Category: Legal

Reading time: 10 minutes

A PPWR Declaration of Conformity is the document that makes packaging legal to place on the EU market. Every packaging type needs one from August 12, 2026, and the regulation is specific about who issues it, what it must say, and how long it needs to be kept.

This guide covers what the declaration actually is, how it differs from the technical documentation sitting behind it, what Annex VIII requires point by point, and what a completed one looks like in practice.

What Is the PPWR Declaration of Conformity?

The PPWR Declaration of Conformity is a written, self-issued statement in which the manufacturer confirms that a specific packaging type meets the applicable requirements of Regulation (EU) 2025/40. Its legal basis is Article 39, and its model structure is set out in Annex VIII.

The declaration covers conformity with Articles 5 to 12, the substantive requirements on substances of concern, recyclability, recycled content, minimization, and labeling, to the extent each one already applies on the date the packaging is placed on the market. Not every article under that range is binding yet, so the declaration states what is true today, not what will eventually be true once later deadlines land.

Who Issues the PPWR Declaration of Conformity?

The manufacturer issues the Declaration of Conformity, under its own sole responsibility, for each distinct packaging type it places on the EU market. You are the manufacturer if you make the packaging, or have it designed or made for you and place it on the market under your own name or trademark. Not sure which role applies to you? Our guide to PPWR role determination walks you through it.

There is one exception. If a brand owner is a microenterprise and its packaging supplier is established in the same Member State, the supplier is treated as the manufacturer and issues the declaration.

Issuing the declaration is not the same as holding it. Importers do not draw up the declaration, because that stays with the manufacturer. But an importer bringing packaging in from outside the EU must verify that a valid declaration exists, keep a copy, and produce it to a national authority within 10 days of a reasoned request. We cover this in full in our post on PPWR importer obligations.

PPWR Declaration of Conformity vs. Technical Documentation

	Declaration of Conformity	Technical Documentation
What it is	A signed statement that packaging complies	The evidence file supporting that statement
Legal basis	Article 39, Annex VIII	Annex VII
Who signs it	The manufacturer	Not signed, it is compiled and retained
What it contains	A fixed structure: identification, responsibility statement, conformity statement, signature	Design drawings, material specifications, test reports, assessment considerations, references to regulations and standards
Who sees it	Retained internally, to be produced to authorities on request. Sometimes shared on voluntary basis down the supply chain	Retained internally, to be produced to authorities on request

The declaration is the conclusion. The technical documentation is the evidence backing it up. A manufacturer cannot sign a valid declaration unless that documentation already exists.

What a PPWR DoC Must Contain: The Annex VIII Structure

Annex VIII sets out the model structure for the declaration in eight numbered points, followed by a signature block. In general terms, it requires the packaging’s unique identification, the manufacturer’s identity and address, the authorized representative, if applicable, a statement of sole responsibility, a description of the packaging precise enough for traceability, a statement of which parts of the regulation the packaging conforms to, a reference to any standards or specifications used, a note on notified body involvement, and space for additional relevant information. The entire DoC has to carry an identification number that allows for referencing the document.

Points 4 through 6 draw on the manufacturer’s technical documentation under Annex VII, which covers design, materials, and test results. For manufacturers who don’t produce their own materials, that documentation depends on data from suppliers under Article 16, which we cover in our post on PPWR supplier obligations.

PPWR Declaration of Conformity Template: A Worked Example

Here is what each of the eight points actually asks for, illustrated with a fictional company, Nordhaven Foods, declaring a plastic food container. The content below is for illustration only, not a real company or a real declaration, and the regulation’s own wording for point 3 should be used exactly rather than paraphrased.

1. Unique identification of the packaging. A type, batch, or serial number, or another element that makes this specific packaging identifiable. Example: NH-PT-250ML-V2.
2. Name and address of the manufacturer. The manufacturer’s name, registered trade name or trademark, and postal address, plus the authorized representative’s details where one has been appointed. Example: Nordhaven Foods GmbH, Hafenstraße 12, 20457 Hamburg, Germany.
3. A statement of sole responsibility. A direct statement that the declaration is issued under the sole responsibility of the manufacturer. Example: “This declaration of conformity is issued under the sole responsibility of the manufacturer.”
4. The object of the declaration. A description of the packaging precise enough to allow traceability: the packaging type, packaging level, components, and materials. Example: 250ml rigid PET food container with polypropylene lid, single-use.
5. Conformity with the relevant Union harmonization legislation. The object of the declaration described in Point 4 is in conformity with the relevant Union harmonization legislation:
   • Regulation (EU) 2025/40 on packaging and packaging waste
6. Harmonized standards, common specifications, or technical specifications applied. As of today, no harmonised standards under Article 36 or common specifications under Article 37 have been published for these requirements. Until they are, this point could reference the analytical methods and internal assessments documented in the technical file rather than a published standard.
7. The notified body, where applicable. PPWR uses Module A, internal production control, so no notified body is involved. This point typically reads “not applicable.”
8. Additional information. Anything further relevant to the declaration: the signatory’s role, cross-references to related declarations, or notes on packaging components assessed separately.

Signature block. Place and date of issue, and the name, function, and signature of the person signing on the manufacturer’s behalf.

How Long to Keep a PPWR Declaration of Conformity

The Declaration of Conformity and the technical documentation behind it must be kept available for 5 years for single-use packaging and 10 years for reusable packaging, counted from the date that packaging was placed on the market.

The declaration is not a one-time document. If the packaging changes, or the requirements it was assessed against change, the conformity of the packaging must be reassessed. It must also be drawn up in, or translated into, the language(s) required by each Member State where the packaging is placed on the market, so a single English version will not cover every market.

Common PPWR Declaration of Conformity Mistakes

Treating a quality certificate as a substitute. An ISO 9001 certificate or a food-contact declaration does not replace a PPWR Declaration of Conformity. The declaration must explicitly reference Regulation (EU) 2025/40.

Issuing one declaration for your whole portfolio. Annex VIII requires each declaration to identify a specific packaging type. A general statement covering “all our packaging” does not meet that requirement.

Not updating the declaration when things change. A declaration that was correct when issued can become outdated if the packaging changes or the standards it references are updated. Nothing triggers a review automatically, so you need to track it yourself.

Signing in the wrong role. Responsibility shifts in defined situations. A microenterprise’s supplier becomes the manufacturer, and a distributor becomes one when it places packaging on the market under its own brand. If you get this wrong, the wrong party signs, or no one does. We cover what happens when documentation gaps like this surface in an audit in our post on PPWR non-compliance.

Frequently Asked Questions

What is a PPWR Declaration of Conformity?

A written, self-issued statement from the manufacturer confirming that a specific packaging type meets the applicable requirements of Regulation (EU) 2025/40, following the structure set out in Annex VIII.

What is the difference between the Declaration of Conformity and technical documentation?

The declaration is the signed conclusion. The technical documentation, required under Annex VII, is the evidence, design drawings, material specs, and test reports, that supports it.

Who signs the PPWR Declaration of Conformity?

The manufacturer, under its own sole responsibility.

How long do I need to keep a PPWR Declaration of Conformity?

5 years for single-use packaging, 10 years for reusable packaging, from the date the packaging was placed on the market.

Is there an official PPWR Declaration of Conformity template?

No downloadable form is published by the European Commission. Instead, Annex VIII of Regulation (EU) 2025/40 defines the mandatory 8-point structure directly.

How PAQR Can Help

PAQR helps you collect the data behind each point of the Annex VIII structure, check how ready your supporting technical documentation is, and generate the Declaration of Conformity. You can share the DoC with partners and download it in 24 official EU languages.

Click “Try now for free” to start a free trial:

Reading time: 9 minutes

Article 16 of the Packaging and Packaging Waste Regulation is short, but it’s key to a supply chain with successful data exchange. It states that suppliers shall provide the manufacturer with all the information and documentation necessary for the manufacturer to demonstrate the conformity of the packaging and packaging materials with the regulation, including the technical documentation referred to in Annex VII and required under Articles 5 to 11, in a language the manufacturer can easily understand, in paper or electronic form. Where the packaging is contact-sensitive, a second paragraph extends this to cover the documentation required under the relevant sectoral law as well.

PPWR supplier obligations are a legal data transfer requirement, and understanding exactly what they cover matters whether you’re the one handing over the data or the one asking for it.

Why PPWR Article 16 Matters

The manufacturer carries sole legal liability for a packaging’s conformity, but the manufacturer frequently doesn’t produce the materials that make up that packaging. Article 16 is the mechanism that makes that liability model actually workable: it obligates the party with the technical knowledge, the supplier, to hand that knowledge to the party with the legal exposure, the manufacturer. If you’re a supplier, your customer’s legal exposure now runs through the completeness and accuracy of your data.

Who’s in Scope

Under Article 3(1) of PPWR, a supplier is any natural or legal person that supplies packaging or packaging material to a manufacturer. Supplier sits within the same “economic operator” umbrella as manufacturer, importer, distributor, authorized representative, final distributor, and fulfillment service provider, each with its own distinct obligations under the regulation.

Contact-sensitive packaging, the category that triggers the second layer of documentation under Article 16(2), covers packaging intended for products governed by their own EU sectoral laws: food contact materials, plastic food contact materials, recycled plastic for food contact, cosmetics, human and veterinary medicines, medical devices, animal feed, and dangerous goods transport. If you supply packaging into any of these sectors, Article 16(2) means your data package needs to cover both PPWR’s own requirements and whatever the relevant sectoral regulation demands.

The Micro-Enterprise Exception: When the Supplier Becomes the Manufacturer

There’s one scenario where an operator under the supplier role for a packaging takes on additional responsibilities, beyond Article 16. Under Article 15(12), if a brand owner has packaging manufactured under its own name or trademark but qualifies as a micro-enterprise (fewer than 10 employees and no more than €2 million in annual turnover or balance sheet total, under Recommendation 2003/361/EC) and its supplier is located in the same Member State, the supplier is deemed to be the manufacturer for the purposes of that article.

Rather than a documentation obligation, this is a full transfer of legal responsibility: the supplier carries out the conformity assessment, compiles the Annex VII technical file, and signs the EU Declaration of Conformity, in its own name. If you supply packaging to small, brand-owning customers, it is worth checking early whether any of them fall under this threshold, since the obligation you’re carrying for that customer may be considerably larger than what’s outlined in Article 16.

What Data Suppliers Can Expect to Be Asked For, Now and Later

Article 16(1) points suppliers toward Articles 5 through 11, and each of those articles carries its own kind of evidence and its own timeline.

Article	Requests Suppliers Should be Prepared For	Implementation Date
Article 5	Heavy metal concentration lab reports (proving combined lead, cadmium, mercury, and hexavalent chromium are below 100 mg/kg), Total Fluorine or PFAS-free test results (below 25 ppb for targeted PFAS) for food-contact materials.	August 2026
Article 6	Polymer and material purity specifications, colorant, ink, adhesive, and barrier coating composition, and sorting compatibility data needed to complete the manufacturer’s Design for Recycling (DfR) assessment and performance grading (Grades A to C).	January 2030
Article 7	Certified post-consumer recycled (PCR) plastic percentages and verification proving recycled resin origin for plastic packaging components.	January 2030
Article 9	Industrial compostability certifications (such as EN 13432 compliance) for pods, fruit labels, and lightweight bags.	February 2028
Article 10	Technical drawings, weight/volume ratio data, material density, wall thickness, and structural tolerance data proving that packaging weight and volume have been engineered down to the functional minimum required for safety and performance.	January 2030
Article 11	Durability, washing, and reconditioning test results for reusable packaging formats.	August 2026 (for reusable formats)

Substance and heavy metal data is the prominent request today. Recyclability, recycled content, and compostability data are the requests that will scale up significantly as 2028 and 2030 approach. Suppliers who build the data collection habit now, rather than waiting for each deadline individually, avoid repeating the same scramble three more times over the next four years.

Are Non-EU Suppliers Legally Accountable, or Just Under Market Pressure?

This is worth being precise about, because the two are genuinely different. PPWR’s direct enforcement mechanisms, market surveillance findings and the fines that follow under Article 68, attach to economic operators established or operating within the EU. A non-EU supplier that has never itself placed packaging on the EU market sits largely outside PPWR’s direct enforcement reach.

What compels compliance instead is entirely commercial. Article 16 places the legal obligation to obtain supplier data on the EU-side manufacturer, and the EU importer carries an equivalent duty under Article 18 to verify that a non-EU manufacturer’s own supply chain is in order. An EU manufacturer or importer cannot legally place packaging on the market without that data, so the pressure a non-EU supplier feels is contractual and commercial, driven by their customer’s legal exposure, not regulatory enforcement reaching them directly.

A Document Checklist for Suppliers Responding to a Data Request

When a manufacturer reaches out for PPWR compliance data, vague statements like “our materials comply with EU law” won’t suffice. To satisfy Annex VII technical file requirements, manufacturers need specific, audit-ready evidence they can attach directly to their technical documentation. Structuring the exchange around the exact data request and the concrete documents you can provide helps both sides streamline compliance and eliminate back-and-forth emails.

The Manufacturer’s Data Request	Documents & Evidence You Can Provide
Material & Component Specifications	Full Bill of Materials (BOM), raw material data sheets, CAD or technical manufacturing drawings, and chemical constituent breakdowns.
Applied Technical Standards	Documented references proving compliance with applicable Harmonised Standards (Article 36) or Common Specifications (Article 37) used in full or in part.
Sustainability Assessment Summaries	Qualitative summaries and material data supporting Design for Recycling (Article 6), packaging minimisation assessments (Article 10), or reusability/durability criteria (Article 11).
Lab Verification & Test Reports	Heavy metal concentration lab reports (proving sum of lead, cadmium, mercury, and hexavalent chromium is below 100 mg/kg), Total Fluorine and PFAS-free test reports (for food-contact materials), migration testing reports, and structural tolerance studies.
Sectoral Safety Compliance (where relevant)	Declarations of Compliance (DoC) and supporting safety dossiers under relevant sectoral laws (such as Regulation (EC) No 1935/2004 or Regulation (EU) No 10/2011 for food-contact plastics, or Regulation (EC) No 1223/2009 for cosmetics).

A general assurance that “our materials are compliant” does not meet this bar. What holds up is documentation a manufacturer can attach directly to their own technical file without needing to chase clarification.

Why Uniting Suppliers and Manufacturers is the Key to a PPWR Compliance Strategy

For suppliers, a significant challenge is navigating unclear requests and inconsistent formats. Customers often ask for generic “PPWR documentation” without specifying the exact standards or lab reports required. Each customer then sends a different questionnaire layout, forcing suppliers to manually reformat and resubmit the same technical data for every request.

For manufacturers, the main challenge is organizing mismatched data. Answers arrive in different file types, requiring manual entry into internal compliance tracking systems. When supplier data is vague or incomplete, manufacturers lose time chasing follow-ups just to complete a single packaging file.

A standardized, shared data exchange solves both sides:

• Suppliers get explicit data requirements and can submit their specifications once, rather than reformatting data for every customer.
• Manufacturers receive structured data that maps directly to Annex VII requirements, eliminating manual entry and reducing back-and-forth emails.

What Happens When Supplier Data Is Missing or Wrong

If technical documentation is missing, incomplete, or contains errors, market surveillance authorities can issue a formal non-compliance finding. Missing supplier data does not release the manufacturer from its own obligations, the legal responsibility stays with them regardless of where the gap originated. We cover the fuller consequences of this, across every role in the supply chain, in our post on PPWR non-compliance.

Frequently Asked Questions

What is a supplier under PPWR?
Any natural or legal person that supplies packaging or packaging material to a manufacturer. Their PPWR supplier obligations run primarily through Article 16. The supplier is one of seven defined economic operator categories under the regulation.

Can a supplier become the manufacturer?
Yes. If a brand owner qualifies as a microenterprise and its supplier is established in the same Member State, the supplier is deemed the manufacturer under Article 15(12), taking on the conformity assessment, technical documentation, and Declaration of Conformity in full.

Do non-EU suppliers have to comply with PPWR directly?
Not in the sense of direct EU enforcement. PPWR’s enforcement mechanisms attach to EU-established operators. Non-EU suppliers are compelled indirectly: their EU customer cannot legally place packaging on the market without their data, which makes the pressure commercial rather than regulatory.

What data should a supplier expect to be asked for in 2026?
Substances of concern and heavy metal data, and PFAS data for anything food-contact, since these apply from August 12, 2026. Recyclability, recycled content, and compostability data will scale up as 2028 and 2030 approach.

How Suppliers can Turn Compliance into a Competitive Advantage

While PPWR imposes significant administrative pressure, it also creates a clear commercial opportunity. European manufacturers face strict legal liability, tight implementation deadlines, and heavy documentation burdens. They will naturally favor suppliers who make compliance simple.

Suppliers that provide structured, audit-ready data proactively position themselves as trusted partners. In a market where missing data can stall a product launch, being compliance-ready is a key differentiator to retain accounts and win new business.

How PAQR Can Help

PAQR connects suppliers and manufacturers through two tools designed to streamline data exchange for both sides:

1. Data Request Portal: Manufacturers send structured requests for specific components directly to the supplier holding the data.
   • For Manufacturers: Eliminates manual data entry and automatically saves responses directly into the component’s compliance audit trail.
   • For Suppliers: Replaces vague requests with clear, specific data fields. Suppliers can quickly upload supporting documents or simply confirm data the manufacturer already entered.
2. Supplier Catalogs: Suppliers may publish verified specifications once for components that are requested repeatedly across multiple customers or packaging lines.
   • For Suppliers: Eliminates repeat work by allowing customers to self-serve specifications from a single, verified source.
   • For Manufacturers: Gives instant access to pre-verified compliance data without sending manual requests or waiting for email responses.

Explore how our PPWR solution can help meet your PPWR supplier obligations today. Click “Try now for free” on paqr.com to start a free trial:

Reading time: 7 minutes

This article explains how PPWR assigns economic operator roles and gives a general overview of the manufacturer, importer, distributor, and producer categories. It does not cover every exception or edge case in the regulation. Role determination can be nuanced, and the correct classification depends on the specific facts of your packaging and supply chain. If you are unsure which role applies to you, consult the legal text of Regulation (EU) 2025/40 or reach out to the PAQR team.

Every requirement in the Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, attaches to a role. Establishing whether your company needs to issue a Declaration of Conformity, register in a producer register, or audit upstream compliance documentation starts with a single question: which economic operator role do you hold for this packaging?

PPWR role determination is the starting point for every other compliance decision. Get it wrong at the outset, and it tends to affect every document, deadline, and obligation that follows.

This post covers the roles PPWR assigns along the supply chain, the principle that decides which one applies, and a step-by-step way to work out your role for a given piece of packaging.

PPWR Roles Are Assigned Per Packaging, Not Per Company

The PPWR does not classify companies. It classifies packaging, item by item.

Under the regulation, “economic operator” is the general umbrella term that covers roles like manufacturers, importers, distributors, and fulfillment service providers. However, “producer” is a separate, specialized compliance status assigned under Article 3 for Extended Producer Responsibility (EPR). It applies to whichever manufacturer, importer, or distributor is the first to place a packaged product on a specific Member State’s territory.

Because of this, the same company can easily hold multiple roles across its portfolio. A business might act as the manufacturer for its own branded product line, the importer for a second line sourced from outside the EU, and a distributor for a third EU-sourced supplier’s product, all at the same time.

This is why PPWR role determination must be run per packaging item, and, for EPR producer status specifically, per Member State. A single, company-wide answer to “what are we under PPWR” simply does not exist.

The PPWR Roles at a Glance

Each role carries a different set of obligations. This is a starting point, not the full list. Detailed breakdowns for each role are linked below.

Manufacturer

• Definition: Under Article 3(1)(13), the party that manufactures packaging, or has packaging designed or manufactured, and markets it under its own name or trademark. This includes brand owners who sell packaged products under their own brand. There is only one manufacturer per packaging item, whose company and contact details have to be indicated on the packaging, as per Article 15(5) and (6).
• What this requires: Carrying out the conformity assessment, compiling the Annex VII technical documentation, signing the EU Declaration of Conformity (DoC), and keeping these files for 5 years (single-use packaging) or 10 years (reusable packaging) after the packaging enters the market.

Importer

• Definition: Under Article 3(1)(17), any natural or legal person established in the EU that places packaging from a non-EU (“third”) country onto the Union market.
• What this requires: Before placing packaging on the market, ensuring the manufacturer completed the conformity assessment and technical documentation, and keeping a copy of the DoC on file for 5 years (single-use) or 10 years (reusable). Verifying that the packaging carries correct marking and labeling, including both the manufacturer’s and the importer’s company and contact details, as required under Article 18(3).
• Visit our Importer Spotlight for a full breakdown of importer obligations.

Distributor

• Definition: Under Article 3(1)(18), any natural or legal person in the supply chain (such as wholesalers or retailers), other than the manufacturer or importer, who makes packaging available on the EU market.
• What this requires: Before selling, verifying that the packaging is correctly labelled, that the manufacturer and importer have printed their contact/ID details on the packaging, and that the producer is registered in the national EPR register of the destination.

Producer (EPR)

• Definition: Under Article 3(1)(15), not a separate operational role, but a legal status under Extended Producer Responsibility (EPR) that applies to whichever manufacturer, importer, or distributor is the first to make packaging (or packaged products) available on a specific Member State’s territory.
• What this requires: Registering in that country’s national producer register under Article 44, reporting packaging weights annually, and paying national EPR recycling fees under Article 45.
• To learn more about what it means to be a Producer, check out our Producer Spotlight.

How to Determine Your PPWR Role

Work through this per packaging type. Sales and grouped packaging follows one path. Transport packaging determines the manufacturer differently, so it gets its own path below.

For sales and grouped packaging

Manufacturer: Do you physically produce this packaging, or have it designed and manufactured under your own brand? If yes, you are the manufacturer, and you must carry out the conformity assessment and issue the Declaration of Conformity (DoC) under Article 15. (Note: If you rebrand or modify someone else’s packaging, you also step into the manufacturer’s obligations under Article 21).

Importer: Are you bringing this packaging into the EU from outside the EU for the first time? If yes, you are the importer, and you must ensure the manufacturer completed their compliance files, and keep a copy of the DoC in your own company records under Article 18.

Supplier: Are you supplying empty packaging or packaging materials or components (like raw materials, caps, bottles, labels, or inks) to a manufacturer? If yes, you are a supplier, and you must provide the manufacturer with the technical and material data they need to prove compliance under Article 16.

Distributor: Do you buy and sell packaged products within the EU without rebranding or modifying them? If yes, you are a distributor, and you must verify that the packaging is correctly labelled, marked with manufacturer/importer contact details, and that the producer is registered for EPR under Article 19.

Fulfillment Provider: Do you warehouse, pack, or dispatch packaging or packaged products for someone else without taking ownership of them? If yes, you are a fulfillment service provider, and you must ensure your storage and handling conditions do not damage compliance under Article 20.

If none of those apply, you’re not an economic operator for this packaging, and no PPWR obligation applies.

For transport packaging

Does this transport packaging (like pallets or crates) carry your logo/trademark, or was it custom designed for your brand or product? If either is true, you are legally considered the manufacturer of that transport packaging. If not, your packaging supplier is the manufacturer.

Full breakdown: PPWR Transport Packaging: Who Is Responsible for the Declaration of Conformity?

Separately: are you also a producer?

Whichever role applies above, ask one more question per Member State: am I the first to make this packaged product available on this specific country’s market? If yes (including if you sell B2C via a webshop from another country, or unpack imported goods), you are also the “producer” under Extended Producer Responsibility (EPR), and must register and report packaging weights in that Member State.

Why Getting Your Role Right Matters

Clear role determination creates a solid foundation for your entire compliance strategy. It ensures Declarations of Conformity are issued by the correct party, EPR registrations are completed in every target market, and products move smoothly through the supply chain without legal friction. For a full overview of role-specific liabilities and regulatory requirements, explore our guide on PPWR Non-Compliance: Legal Consequences Across the Supply Chain.

Frequently Asked Questions

What is an economic operator under PPWR?
“Economic operator” is the regulatory umbrella term for the physical businesses in the supply chain. Under the PPWR, this officially includes manufacturers, suppliers, importers, distributors, authorized representatives, and fulfillment service providers. (Note: “Producer” is a separate, additional status for Extended Producer Responsibility).

Is a PPWR role tied to a company or to a specific packaging item?
To the packaging item. The same company can be the manufacturer for one packaging, the importer for another, and a distributor for a third, all at the same time, and even hold different producer status in different Member States for the same packaging.

Who is the manufacturer under PPWR?
The manufacturer is normally the party that manufactures packaging under its own name or trademark, or that effectively controls how it’s manufactured by another company. For sales and grouped packaging, this is usually the brand owner. For transport, service, and primary production packaging, it’s normally the party that makes that packaging, unless it carries the user’s branding or specification.

When does an importer become the manufacturer under PPWR?
Under Article 21, an importer that places packaging on the market under its own name or trademark, or that modifies packaging in a way affecting its conformity, is treated as the manufacturer and takes on the full set of manufacturer obligations for that packaging.

What is the difference between manufacturer and producer under PPWR?
The manufacturer holds conformity obligations (the Declaration of Conformity and technical documentation) and is determined once per packaging item for the entire EU Single market. The producer holds EPR obligations (registration, reporting, recycling fees) and is determined separately per Member State, based on who first makes the packaging available there. The same business is often both, but not always.

Can a distributor also be a producer under PPWR?
Yes. If a distributor is the first to make a given packaging or packaged product available within a specific Member State, it takes on producer status there, alongside its distributor role.

How PAQR Can Help

Once your role is determined, day-to-day work shifts to whichever documentation obligation follows from it: conformity data for manufacturers, verification records for importers and distributors. PAQR gives you a central workspace to organise that documentation by packaging and by market, so the record of what applies to which packaging item doesn’t live in someone’s inbox.

Click “Try now for free” on paqr.com to start a free trial:

Reading time: 5 minutes

A strategic guide for general management on the EU Packaging and Packaging Waste Regulation and Switzerland’s 2026 Packaging Ordinance (VerpV)

The EU Packaging and Packaging Waste Regulation (PPWR) and Switzerland’s Packaging Ordinance (VerpV) pursue the same goal: cutting packaging waste and building a circular economy. However, the two regulations do not use the same tools to get there. The EU relies on binding bans and fixed quotas. Switzerland relies on reporting duties, fees, and rules that only tighten if industry falls short of its own targets. Companies selling packaged goods in both markets need to track both frameworks separately, since compliance with one does not cover the other.

PPWR (Regulation (EU) 2025/40) was adopted in December 2024 and applies since August 12, 2026, with further requirements phased in through 2040. VerpV was adopted by the Swiss Federal Council on June 24, 2026, and enters into force on January 1, 2027, replacing the Ordinance on Beverage Packaging (VGV) from 2000. Both apply to businesses placing packaging on their respective markets, regardless of company size, though each includes some relief for smaller companies.

Where PPWR and VerpV Agree

PPWR and VerpV share three main commitments: limiting packaging to the minimum necessary, designing packaging for recyclability, and requiring companies to report what they place on the market.

Packaging minimization. Both regulations cap packaging weight and volume at what is needed for safety, hygiene, and product protection, and both ban design choices meant only to make a product look bigger than it is. Under PPWR (Articles 10 and 24), a maximum 50% empty-space ratio applies to grouped, transport, and e-commerce packaging from January 1, 2030. Double walls, false bottoms, and other features added purely to increase perceived volume are explicitly prohibited. VerpV (Article 3) sets a parallel requirement from the same date: packaging must be limited to what safety and hygiene demand, and features designed only to inflate a product’s apparent size are banned.

Design for recyclability. Both frameworks require packaging to be physically recyclable, not just theoretically collectible. PPWR (Article 6) introduces recyclability performance classes A, B, and C from January 1, 2030. Packaging that falls below Class C cannot be placed on the EU market, and by 2038 only Classes A and B will remain allowed. VerpV (Article 3) requires packaging to be technically suitable for collection, sorting, and high-quality recycling from the same date, without the EU’s letter-graded class system.

Reporting and producer responsibility. Both countries require companies to report what they place on the market, though the burden differs by size. PPWR (Articles 44 and 45) requires a national producer registry, with annual reporting for anyone placing packaging on the EU market, and includes administrative relief for micro-enterprises. VerpV (Articles 21 to 24) requires companies to report packaging weights by material. Switzerland limits this duty to companies with turnover above CHF 1 million that place more than 500 kg of packaging on the market each year.

Where PPWR and VerpV Diverge

The EU legislates through direct bans and fixed numbers. Switzerland legislates through reporting, fees, and conditional rules that escalate only if voluntary industry targets are missed. Four differences matter most for general management.

Bans vs. subsidiary rules. PPWR bans specific single-use plastic formats outright from January 1, 2030, including grouping films for multipacks, packaging for fresh fruit and vegetables under 1.5 kg, and single-use cups and plates for dine-in service. VerpV avoids outright bans. Instead, Article 4 sets a subsidiary return obligation: businesses must take back beverage cartons and single-use plastic packaging free of charge at the point of sale, unless they join a collective industry recycling scheme. The ordinance also sets minimum recycling rates of 70% for beverage cartons and 55% for single-use plastic packaging. If industry does not meet these rates voluntarily, the Swiss government can impose a deposit requirement (Pfandpflicht).

Recycled content quotas. PPWR (Article 7) sets binding minimum percentages for recycled plastic content, rising over time. For contact-sensitive PET, such as beverage bottles, the quota is 30% by 2030 and 65% by 2040. Other contact-sensitive plastics must reach 10% by 2030, and other plastic packaging must reach 35%. VerpV (Article 3) requires the highest possible share of recycled material without setting a fixed percentage, leaving the exact figure to what is technically and economically feasible.

Deposit return systems. PPWR (Article 50) requires all EU member states to run a deposit return system for single-use plastic bottles and metal cans up to 3 liters by January 1, 2029, targeting 90% separate collection. VerpV takes a narrower approach: a deposit of at least 30 Rappen applies to reusable beverage containers once the ordinance enters into force. For single-use glass, PET, and aluminum, Switzerland sets a 75% target recycling rate, and a deposit on single-use formats only becomes mandatory if that voluntary rate is missed.

Switzerland’s glass fee (VEG). The EU funds glass recycling through eco-modulated EPR fees built into its general producer responsibility system. Switzerland instead keeps a dedicated Advanced Disposal Fee, the vorgezogene Entsorgungsgebühr (VEG), on glass, charged per bottle at 1 to 10 Rappen. The fee already applies to beverage glass and extends to food and cosmetics glass packaging from January 1, 2028.

Key Deadlines for PPWR and VerpV

Both regulations phase in over several years. These dates matter most for planning:

• January 1, 2027: VerpV enters into force in Switzerland, replacing the 2000 Ordinance on Beverage Packaging. Deposits of at least 30 Rappen on reusable beverage containers apply from this date.
• January 1, 2028: Switzerland’s VEG glass fee extends to food and cosmetics packaging.
• August 12, 2028: Harmonized EU-wide labeling for packaging material composition becomes mandatory.
• January 1, 2029: EU deposit return systems for single-use plastic bottles and metal cans must be operational.
• January 1, 2030: EU bans on specified single-use plastic formats, the 50% empty-space limit, and the first recycled content quotas take effect. Switzerland’s minimization and recyclability requirements apply from the same date.
• January 1, 2031: Swiss reporting duties and subsidiary take-back obligations for beverage cartons and single-use plastic packaging become legally binding.

What This Means for Businesses Selling in Both Markets

Swiss law does not exempt companies from EU rules. If your business is based in Switzerland but exports to the EU, PPWR applies to that packaging regardless of what VerpV requires domestically. Meeting VerpV alone is not sufficient for EU market entry, and meeting PPWR alone is not sufficient for the Swiss market, since VerpV includes reporting and take-back duties that PPWR does not.

Three steps help ahead of the 2030 deadlines that apply in both markets:

1. Audit packaging formats against both frameworks. Check for empty-space violations and single-use plastic formats that PPWR will ban outright, and confirm VerpV’s minimization and recyclability rules separately.
2. Track recycled content requirements by market. PPWR’s quotas are fixed and rising. VerpV’s requirement is qualitative, but demand for certified recyclates will increase in both markets as 2030 approaches.
3. Set up material-level data tracking now. Both regulations require precise data on packaging weight, volume, and material composition, and manual tracking becomes difficult to sustain once EU and Swiss reporting duties overlap.

Frequently Asked Questions

What is the difference between PPWR and VerpV?
PPWR relies on binding EU-wide bans and fixed quotas, while VerpV relies on reporting duties, fees, and rules that only escalate if Swiss industry misses its own voluntary targets. Both aim to cut packaging waste and support a circular economy, but the EU regulates through direct legal requirements and Switzerland regulates through conditional, market-driven mechanisms.

When does VerpV enter into force?
VerpV enters into force on January 1, 2027, replacing Switzerland’s 2000 Ordinance on Beverage Packaging (VGV). Deposits of at least 30 Rappen on reusable beverage containers apply from that date.

Does a Swiss company have to comply with PPWR?
Yes, if the business exports packaged goods to the EU. That packaging must comply with PPWR regardless of what VerpV requires domestically, since meeting VerpV alone is not sufficient for EU market entry.

Does Switzerland have a deposit return system for packaging?
Switzerland currently mandates a deposit of at least 30 Rappen only on reusable beverage containers, not on single-use packaging. A deposit on single-use glass, PET, and aluminum packaging only becomes mandatory if the voluntary 75% recycling target is missed.

Does VerpV set a recycled content percentage, the way PPWR does?
No. PPWR sets binding quotas, for example 30% recycled content for contact-sensitive PET bottles by 2030, rising to 65% by 2040. VerpV requires only the “highest possible share” of recycled material, based on what is technically and economically feasible, without a fixed number.

How PAQR Can Help

PAQR gives businesses a single, structured workspace for managing packaging component data, so PPWR documentation does not end up duplicated across spreadsheets and supplier emails. Map your packaging portfolio once, generate a Declaration of Conformity for the EU market, and keep the underlying material data ready to adapt as reporting needs grow across other frameworks like VerpV.

Click “Try now for free” on paqr.com to start a free trial:

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Under the Packaging and Packaging Waste Regulation (PPWR), importers are the legally accountable party inside the EU for every piece of non-EU packaging that enters the market. They act as the gatekeeper between a non-EU manufacturer and the EU market, and the regulation holds them accountable accordingly.

But importer status isn’t fixed, it depends on the specific packaging and transaction. This post breaks down who qualifies as an importer, what obligations that role carries, and what it takes to stay compliant, from the initial border crossing to the years of mandatory document retention that follow.

Am I an Importer Under PPWR?

You are an importer if you place packaging from outside the EU onto the EU market, whether that packaging is empty or already contains a product. But here’s the key: importer status is determined per packaging, not per company.

A manufacturer may produce their own packaging for their own products. The same company may also source packaging from a supplier outside the EU and place it on the market. In that transaction, they act as an importer, subject to importer obligations, even though they are also a manufacturer elsewhere in their supply chain.

Similarly, a distributor that typically sources packaging from EU suppliers may occasionally import a specialty packaging type from Asia. For that specific shipment, they step into the shoes of an importer and must comply with Article 18 (as well as Article 21 if they place that imported packaging on the market under their own brand or trademark).

The takeaway: PPWR does not assign roles to companies; it assigns roles to transactions. If you source any packaging from outside the EU and place it on the EU market, you need to read this post and ensure those specific packagings meet the requirements below.

Verification Obligations Before Placing on the Market

Under Article 18 PPWR, the obligation to place on the market only packaging that complies with Articles 5 to 12 does not fall on the manufacturer alone. It extends explicitly to importers.

Conformity assessment. The importer must ensure that the manufacturer in the third country has carried out the conformity assessment procedure under Article 38 and compiled the technical documentation required under Annex VII.

Declaration of Conformity. Article 18(7) legally obligates the importer to keep a copy of the manufacturer’s EU Declaration of Conformity, retaining it for 5 years for single-use packaging and 10 years for reusable packaging.

Labelling compliance. The importer must ensure the packaging carries the harmonised sorting labels required by Article 12. These labels become mandatory from 2028 on, so this obligation phases in rather than applying immediately, but the verification duty sits with the importer once it does.

Manufacturer identification. The importer must verify that the manufacturer has complied with their identification obligations: placing a type, batch, or serial number on the packaging under Article 15(5), and indicating their name, registered trade name or trademark, and contact address under Article 15(6).

Accompanying documents. The importer must ensure the packaging is accompanied by any legally required documents.
If the importer has reason to believe the packaging does not comply with PPWR requirements, they must not place it on the market.

Traceability and Importer Identification

Once the importer places the packaging on the market, they must make themselves identifiable to market surveillance authorities, separately from the manufacturer.

Contact information. The importer must indicate their own name, registered trade name or trademark, and postal address, plus electronic means of communication where available, on the packaging.

The accompanying document exception. Where it is not possible to display this information on the packaging, the importer may provide it via a standardised, open, digital data carrier (such as a QR code) or on a document accompanying the packaged product. If the manufacturer is already integrating a QR code into the packaging to meet their own identification and contact-detail obligations under Article 15, the importer’s contact details can typically sit on that same digital carrier rather than requiring a separate one.

Storage and transport care. While the packaging is under the importer’s responsibility (whether empty or already containing a product), they must ensure that storage or transport conditions do not jeopardise its compliance with the core sustainability and labelling requirements of Articles 5 to 12.

Record Keeping and Cooperation with Authorities

The importer’s compliance duties continue long after the packaging has entered the EU supply chain.

Document retention: the 5/10-year rule. The importer must keep a copy of the EU Declaration of Conformity at the disposal of market surveillance authorities and ensure the manufacturer’s technical documentation can be made available on request. This retention period is 5 years for single-use packaging and 10 years for reusable packaging, starting from the date the packaging was placed on the market.

The 10-day response limit. If a national authority submits a reasoned request for the technical documentation or proof of conformity, the importer must provide it electronically, and in paper if requested, in a language easily understood by that authority, within 10 days.

Corrective measures. If the importer has reason to believe that packaging they already placed on the market is non-compliant, they must immediately take corrective measures to bring it into conformity, withdraw it, or recall it, and must notify the relevant national market surveillance authorities of the suspected non-compliance and the corrective actions taken. We cover what happens across every role when this goes wrong, including the fines involved, in our post on PPWR non-compliance.

Special Structural Considerations: Branches and EPR

Branch offices cannot be importers. An EU branch office of a non-EU company typically lacks a separate legal personality, meaning it cannot legally take on the importer role under the PPWR. To handle these responsibilities directly, rather than forcing your European distributors or customers to inherit heavy importer liabilities, your non-EU company must incorporate a separate, legally distinct subsidiary within the EU to act as the importer of record.

EPR obligations. Under PPWR, an importer is legally classified as a producer if they are the first to make a packaged product, or empty transport or service packaging, available on a specific Member State’s territory. This means registering in that Member State’s producer register, reporting packaging weights annually, and paying EPR waste management fees. We cover this status in full in our post on the PPWR producer, since importer and producer status frequently apply to the same company at once.

PPWR Importer Obligations at a Glance

Obligation	Legal Basis	When It Applies
Verify conformity assessment & technical documentation drawn up by manufacturer	Article 18(2)(a) (ref. Article 38 & Annex VII)	From August 12, 2026
Verify manufacturer identification & contact details are printed on the packaging or accessible via digital identifier	Article 18(2)(d) (ref. Article 15(5) & 15(6))	From August 12, 2026
Indicate own importer name, trade name, and postal address on the packaging or through a digital identifier	Article 18(3)	From August 12, 2026
Retain the DoC & make technical documentation available if requested	Article 18(7)	5 years for single-use, 10 years for reusable (from August 12, 2026)
Respond to reasoned national authority requests within 10 days	Article 18(8)	Within 10 days of request (from August 12, 2026)
Verify harmonised material composition sorting labels	Article 18(2)(b) (ref. Article 12)	Mandatory from August 12, 2028 (or 24 months from implementing acts)
Register and report as a “producer,” if unpacking or distance-selling	Articles 44 & 45	Per Member State once national registers launch (Transition rules apply)

Frequently Asked Questions

What is an importer under PPWR?
An importer is any natural or legal person established within the EU that places packaging from a third country, empty or containing a product, on the Union market. A branch office without separate legal personality cannot hold this role.

Does an importer need to create the Declaration of Conformity?
No. The manufacturer is solely responsible for drawing up and signing the EU Declaration of Conformity. The importer’s obligation is to keep a copy of this completed DoC at the disposal of market surveillance authorities once the packaging is on the market, and to ensure the manufacturer’s supporting technical documentation can be provided upon request.

How long must an importer keep packaging documentation?
5 years for single-use packaging and 10 years for reusable packaging, starting from the date the packaging was placed on the market.

How quickly must an importer respond to an authority request?
Within 10 days of a reasoned request, providing the information electronically and, if requested, in paper, in a language the authority easily understands.

Is an importer automatically an EPR producer?
Often, but not automatically. An importer becomes a producer under Extended Producer Responsibility specifically when they are the first to make packaging or a packaged product available in a given Member State’s territory.

How PAQR Can Help

Verifying a non-EU manufacturer’s conformity assessment, holding their Declaration of Conformity, and being ready to produce technical documentation within 10 days of a request are three separate obligations that all depend on the same underlying data being organised and current. PAQR gives you a central workspace to collect and store this documentation by supplier and packaging format, so a request from a market surveillance authority is a retrieval, not a scramble.

Click “Try now for free” on paqr.com to start a free trial:

Reading time: 3 minutes

One of the most common misconceptions in PPWR compliance is what “producer” actually means. Under the regulation, it has nothing to do with who physically makes the packaging. It is a legal status tied to Extended Producer Responsibility, and it applies to a much wider range of businesses than most expect.

Here is what it means, how to tell if it applies to you, and what it requires.

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