Key Evaluation Criteria at a Glance:

• Data architecture: component-level packaging data model, not documents stored as attachments.
• Long-term storage: structured for the five-to-ten-year retention PPWR requires for Declarations of Conformity and technical documentation.
• Extensibility: built on structured data that can extend into Digital Product Passport (DPP) requirements and EPR reporting, not just today’s Declaration of Conformity.
• Collaboration: multi-entity, multi-language internal support, plus a structured way to request data from suppliers directly.
• Integration: works with the ERP or PLM system you already run, instead of requiring significant changes to IT systems.
• Regulatory tracking: provider actively tracks and builds for new Commission guidance and delegated acts, not just the original 2025 text.

It Treats Packaging as Structured Data, Not Stored Documents

When evaluating options, look for a tool that models packaging as structured components, mapping supplier certificates and material declarations directly to specific parts rather than treating them as isolated files.

Why it matters: Storing supplier documentation is essential, but documents need context to remain useful over time. When certificates and declarations are mapped at the component level, every component retains its own material composition, supplier details, and compliance status, ready to be reused across every product sharing that part.

This structured approach ensures your data remains durable. The component records you build to meet the initial PPWR requirements for August 2026 become a multi-year foundation. When a supplier updates a formulation or additional regulatory deadlines arrive, your team can update the central component record once, automatically reflecting changes across your entire packaging portfolio without starting from scratch.

It Handles Collaboration, Not Just Data Entry

When evaluating a PPWR compliance tool, consider whether it supports the specific types of collaboration your business actually needs. Compliance is rarely managed in a vacuum, so the tool you choose should simplify communication both inside your organization and across your extended supply chain.

Internal Collaboration

If your company operates across multiple legal entities, brands, or geographic markets, your compliance team is rarely a single unit working in one language on a shared packaging portfolio. Look for a PPWR compliance tool that supports multi-language interfaces and allows you to configure multi-entity organizational structures. This ensures the software flexes to fit how your business is structured rather than forcing you into a single-user setup.

External Collaboration

Beyond internal workflows, evaluate how the tool manages communication with external partners like suppliers and downstream business partners.

• Upstream Suppliers: Most of the technical data required for compliance, such as material breakdowns, recycled content percentages, and PFAS test results, sits with your suppliers. Look for a tool that allows you to issue direct data requests in the supplier’s native language, track response statuses in real time, and update records as formulations change without requiring suppliers to onboard onto a complex platform.
• Downstream Partners: Once compliance is established, you will need to share the results. Consider whether the tool allows you to seamlessly export or share final Declarations of Conformity, technical documentation, and compliance statuses directly with retail partners, distributors, and auditing bodies.

It Fits Into What You Already Run, Rather Than Replacing It

Packaging data usually already exists inside your organization, whether in an ERP system, a PLM platform, or specification sheets maintained by product development. Look for a PPWR compliance tool that can ingest your existing data (such as material IDs, descriptions, and suppliers), allow you to add further technical granularity directly within the tool, and layer compliance logic on top.

Why it matters: ERP systems are designed for purchasing and inventory rather than deep regulatory attributes, while re-entering data manually creates a redundant second source of truth. Before committing to a solution, evaluate the import options and native integration capabilities directly to ensure the tool connects smoothly with your current technology stack.

It Delivers Audit-Ready Output and Retains Data for 5 to 10 Years

The primary output of PPWR compliance is not an internal dashboard; it is a legally binding Declaration of Conformity supported by robust technical documentation. Look for a compliance tool that generates these complete document packages while securely maintaining historic records for the required 5 to 10 year retention period.

Why it matters: Market surveillance authorities demand traceable, defensible evidence. When evaluating software options, ensure the platform delivers on these core capabilities:

• Long-Term Data Retention: PPWR rules require technical documentation to remain retrievable for 5 to 10 years after packaging is placed on the market. The tool should allow you to pull a component’s exact historical record from five years ago as easily as today’s active version.
• Complete Audit Trails: Generated documentation should show its work. The system should trace every statement in a Declaration of Conformity back to the specific supplier inputs, documents, and material assessments used at that point in time.
• Support for Specific Labeling Obligations: Specific provisions, such as Article 15 requirements for packaging identifiers and manufacturer contact details, require verifiable underlying data. These obligations can be streamlined directly on packaging; for more on this topic, see our breakdown on how one QR code solves core Article 15 obligations.

While managing current documentation is essential, the remaining considerations focus on choosing a foundation that adapts as PPWR and related European regulations continue to evolve.

Consider Purpose-Built Packaging Tools vs. Broader ESG Suites

Both purpose-built packaging platforms and broader ESG compliance suites serve clear purposes. The right fit depends on your organization’s existing software stack and primary compliance goals.

Broader ESG Suites

If your organization already uses an enterprise ESG platform to manage carbon footprints, CSRD disclosures, and broader corporate sustainability reporting, adding a packaging module within that same system can be a logical choice. It helps keep broad sustainability metrics in one centralized place. If you choose this route, verify that the packaging module provides enough technical depth for PPWR, particularly around component-level material breakdowns and supplier data collection.

Purpose-Built Packaging Platforms

A purpose-built platform provides the granular technical foundation for all your packaging compliance needs, as they extend over time, unified in a single database with one intuitive interface. Today, it handles immediate priorities like PPWR conformity and supply chain data exchange. As requirements evolve, that same foundation effortlessly scales to support EPR fee reporting, perform recyclability assessments on granular packaging data, and manage Digital Product Passports.

What to verify regardless of your choice:

• Can the system track material data at the individual component level, including multi-layer structures?
• Does it support supplier collection workflows tailored specifically to packaging specifications?
• Can it handle packaging-focused calculations, such as empty space ratios and recyclability requirements?

It Keeps Pace with Ongoing Regulatory Updates

Look for a PPWR compliance tool backed by a vendor that actively tracks EU regulatory developments and updates its software logic as secondary legislation is finalized.

Why it matters: PPWR relies heavily on delegated and implementing acts phased in between now and 2030. Key calculation methodologies, including empty space ratio formulas, recyclability performance grading criteria, and recycled content verification standards, continue to be detailed through official Commission guidance and implementing acts.

When evaluating vendors, consider how ongoing regulatory tracking is handled:

• Automated System Logic Updates: Check whether the platform updates its underlying calculation models automatically when new implementing acts land, or if your team must manually reconfigure rules.
• Reduced Internal Interpretation Burden: Ongoing regulatory monitoring by the software provider ensures your compliance team spends less time interpreting legal texts and more time managing packaging operations.
• Long-Term Regulatory Roadmap: Ensure the provider maintains an active product development roadmap aligned with upcoming EU milestones through 2028 and 2030.

A Few Questions Worth Writing Down

When evaluating software vendors, these targeted questions can assess whether a platform provides a long-term foundation for your business:

• Does it model packaging at the component level, or only at the product level?
• Is packaging compliance the core product, or one module inside something broader?
• How does the provider track and incorporate new Commission guidance and implementing acts?
• Can multiple entities, brands, and languages work inside the same system?
• How do suppliers submit data, and what does that experience actually look like for them?
• Does it work with the ERP or PLM system you already use, or does it require fundamental changes to your IT landscape?
• Can a generated Declaration of Conformity be traced back to the underlying evidence?

Frequently Asked Questions

What should I consider when contracting PPWR software?
Focus on whether the platform models packaging as structured, component-level data rather than stored PDFs, integrates with your existing ERP/PLM systems, retains historical records for 5 to 10 years, and updates automatically as new Commission guidance lands through 2030. You should also evaluate whether a specialized packaging tool or a broader ESG suite best matches your team’s operational needs.

What should I look for in a PPWR tool specifically for supplier collaboration?
Look for a system that lets you issue structured data requests to suppliers in their native language without requiring them to buy platform licenses. The tool should provide real-time tracking of submission statuses, highlight missing details, and track formulation changes automatically over time.

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:

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:

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:

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.

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.

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.