PPWR Compliance Requirements 2026: What Packaging Companies Must Do

The PPWR reaches almost every company that handles packaging commercially: manufacturers of packaging, fillers and packers who put products into packaging, importers who bring packaging or packed products into the EU, and distributors.

Importers deserve particular attention. If the original manufacturer is established outside the EU, the importer steps into the manufacturer's obligations and must ensure that a proper declaration of conformity and technical documentation exist — or, in practice, take care of them itself.

The most frequently overlooked group: distributors and brands that sell packaging under their own name or trade mark. Under the PPWR they are legally treated as the manufacturer and must issue their own EU declaration of conformity — relying on the upstream supplier's paperwork is not enough. This regularly catches private-label and online sellers as well.

The core obligations of the PPWR sit in Articles 5 to 12. They start with substances of concern in packaging, including limits on heavy metals and restrictions targeting PFAS, and continue with recyclability: packaging must be designed for recycling. Plastic packaging additionally faces minimum recycled content requirements.

Further requirements cover compostability for specific packaging formats, packaging minimisation — packaging must be reduced to what its function actually requires — reusability requirements for certain packaging, and harmonised labelling so that packaging can be sorted and disposed of correctly.

Which of these requirements apply depends on the specific packaging: its material, format and use. This mapping is the analytical heart of PPWR compliance, because the declaration of conformity must state exactly which requirements the packaging meets.

Before the declaration can be issued, the packaging must undergo a conformity assessment. For packaging, the PPWR provides for internal production control — Module A. The manufacturer performs the assessment on its own responsibility; no notified body and no external certification are required.

Module A means the manufacturer checks the applicable requirements itself, documents the assessments and calculations, and ensures that ongoing production stays in conformity. The absence of an external body lowers the formal hurdle, but it shifts the full burden of getting it right onto the manufacturer.

The technical documentation under Annex VII contains a description of the packaging, the applicable requirements, the harmonised standards or other technical specifications used, and the results of the assessments and calculations performed. It is the evidence base behind every statement in the declaration.

On that basis the manufacturer issues the EU declaration of conformity under Article 39, structured according to Annex VIII with its eight mandatory points — from the unique identification of the packaging through the conformity statement to the signature. Declaration and documentation must be retained for five years for single-use packaging and ten years for reusable packaging.

The most immediate consequence of non-compliance is market access. Packaging without a valid declaration of conformity or technical documentation may not be placed on the market; market surveillance authorities can prohibit the making available of the packaging and order its withdrawal.

Fines come on top — but their amount is set nationally. The PPWR obliges member states to lay down effective, proportionate and dissuasive penalties, with the national PPWR penalty regimes due by 2027. As an indication of scale: in Germany, the current Packaging Act already provides for fines of up to 200,000 euros for comparable packaging violations. That figure is an orientation, not a guaranteed PPWR maximum.

Independent of any fine, a sales ban or a withdrawal usually hurts far more commercially than the penalty itself. Treating the documentation duties as a formality is the expensive mistake.

Step 1 — Take inventory: record every packaging you manufacture, import or sell under your own brand, and clarify your role for each one (manufacturer, importer, pure distributor) — your role decides who must issue the declaration. Step 2 — Map the requirements: assign the applicable requirements of Articles 5 to 12 to each packaging.

Step 3 — Collect the data: obtain the material and supplier data needed to support the assessments and calculations. Step 4 — Draw up the technical documentation per Annex VII. Step 5 — Carry out the Module A internal production control and document the result.

Step 6 — Issue the EU declaration of conformity with all eight Annex VIII points, signed by an authorised person; a guided generator such as ppwr-doc.com produces the finished document in minutes. Step 7 — Archive declaration and documentation (five years for single-use, ten for reusable packaging) and set up a process that captures new or changed packaging, so you stay compliant after the deadline too.