaging in contact with food; food contact legislation regulates the safety of materials in contact with foodstuffs. Packaging can comply with one and not the other. For barrier food packaging, these issues are dealt with together, as detailed in our guide on PFAS in packaging.
Do you have, for each food packaging item, a food contact declaration and PFAS data linked to the same item reference?
The PPWR provides for a penalties regime defined and implemented by each Member State: amounts and arrangements therefore vary by country. In France, this is compounded by penalties specific to the EPR scheme in the event of non-reporting or incorrect information. The logic remains the same: not reporting does not remove the obligation. The exact amounts are to be checked according to your jurisdiction and your case.
Beyond the fine, assess the operational risk - a non-compliant batch can block a placing on the market or a delivery.
An inspection is rarely about reading the text: it is about the ability to produce the evidence - declaration, technical documentation, data linked to the right packaging, in the right version. The useful test is simple: can you retrieve, within a few minutes, the composition, the recycled content rate and the declaration of a given packaging item? If the answer is no, the file is not ready, even if the documents exist somewhere.
Do the exercise on three real items, without preparation, and time how long it takes to reconstitute the file.
With scope and risk, not with the text. Three steps: map the packaging placed on the market, prioritise packaging in contact with food and categories subject to recycled content requirements, then structure the collection of supplier data in a single repository. Without centralisation, data remains scattered across technical data sheets, emails and spreadsheets.
Choose a priority packaging family and test data collection on five items before rolling out the approach.
Where to start
Start with scope and risk, not with reading the text.
If you remember only five points from this FAQ, remember these:
These five questions are dealt with together, on the same foundation of supplier data. To go further within this set of guides:
The next concrete step is a test, not a read: pick a packaging item at random and check whether you can retrieve, within a few minutes, its composition, its recycled content rate and the declaration covering them, with their dates and versions. If the answer is no, that is the first workstream to open - before the deadlines make it mandatory.
Two free tools, built by the Tracklab team from the text of Regulation (EU) 2025/40, to frame your action plan and collect evidence from your suppliers.
All the deadlines of Regulation (EU) 2025/40 on a single timeline, and the checklist of actions to start now, article by article.
The step-by-step method to obtain PPWR evidence from your suppliers (PFAS, substances, recyclability, recycled content), with the questionnaire and evidence matrix ready to send.
Enter your details to access the download immediately.
The files open in Google Drive. For the spreadsheet, Google offers to make a copy in your own Drive.
The official texts and tools this guide is based on.
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