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Tag: LEGAL

  • The PPWR Producer: What It Means and Why You Might Already Be One

    The PPWR Producer: What It Means and Why You Might Already Be One

    3 minute read

    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.

    What a producer actually is

    A producer is the economic operator who is first to make packaged products available on the market within a specific EU Member State. That could be a manufacturer, an importer, or a distributor. The determining factor is who goes first in a given territory.

    Physical production has nothing to do with it.

    Are you a producer?

    You are a producer in a Member State if any of the following applies to your business.

    You import packaged goods. If you buy packaged products from another Member State or a third country and supply them within your own Member State, you are the producer in that territory.

    You sell cross-border via e-commerce. If you sell directly to end-users in another Member State, you are the producer in the destination country, regardless of where your business is established.

    You unpack goods commercially. If your business unpacks packaged products and you are not the final end-user, you assume the producer role for that packaging.

    One exception: “point-of-sale packaging”. If transport, primary production, or service packaging is filled at the point of sale, such as a local shop providing plastic bags for produce or a fry shop handing out their product in paper cones, the producer is the manufacturer, importer, or distributor who originally supplied the empty packaging. This exception exists to reduce the administrative burden on small businesses.

    What producers must do

    Register in every Member State where you sell. Producers must register in the national producer register of every Member State where they first make packaging available. Operating without registration is legally prohibited and can result in a market ban.

    Appoint an authorised representative where you are not established. If your company is established outside the EU and you sell packaged goods into an EU Member State, you must appoint a local Authorised Representative (AR) by written mandate to fulfill your EPR obligations. If your company is established within the EU, the baseline PPWR requires a local AR when selling cross-border into another Member State. However, a pending EU legislative proposal (COM(2025) 982) aims to suspend this local AR requirement for EU-established businesses until 2035. Companies should monitor the final adoption of this “Omnibus” package, as direct national registration may apply instead.

    Take on Extended Producer Responsibility. Producers bear the financial and organisational responsibility for end-of-life packaging management: collection, sorting, and recycling. Most producers meet this by joining a Producer Responsibility Organisation (PRO). In some Member States, joining a PRO is legally mandatory.

    Provide a financial guarantee. In cases where producers act individually instead of joining a PRO, they must obtain official authorisation from the competent authority and maintain an adequate financial guarantee to cover waste management costs.

    Report annually. Producers must submit annual reports detailing the quantities and categories of packaging placed on the market for the first time.

    Inform consumers. Producers must provide end-users with information on packaging waste prevention, reuse arrangements, label meanings, and correct disposal methods.

    How PAQR can help

    Understanding your producer obligations starts with knowing exactly what packaging you have placed on the market, in which categories, and with what documentation behind it. PAQR gives you a central workspace to organize this data by packaging format and market, so when annual reporting or an audit requires it, the information is structured and ready.

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

  • Your PPWR Compliance Checklist for August 12, 2026

    Your PPWR Compliance Checklist for August 12, 2026

    4 minute read

    From August 12, 2026, packaging placed on the EU market must meet PPWR’s chemical restrictions, and every manufacturer of packaging or packaged goods must have a valid Declaration of Conformity in place. This PPWR compliance checklist covers the four phases to work through before the deadline.

    Phase 1: Determine Your Legal Role and EPR Status

    ☐ Identify your supply chain role. Establish whether PPWR classifies your business as a Manufacturer (you produce packaging or sell it under your own brand), an Importer (you bring packaging into the EU), or a Distributor (you make packaging available on the market after the manufacturer or importer). Your role determines your compliance obligations.

    ☐ Check the Brand Rule. If you are an importer or distributor but sell packaging under your own name or trademark, or if you modify packaging in a way that affects compliance, PPWR classifies you as the Manufacturer. You carry all manufacturer obligations.

    ☐ Confirm your Producer status for EPR. If you are the first business to make packaging available in a specific Member State, you are a Producer under PPWR and must register in that country’s national producer register. This applies per Member State, so selling into multiple markets may mean multiple registrations.

    Phase 2: Map Your Packaging Portfolio

    ☐ Break down packaging by component and material. Plastic food containers face different regulatory requirements than cardboard or glass. Map each packaging unit by component and material type before starting your compliance assessment.

    ☐ Prepare for a consolidated Declaration of Conformity. PPWR requires a single EU Declaration of Conformity covering all applicable Union acts, including overlapping directives and harmonized standards. A gap in any one of those acts could undermine the entire compliance dossier.

    Phase 3: Audit Food-Contact Packaging for Chemical Restrictions

    The August 12, 2026 chemical restrictions apply specifically to food-contact packaging. If any of your packaging touches food, complete this phase in full.

    ☐ Identify all food-contact packaging in your portfolio.

    ☐ Verify heavy metals limits. Obtain documentation confirming that the combined concentration of lead, cadmium, mercury, and hexavalent chromium does not exceed 100 mg/kg.

    ☐ Address the total fluorine rule. If your packaging’s total fluorine (TF) content exceeds 50 mg/kg, you must obtain documentation differentiating PFAS-sourced fluorine from non-PFAS fluorine. A standard material declaration is not sufficient.

    ☐ Secure PFAS declarations from suppliers. If TF exceeds the 50mg/kg limit, you need structured test results confirming PFAS concentrations to not meet or exceed:

    • 25 ppb for any single targeted PFAS
    • 250 ppb for the sum of targeted PFAS
    • 50 ppm for total PFASs, including polymeric PFAS

    Phase 4: Finalize Your Documentation

    ☐ Compile your Annex VII technical documentation. Gather conformity assessments and supporting documentation proving your packaging meets PPWR’s sustainability and safety requirements.

    ☐ Issue the EU Declaration of Conformity. Formally issue the single EU DoC based on your completed conformity assessment.

    ☐ Set up your retention system. The DoC and technical documentation must be kept available for national authorities for:

    • 5 years for single-use packaging
    • 10 years for reusable packaging

    Importers must retain a copy of the DoC for the same timeframes.

    How PAQR can help

    Working through this checklist generates a significant volume of supplier data, compliance documentation, and technical files that need to be structured, stored, and available for audit.

    PAQR’s supplier request portal lets you collect PFAS declarations, heavy metals certifications, and material documentation directly from your suppliers. Responses are stored centrally alongside your component data and compliance records in one auditable workspace. When your technical files are complete, you can generate your Declaration of Conformity from the same platform.

    Get a head start on PPWR implementation. Click “Try now for free” on paqr.com to start a free trial.

  • PPWR PFAS Restrictions: What Food-Contact Packaging Teams Need to Know

    PPWR PFAS Restrictions: What Food-Contact Packaging Teams Need to Know

    6 minute read

    From August 12, 2026, food-contact packaging placed on the EU market must meet specific PPWR PFAS concentration limits under the Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40). The thresholds are precise, the data requirements are demanding, and the documentation burden falls directly on your supply chain as manufacturer.

    This post covers the PPWR PFAS restrictions your team needs to prepare for, the supplier data you must secure, and how to structure your technical documentation before the deadline.

    1. How the PPWR Defines PFAS

    Before requesting supplier data, it is worth agreeing on exactly what the regulation targets. Under article 5 of the PPWR, PFAS is defined as any substance that contains at least one fully fluorinated methyl (CF3-) or methylene (-CF2-) carbon atom, without any hydrogen, chlorine, bromine, or iodine attached to it.

    The definition includes specific exceptions. If a substance only contains CF3-X or X-CF2-X’ groups, where X or X’ is a methyl, methylene, aromatic group, or carbonyl group, it may fall outside the restriction. Your packaging team should cross-reference the exact chemical structures of your materials against these exemptions before drawing conclusions.

    2. The Three Critical PFAS Thresholds

    Starting August 12, 2026, food-contact packaging cannot be placed on the market if PFAS concentrations meet or exceed any of the following limits:

    • 25 ppb for any single PFAS, measured using targeted PFAS analysis. Polymeric PFAS are excluded from this quantification.
    • 250 ppb for the sum of PFAS, measured as the sum of targeted PFAS analysis. Polymeric PFAS are also excluded here.
    • 50 ppm for total PFAS. This threshold is broader: it includes polymeric PFAS.

    The distinction between the first two thresholds and the third matters. Targeted analysis covers specific PFAS compounds. Total PFAS analysis is wider and will catch materials that appear compliant under targeted testing alone. Your technical documentation needs to address all three.

    3. The “Total Fluorine” Trap

    This is where many packaging teams run into difficulty, and it is worth understanding before you start collecting supplier data.

    If a packaging material’s total fluorine content exceeds 50 mg/kg, you cannot assume compliance. At that point, the manufacturer, importer, or downstream user is legally required to demonstrate how much of that fluorine comes from PFAS and how much does not.

    In practice, this means a standard material declaration from your supplier is not enough. You need documentation that differentiates between PFAS-sourced fluorine and non-PFAS fluorine, and that breakdown must form part of your Annex VII technical files. If a supplier cannot provide this, treat it as a procurement issue to resolve now.

    4. Other Chemical Restrictions to Prepare For

    PFAS is the most technically demanding restriction, but your compliance files must also cover two additional areas.

    • Heavy metals: The combined concentration of lead, cadmium, mercury, and hexavalent chromium in packaging and its components cannot exceed 100 mg/kg. This threshold applies to the sum of all four metals, not to each individually.
    • Bisphenol A (BPA): A comprehensive restriction on BPA applies across food packaging and food-contact materials. Factoring in the 18-month general transition period, managing BPA-free supply chains alongside the new PPWR chemical thresholds is a parallel compliance priority for 2026. If BPA has not yet been addressed in your technical documentation, it should be.

    5. What to request from your suppliers

    Your suppliers may not be accustomed to providing this level of chemical analysis, and some will need clear guidance on what is required. Here is the breakdown of what your technical files must contain for each food-contact material.

    For PFAS:

    • Targeted PFAS analysis results, listing individual PFAS compounds and concentrations in ppb
    • Sum of PFAS concentrations, including results with prior precursor degradation where applicable
    • Total PFAS measurement in ppm, covering polymeric PFAS
    • Where total fluorine exceeds 50 mg/kg: a breakdown confirming the quantity of PFAS-sourced versus non-PFAS fluorine

    For heavy metals:

    • Declarations or test results showing combined lead, cadmium, mercury, and hexavalent chromium concentrations below 100 mg/kg

    For BPA:

    • Declaration of compliance according to Annex III of the Commission Regulation (EU) 2024/3190, confirming the BPA-free formulation, or documentation of BPA use within permissible limits.

    Request these in a structured format that can be stored and retrieved as part of your formal technical documentation.

    How PAQR can help

    The PFAS documentation challenge is largely a data collection and organisation problem. Your suppliers need to know exactly what to send, you need a structured place to store it, and your technical files need to be complete and retrievable when an audit requires them.

    PAQR’s supplier request portal lets you send targeted data requests directly to your suppliers, specifying exactly which declarations, test results, and certifications you need. Responses are stored centrally alongside the rest of your packaging data, so your PFAS declarations, heavy metal certifications, and BPA confirmations sit in the same auditable workspace as your component specs, recyclability assessments, and supplier certificates.

    When you are ready to generate your Declaration of Conformity, the documentation you have collected feeds directly into the process.

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

  • Clarity on PPWR Reuse: The Exemption for Pallet Wrappings and Straps was officially published on May 6, 2026

    Clarity on PPWR Reuse: The Exemption for Pallet Wrappings and Straps was officially published on May 6, 2026

    3 minute read

    The transition to the Packaging and Packaging Waste Regulation (PPWR) is often seen as a steep climb for manufacturers and suppliers. However, the latest update from Brussels offers a significant sigh of relief for logistics operations.

    Commission Delegated Decision (EU) 2026/429, published this week, introduces a critical exemption regarding the reuse of pallet wrappings and straps.

    Here is what you need to know, without the legal jargon.

    The Background: The 100% Reuse Target

    Under the original PPWR framework (Article 29), transport packaging used for shipments within the same company or between partner sites in the EU was subject to a strict 100% reuse target. For many of you, this meant a looming requirement to transition all stretch foil, plastic wrapping, and metal or plastic strapping to reusable alternatives by the deadline August 12, 2026.

    The Change: A Practical Exemption

    The Commission has recognized that for many packaging lines, the shift to 100% reusable wrappings is currently technically difficult and financially disproportionate. High investment costs in automated packaging lines and a lack of market-ready, scalable reusable solutions for these specific formats would have caused significant supply chain disruption.

    The Decision: Economic operators are now exempted from the 100% reuse requirements for:

    1. Pallet wrappings (e.g., stretch and shrink films)
    2. Straps (used for stabilization and protection during transport)

    This applies specifically to the mandates for internal company transfers and domestic B2B shipments.

    Marketing teams can update digital content without reprinting packaging. Recalls can be precise to individual units. Country-specific information can be served dynamically. Sustainability stories surface at the moment of consumer engagement without cluttering the design.

    What this means for your operations

    • Reduced Capex Pressure: You are no longer legally mandated to overhaul your packaging lines to accommodate reusable pallet stabilization systems for internal or domestic transport in the immediate term.
    • Focus on Recyclability: While the reuse mandate for these specific items is lifted, the requirements for recyclability and recycled content targets under the broader PPWR still apply. Your focus should remain on sourcing high-quality, recyclable films.
    • Reporting remains key: Even with exemptions, data is the backbone of compliance. You still need to accurately track the volumes of these materials to meet your annual reporting obligations and EPR (Extended Producer Responsibility) requirements.

    How PAQR helps

    At PAQR, we believe compliance should be a competitive advantage, not a headache. Our platform is already updated to reflect these regulatory shifts.

    We help you categorize your packaging formats accurately so that you benefit from every available exemption while staying fully compliant with the targets that do remain.

    The bottom line: You can keep your pallets secure with traditional wrappings for now, just make sure your data is as secure as your cargo.

  • Mastering PPWR in Six Moves: A Compliance Blueprint for European Businesses

    Mastering PPWR in Six Moves: A Compliance Blueprint for European Businesses

    6 minute read

    The EU Packaging and Packaging Waste Regulation (PPWR) replaces a patchwork of national rules with one set of laws that apply directly in all 27 Member States. It covers every package placed on the EU market, from a single wrapper to an industrial pallet.

    If you manufacture, brand, fill, import, or retail packaged goods in the EU, this is a structural change to how you operate. Below are the six strategic moves that turn PPWR from a compliance threat into an operational advantage.

    1. Audit and redesign for recyclability

    By 2030, every piece of packaging needs a Recyclability Performance Grade of A, B, or C. Anything below C is banned. By 2038, only A and B are allowed.

    What to do: Audit your portfolio now. Phase out multi-material laminates, heavily dyed plastics, and adhesives that disrupt recycling streams. Build a single source of truth for component data, including supplier specs. EPR fees will be modulated by your grade, so a Grade A design lowers your tax bill on every unit shipped.

    2. Cut packaging size and ban shipping air

    Packaging weight and volume must be reduced to the minimum needed for function, hygiene, and safety. Double walls and false bottoms are banned. The empty space ratio in transport, grouped, and e-commerce packaging is capped at 50%, and void-fill materials like bubble wrap and paper count as empty space.

    What to do: Invest in box-on-demand technology or smart packing algorithms. Document your minimisation logic in technical files for every primary package.

    3. Lock in recycled plastic supply

    Mandatory minimum post-consumer recycled (PCR) content takes effect January 1, 2030.

    • 30% for contact-sensitive PET packaging
    • 10% for contact-sensitive non-PET plastics
    • 30% for single-use plastic beverage bottles
    • 35% for all other plastic packaging

    Targets jump again by 2040, hitting 65% for beverage bottles and other non-contact-sensitive plastics.

    What to do: Start procurement conversations with recyclers now. Long-term contracts beat last-minute scrambles. Make sure recycled inputs comply with Regulation (EU) 2022/1616 on food-contact safety.

    4. Build reuse into core operations

    By 2030, at least 40% of transport packaging must be reusable, aiming for 70% by 2040. Inter-site and intra-Member-State transport packaging must be 100% reusable. Beverage distributors must offer at least 10% of products in reusable formats. By 2027, HORECA businesses must let consumers bring their own containers at no extra cost.

    What to do: Treat reuse as a core logistical operation, not a sustainability project. Invest in reverse logistics, durable formats, and cleaning facilities. The regulation legally protects HORECA operators from food safety liability when consumer containers are involved.

    5. Eliminate restricted chemicals and formats

    From August 12, 2026, food-contact packaging cannot exceed 25 ppb for specific targeted PFAS, 250 ppb for the sum of PFAS, or 50 ppm for total PFASs. If total fluorine exceeds 50 mg/kg, you must be able to prove the fluorine does not come from PFAS. Heavy metals (lead, cadmium, mercury, hexavalent chromium combined) cannot exceed 100 mg/kg. By 2030, dine-in disposables, hotel miniatures, and retail-grouping shrink wrap are banned.

    What to do: Test your packaging for PFAS and heavy metals now. If your suppliers cannot provide composition declarations, treat that as a procurement problem to fix immediately. Limit compostable materials to the narrow categories the regulation specifies, otherwise you contaminate recycling streams.

    6. Modernise your compliance documentation

    Every package needs a conformity assessment, technical documentation, and an EU Declaration of Conformity before it goes to market. Records must be kept for 5 years (single-use) or 10 years (reusable). EPR registration is required in every Member State you sell into. By August 12, 2028, packaging must carry a harmonised pictogram label for sorting. Furthermore, by February 12, 2029, reusable packaging must carry a QR code or digital data carrier to track trips and rotations.

    What to do: Digitise compliance tracking. Build a system that generates and stores Declarations of Conformity automatically, alerts you when supplier data changes, and produces audit-ready files on demand. Importers carry the same legal burden as domestic manufacturers, so document verification needs to happen before customs clearance.

    The bottom line

    Companies that treat PPWR as a compliance hurdle will absorb rising EPR fees, supply chain bottlenecks, and product recalls. Companies that audit their portfolios now, lock in recycled plastic contracts, right-size their boxes, and digitise their documentation will move from compliance into competitive advantage.

    The window to act is open. 

    PAQR is the single source of truth for your packaging data. Generate Declarations of Conformity, track supplier data, and stay audit-ready as the regulation evolves. Click “Try now for free” on paqr.com to start a free trial.

  • PPWR’s Grey Areas: What The European Commission’s March 2026 Guidance Actually Clears Up (And What It Doesn’t)

    PPWR’s Grey Areas: What The European Commission’s March 2026 Guidance Actually Clears Up (And What It Doesn’t)

    4 minute read

    On March 30, 2026, the European Commission released its long-awaited guidance document for the EU Packaging and Packaging Waste Regulation (PPWR), which becomes fully applicable on August 12, 2026.

    The document is 56 pages. It clarifies a lot. It also explicitly leaves much unresolved, noting that it only addresses questions where there is “evident margin of legal discretion.” Everything else is being pushed to a future, non-binding FAQ.

    Here are four areas where the guidance still leaves businesses exposed.

    1. The flowerpot problem (function-based definitions)

    Whether something counts as “packaging” depends on its intended use, not its physical form. The Commission’s example is a flowerpot. The same pot is non-packaging when used for cultivation in a nursery, but becomes packaging the moment a plant is sold to an end consumer in it.

    In practice, plants are rarely transplanted between cultivation and sale. The classification still has to follow the function. Growers are now in a difficult position around which pots fall under EPR and recyclability rules.

    2. The PFAS stockpile cliff

    From August 12, 2026, food-contact packaging cannot be placed on the market if it exceeds 25 ppb for specific targeted PFAS, 250 ppb for the sum of PFAS, or 50 ppm for total PFASs, and if total fluorine exceeds 50 mg/kg, the operator must prove it does not stem from PFAS. However, the “stockpile cliff” primarily impacts manufacturers, as the regulation actively protects downstream inventory. Because “placing on the market” refers to the first making available on the Union market, packaging already in the stocks of distributors (including retailers and wholesalers) before the deadline is legally exempt from these new sustainability restrictions. This means fillers and distributors are protected, provided their suppliers beat the August 2026 deadline for new shipments.

    3. The micro-enterprise loophole

    If the brand owner is a micro-enterprise and the supplier is in the same Member State, the supplier becomes the legal “manufacturer” for compliance purposes.

    This was meant to protect small businesses. In practice, it creates a due-diligence burden: suppliers now need to verify the size and location of every customer to determine who carries the legal responsibility for the package’s technical documentation.

    4. “Sales packaging used for transport” is undefined

    Article 29 introduces 40% reuse targets for transport packaging by 2030. It also covers “sales packaging used for transporting products,” which includes pails, drums, and canisters.

    The guidance acknowledges that some of these formats may require “disproportionate costs” to clean (think viscous materials like paint or chemicals), but leaves the determination of “disproportionate” to the operator. This effectively creates a loophole that could undermine the 40% target.

    What’s coming next

    The March 2026 guidance is the first layer of regulation. Over the next few years, the Commission will publish further binding legislation, including:

    • Delegated acts establishing harmonised methodologies for design for recycling criteria and recyclability performance grades (due by January 1, 2028).
    • Delegated acts establishing the minimum number of rotations for reusable packaging (due by February 12, 2027).
    • Implementing acts detailing the exact specifications for harmonised waste-sorting labels and reusable packaging digital labels/QR codes (due by August 12, 2026)

    What businesses should do now

    Do not wait for the implementing acts. Update your technical documentation now, especially around PFAS content and recyclability. Map your exposure to the four ambiguities above and document the assumptions you are making.

    The transition from the old PPWD to the new PPWR is a fundamental shift in legal liability and design requirements. Industry will be operating in flux for years. Companies that build defensible documentation early will weather that flux without disruption.

    PAQR keeps your packaging documentation current as the regulation evolves. Every supplier change, every formulation update, every regulatory clarification flows through your records automatically. Click “Try now for free” on paqr.com to start a free trial.

  • PPWR: A Complete Guide to the EU’s Circular Economy Overhaul

    PPWR: A Complete Guide to the EU’s Circular Economy Overhaul

    7 minute read

    EU packaging waste hit 173 kg per capita in 2018 and was projected to keep climbing. Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation (PPWR), is the EU’s response.

    It replaces a 30-year-old Directive that produced a patchwork of inconsistent national rules. PPWR applies directly in all 27 Member States with one set of laws covering the entire packaging lifecycle, from chemical design to end-of-life recycling.

    Here are the eight things every business needs to understand about PPWR.

    1. Waste prevention and minimisation

    Member States must reduce per-capita packaging waste by 5% by 2030, 10% by 2035, and 15% by 2040, against a 2018 baseline.

    By 2030, all packaging must be designed to the minimum weight and volume needed for function, safety, and hygiene. Double walls and false bottoms are banned. Empty space in transport and e-commerce packaging is capped at 50%, with bubble wrap and paper fillers counting as empty space.

    By 2030, single-use formats including hotel miniatures, retail-grouping shrink wrap, and dine-in food and beverage disposables in HORECA premises are banned outright.

    2. Reuse and refill targets

    Reusable packaging must be designed to complete a minimum number of rotations within a formal reuse system.

    • Transport packaging: 40% reusable by 2030, 70% by 2040. 100% for inter-site or intra-Member-State movement.
    • Beverages: 10% in reusable packaging by 2030, climbing toward 40% by 2040.
    • HORECA: by 2027, consumers can bring their own containers at no extra cost. By 2028, reusable purchase options must be offered.

    Micro-enterprises and final distributors with sales areas under 100 square meters are exempt.

    3. Universal recyclability

    All packaging on the EU market must be recyclable, assessed in two stages.

    Stage 1 (2030): Design for Recycling. Each package gets a Recyclability Performance Grade of A, B, or C. Anything below C (less than 70% recyclable by weight) is banned. EPR fees are modulated by grade.

    Stage 2 (2035): Recycled at Scale. Theoretical recyclability is no longer enough. Packaging must be proven to be collected, sorted, and recycled in real-world infrastructure. By 2038, Grade C is also banned, leaving only A and B.

    Innovative materials may qualify for a 5-year derogation while collection infrastructure develops.

    4. Recycled content in plastic packaging

    Mandatory minimum post-consumer recycled (PCR) content for plastic packaging takes effect January 1, 2030.

    By 2030: 30% PCR for contact-sensitive PET, 10% for non-PET contact-sensitive, 30% for single-use plastic beverage bottles, 35% for all other plastic packaging.

    By 2040: 50% PCR for contact-sensitive PET, 25% for non-PET, 65% for beverage bottles and other plastics.

    Targets are calculated as an annual average per manufacturing plant, giving operational flexibility. Medical devices, medicinal products, and specialised infant food packaging are exempt for safety reasons.

    5. Chemical safety and PFAS

    From August 2026, food-contact packaging cannot contain PFAS above 25 ppb (targeted) or 50 ppm (total fluorine).

    Heavy metals (lead, cadmium, mercury, hexavalent chromium combined) cannot exceed 100 mg/kg in any packaging.

    A circular economy cannot recycle hazardous chemicals back into new products. The regulation closes that loop.

    6. Compostable packaging, narrowly defined

    Compostable formats are restricted to a small list to avoid contaminating recycling streams:

    • Sticky labels on fruits and vegetables
    • Filter coffee pods and tea bags
    • Very lightweight plastic carrier bags

    Standard plastic packaging should be designed for material recycling, not composting. Claims about home compostability will face heavy scrutiny because home conditions vary too widely to break down industrial bioplastics safely.

    7. Harmonised labelling and Deposit Return Systems

    By August 2028, all packaging must carry a uniform pictogram label showing material composition. The same pictograms will appear on municipal waste bins, so consumers can match packaging to the correct disposal stream.

    By February 2029, reusable packaging must carry a QR code or digital data carrier tracking rotations and collection points.

    By January 2029, every Member State must have a Deposit Return System for single-use plastic and metal beverage containers up to 3 litres, designed to hit a 90% separate collection rate.

    8. Compliance and Extended Producer Responsibility

    PPWR follows the “polluter pays” principle. The Producer (typically the brand owner, importer, or retailer placing the packaged product on the market) carries the financial and legal burden.

    Producers must register in a national EPR database in every Member State they sell into. They pay fees to a Producer Responsibility Organisation, with fees modulated by the packaging’s recyclability grade and recycled content.

    Manufacturers must perform conformity assessments, compile technical documentation, and issue an EU Declaration of Conformity before placing any packaging on the market. Importers and distributors are legally required to verify these documents exist before selling. Non-compliant packaging gets blocked at the border.

    The takeaway

    PPWR is one of the most ambitious environmental laws in EU history. Major milestones hit in 2026, 2030, and 2035, and every part of the supply chain (design, procurement, manufacturing, logistics, retail) needs to adapt.

    PAQR turns PPWR compliance into a workflow. Generate Declarations of Conformity, manage supplier data, and prepare for every milestone in one platform. Click “Try now for free” on paqr.com to start a free trial.