PPWR: new packaging data obligations from August 2026
The EU Packaging Regulation applies from 12 August 2026. It turns packaging into a regulated product with conformity assessment and evidence obligations. Not every requirement bites immediately. The conformity process does.
More than 200 companies trust Narravero
The PPWR applies from directly in every EU member state. The legal basis is Regulation (EU) 2025/40. Contrary to what the headlines suggest, not every requirement switches on at once. The PPWR is staged, and several central obligations depend on acts that have not yet been adopted.
What does apply immediately is the conformity process: you need to know which requirements apply to your packaging, you need to be able to demonstrate them, and you need to have the data under control. This is not a labelling task. It is a data task. This overview sets out who carries responsibility under the PPWR, which deadlines actually bite, what is fact and what is rumour on labelling, and how the PPWR connects to the Digital Product Passport.
What applies from 12 August 2026
Evidence
You may only place packaging on the market once you have assessed its conformity
Art. 15(1) and (2), Art. 38
Documentation
Technical files covering intended use, drawings, production drawings, materials, specifications, assessments and test reports
Art. 15(2) and (3), Annex VII(2)
Declaration
A written EU declaration of conformity per packaging type, through which you take responsibility
Art. 15(2), Art. 39, Annex VIII
Identifier
A type, batch or serial number on the packaging, or in the accompanying documents
Art. 15(5)
Substances
Minimise substances in the packaging and stay within the applicable substance and concentration limits
Art. 5
Registration
Register as a producer before you first make packaging available, separately in each member state
Art. 44(2) and (4)
What to do from 12 August 2026
The start of application is not a deadline by which everything must be finished. It is the day from which you must be able to evidence conformity for every type of packaging you place on the market. Five things matter immediately. Everything else builds on them.
| What | Why now | Legal basis |
|---|---|---|
| Determine your role per product and market | Without this you do not know which obligations apply to you at all. It cannot be done retrospectively. | Art. 3(1)(13), (15), (16) |
| Register as a producer | Without registration you may generally not make packaging available in that member state for the first time. Separately per country. | Art. 44(2) and (4) |
| Carry out the conformity assessment | Before placing on the market, for whichever requirements in Articles 5 to 12 already apply. | Art. 15(1) and (2), Art. 38 |
| Create technical documentation and the declaration of conformity | Per packaging type, in writing. With the declaration you take responsibility for conformity. | Art. 15(2) and (3), Art. 39, Annex VII and VIII |
| Be ready to respond | Authorities can request documents. You then have ten days, electronically. | Art. 15(10) |
What does not apply immediately: recyclability criteria, minimum recycled content, weight minimisation and harmonised material labelling. These phase in from 2028 and 2030 and partly depend on acts that have not been adopted. Anyone redesigning packaging now is doing so for commercial reasons, not because of an immediate obligation.
Key point From 12 August 2026 what counts is the evidence process, not the packaging design.
What is the PPWR?
The PPWR is the EU Packaging and Packaging Waste Regulation, formally Regulation (EU) 2025/40 on packaging and packaging waste. It replaces the previous Packaging Directive and, as a regulation, applies directly in every member state without national transposition.
The PPWR governs two things that are often conflated in practice. First, requirements for the packaging itself: which substances it may contain, how recyclable it must be, how much recycled content it needs, how heavy and how large it may be, how it is labelled. That is Articles 5 to 12. Second, extended producer responsibility: who has to register, report volumes and pay for waste management later on.
Both pillars draw on the same data. Materials, weights, components, product assignment. Handle them separately and you maintain the same information twice.
One important point about the start date: the regulation applying from 12 August 2026 does not mean that every substantive requirement in Articles 5 to 12 is fully applicable on that day. Several take effect later or depend on delegated and implementing acts that had not been adopted when application began. What does apply immediately is the obligation to run a robust conformity process for the requirements already in force and to prepare for the later stages.
Key point The PPWR applies from 12 August 2026, but not every requirement does. The conformity process does.
The PPWR and national packaging law
If you already place packaging on a national market, you know the local packaging law, the national register and the compliance scheme fees. That world does not disappear. It now sits inside a European framework.
The essential difference is reach. National packaging law mainly governs waste responsibility inside one country. The PPWR additionally governs the product itself: it turns packaging into a regulated product with conformity assessment, technical documentation and an EU declaration of conformity. That is a different order of legal obligation. It is the logic familiar from product safety law, applied to packaging.
In practice: registration and volume reporting stay national, with national systems. Conformity of the packaging becomes European, with uniform requirements. And because both strands need the same packaging data, there is finally a real reason to hold that data in one place rather than in separate processes.
Key point The PPWR adds genuine product conformity for the packaging itself on top of national waste responsibility.
Who is the manufacturer? The PPWR roles
This is where most companies take the wrong turn. The PPWR knows several roles, and they do not depend on who physically produces the packaging.
The manufacturer under Article 3(1)(13)(a) is whoever has packaging or packaged products designed or made and places them on the market under their own name or trademark. The manufacturer carries responsibility under product law for the packaging. Across the supply chain there is only one manufacturer for any given packaging.
The producer under Article 3(1)(15) is the company that becomes responsible for the packaging in the member state where it is first made available and is likely to become waste. EPR stands for extended producer responsibility. The distinction between this role and the manufacturer role is the one most often confused in practice.
The company that makes the packaging is usually the supplier under Article 3(1)(16). It produces and delivers the packaging together with the information the manufacturer needs to demonstrate conformity.
The key consequence: you cannot shift your responsibility as manufacturer onto the packaging supplier simply because they physically make the box. Conversely, producing the packaging alone makes a supplier neither the manufacturer nor the producer.
There are special cases that need assessing case by case: the micro enterprise rule in Article 3(1)(13)(b), neutral or unfilled standard packaging, transport and service packaging, imports from third countries, repackaging, and unusual B2B or direct-to-consumer routes. Anyone who modifies packaging already on the market in a way that could affect its conformity may themselves be treated as the manufacturer under Article 20.
Key point The manufacturer is whoever places packaging on the market under their own brand, not whoever produces it.
The key PPWR deadlines
The PPWR works with dynamic deadlines. Many requirements apply from the stated date or a set period after the relevant acts enter into force, whichever is later. If Brussels is late, the obligation moves automatically. That matters more for planning than it might seem.
| Requirement | What it means | Applies from | Basis |
|---|---|---|---|
| Application, roles, conformity process | You need to know which role you hold and be able to prove, for every type of packaging, that the applicable requirements are met. | Art. 71 | |
| Registration as a producer | Registration in every member state where you first make packaging available. Without it you generally may not place packaging there. | 12 Aug 2026, per country | Art. 44(2) and (4) |
| Substances in packaging | Restrictions on certain substances, for example PFAS in food contact packaging. You need substance evidence from your suppliers. | Generally 12 Aug 2026 | Art. 5 |
| Compostable packaging | Only affects packaging placed on the market as compostable or biodegradable. | 12 Feb 2028 | Art. 9 |
| Harmonised material labelling | A uniform EU label on the packaging showing material and disposal route. The symbols themselves are not yet defined. | 12 Aug 2028 or 24 months after the implementing acts, whichever is later | Art. 12 |
| Data carrier for reusable packaging | QR code or comparable open data carrier with information on return and the reuse system. Does not apply to open-loop systems without a system operator. | 12 Feb 2029 or 30 months after the act under Art. 12(6), whichever is later | Art. 12(2) |
| Recyclability | The packaging must be designed so it can be recycled and must reach a defined performance grade. That grade later feeds into your EPR fees. | 1 Jan 2030 or 24 months after the delegated acts, whichever is later; further stages in 2035 and 2038 | Art. 6 |
| Minimum recycled content | Plastic packaging must contain a defined share of recycled material, generally 35% for other plastic packaging. | 1 Jan 2030 or three years after the act under Art. 7(8), whichever is later | Art. 7 |
| Minimise weight and volume | Packaging may not be larger or heavier than necessary. Empty space and purely visual enlargement need to be justified. | 1 Jan 2030 | Art. 10, Annex IV |
Do not read this as an all-clear. The conformity process applies in full from 12 August 2026, and you will need the evidence at the next customer audit or the next request from an authority, not in 2028. What shifts is only the requirements for the packaging itself. Waiting for the final act before starting the data work leaves you with less time later, not more. The data you need for labelling in 2028 and recyclability in 2030 does not appear in the year of the deadline. It accumulates in the supply chain, over years, with every packaging change.
Key point Almost every PPWR deadline is dynamic and moves with the outstanding acts. The data work in front of it does not.
What the manufacturer must do
Article 15 of the PPWR bundles what you must deliver as the manufacturer. The structure will be familiar from other European product regulations.
These obligations apply in full from 12 August 2026. What phases in is not Article 15 itself but the substantive requirements in Articles 5 to 12 that it refers to. In practice: from now on you must determine, for every type of packaging, which requirements apply, assess them and document that. Only the scope of the assessment grows over the years.
| Obligation | Legal basis | What it means |
|---|---|---|
| Place only compliant packaging on the market | Art. 15(1) and (2) | Determine and assess the applicable requirements in Art. 5 to 12 before placing on the market |
| Carry out conformity assessment | Art. 15(2), Art. 38, Annex VII | Run or commission the procedure before placing on the market |
| Create technical documentation | Art. 15(2) and (3), Annex VII(2) | Description, intended use, designs, production drawings, materials, specifications, assessments, test reports |
| Issue the EU declaration of conformity | Art. 15(2), Art. 39, Annex VII(4), Annex VIII | In writing for every packaging type, taking on responsibility |
| Provide an identifier | Art. 15(5) | Type, batch or serial number or another identifier, alternatively in the accompanying documents |
| Control series production and changes | Art. 15(4), Annex VII(3) | Changes to design, characteristics and specifications can trigger a reassessment |
| Respond to authorities | Art. 15(10) | Information including technical documentation, electronically and within ten days of a reasoned request |
| Take corrective measures | Art. 15(8) and (10) | Restore conformity, if necessary withdraw from the market or recall |
Two of these rows deserve particular attention.
The ten-day deadline in Article 15(10) is the only documentation obligation for which the PPWR explicitly requires electronic provision. The technical documentation, the declaration of conformity and the supplier handover under Article 16 may also be kept on paper. Ten days sounds generous until you ask the practical question: can you produce, within ten days and for one specific packaging version, the valid technical documentation, the matching declaration of conformity and the associated test reports, including evidence of which products use that version? For many companies, that is not possible with the way documents are filed today.
10 days
is how long you have to give the authorities the required information, including the technical documentation, electronically, counted from receipt of a reasoned request.
The change clause in Article 15(4) is the quiet cost driver. Every material switch, every change of plant, every design change can trigger a reassessment. If you do not know which products and markets a changed packaging version affects, you cannot meet this obligation in a controlled way.
Your suppliers are obliged to support you here. Article 16(1) requires the company that makes the packaging, in its role as supplier, to hand over all information and documents you need to demonstrate conformity. Under recital 77 that handover may be on paper or electronic. And that is exactly the catch: a legal duty to supply does not create a usable data architecture.
Key point Only the response to authorities must be electronic, but without structured data the ten-day deadline is not realistically achievable.
PPWR labelling under Article 12
Article 12 governs the labelling of packaging, but mostly sets the framework. The graphic symbols, the specifications and the formats are not in the regulation itself. They follow through implementing acts.
For harmonised labelling of material composition: it applies from or 24 months after the relevant implementing acts enter into force, whichever is later. Until those acts are in force, the label cannot be finalised.
What you can and should do regardless: hold the material data so the later label can be generated from it. Material composition per component, individual weights, packaging category. You need that data anyway for recyclability under Article 6, recycled content under Article 7 and EPR volume reporting. The label is just one output of that data.
Key point The harmonised label is not settled yet. The data behind it can still be built today.
The QR code on packaging
One claim keeps circulating in the market: that from 2026 the PPWR requires QR codes on packaging across the board. That is not correct, and the distinction is worth making because it decides project budgets.
For general packaging labelling the PPWR does not require a QR code.
A digital data carrier does become mandatory for reusable packaging. Article 12(2) requires reusable packaging to carry a label informing end users about its reusability. Further information, for example on the availability of reuse systems and collection points, is provided via a QR code or another standardised and open digital data carrier. That carrier is meant to facilitate tracking of the packaging and the calculation of trips and rotations, or, where that is not feasible, an estimate of the average.
The timing is dynamic: from or 30 months after the implementing act under Article 12(6) enters into force, whichever is later. The 30-month period only starts when that act enters into force.
There is also an exemption that is often missed. Under Article 12(3) the labelling and data carrier obligation does not apply to open-loop systems that have no system operator under Annex VI. A blanket statement such as “all reusable packaging will need a QR code” does not hold up for that reason alone.
Worth clarifying too: the PPWR does not require individual tracking of every single packaging item. It requires that the data carrier facilitates the calculation of trips.
Key point A QR obligation exists only for certain reusable packaging and from February 2029 at the earliest, not across the board from 2026.
Extended producer responsibility and eco-modulation
The second pillar of PPWR obligations covers extended producer responsibility. As the EPR producer you have four duties, separately for each member state concerned:
- Registration before first making packaging available (Article 44(2) and (4))
- Reporting of packaging volumes, generally annually by packaging type and material category (Article 44(7) and Annex IX)
- Financing or organisationally ensuring the collection and treatment of packaging waste (Article 45 in conjunction with Articles 8 and 8a of the Waste Framework Directive)
- Where applicable, appointing a producer responsibility organisation (Article 46)
Working out the volumes is pure data arithmetic: units sold per product, multiplied by the uniquely assigned packaging version, multiplied by the material weight per packaging component. Sounds trivial. If a fashion company sells 100,000 pairs of shoes in Germany with 350 grams of cardboard packaging and 15 grams of plastic each, that gives you 35,000 kilograms of cardboard and 1,500 kilograms of plastic as a simplified figure. Those volumes have to be assigned to the right company, member state, reporting year and applicable reporting categories. National reporting logic can differ.
It gets difficult as soon as several packaging versions are in circulation during a year, products change packaging, or several markets are served. At that point the question “which packaging version was in which product in which country and when?” can no longer be answered from a spreadsheet.
On top of that comes eco-modulation. Under Article 6(8), and subject to future acts, financial contributions are to be modulated according to recyclability performance grades. For plastic packaging they may additionally be adjusted for recycled content under Article 7(7). That turns recyclability and recycled content from a compliance figure into a cost driver. If you cannot evidence the values, you will likely pay the less favourable rate.
One signal about direction of travel: Article 44(14) requires the future harmonised registration and reporting formats to be interoperable, based on open standards and machine-readable data, and transferable without vendor lock-in. The PPWR itself points towards machine-readable EPR processes.
Key point Through eco-modulation, recyclability and recycled content become a direct cost factor that has to be evidenced.
Does this apply to you?
Quick check
Three questions for a self-assessment:
- Do you place packaging or packaged products on the EU market under your own name or trademark? Then you are normally the manufacturer and carry the obligations in Article 15.
- Do you first make packaged products available in a member state? Then the EPR obligations in Articles 44 to 47 apply on top, separately per member state.
- Could you produce, today and within ten days, the complete technical documentation for one specific packaging version, including which products use that version?
The first two questions decide whether you are legally responsible. The third decides how large your project is. You need an answer to both.
Anyone placing packaged products on the EU market under their own brand is in scope, whatever the sector. What trips companies up in practice is rarely the scope question. It is matching evidence to packaging versions and products.
The pressure rarely comes from the authority
In practice the PPWR reaches many companies not through market surveillance but through their own customer relationships. Suppliers to retail are increasingly asked, contractually, to provide packaging data and conformity evidence. If you cannot deliver it, your listing is at risk.
A legal distinction is worth making here. Who holds the manufacturer role depends on whose name or trademark the packaged product is placed on the market under. That role cannot simply be passed down by contract. What can be agreed contractually is the duty to supply data. The two are frequently conflated. For you as a supplier the practical consequence is the same: you need the data. For the question of who ultimately answers to the authority, the distinction is decisive.
There is also a timing problem that appears in no deadline table: packaging changes have lead times. For printing new film or board, printers and converters typically allow around four weeks. Add shipping times of up to three months and several months can pass between the decision and the changed packaging on the shelf. The deadline that actually governs your project is therefore rarely the one in the regulation.
Key point The practical trigger is usually not the authority but a retail customer asking for evidence.
What happens if you do not comply
The PPWR does not set the penalties itself. Article 68 requires member states to provide for effective, proportionate and dissuasive penalties and to notify the Commission. The concrete fine ranges are therefore national and differ by market.
In practice the sequence matters more than the amount. The first lever market surveillance pulls is not the fine. It is market access.
| Stage | What happens | Basis |
|---|---|---|
| 1. Request | Market surveillance asks for documents. You have ten days, electronically. If evidence is missing, a request to remedy follows. | Art. 15(10) |
| 2. Corrective measures | You must restore conformity without delay. If that fails, the packaging has to be withdrawn from the market or recalled. | Art. 15(8) and (10) |
| 3. Market access | Non-compliant packaging may not be placed on the market. That affects the packaged product with it. | Art. 15(1) |
| 4. Penalty | Fines under national law. Member states must set out their rules by February 2027. | Art. 68 |
The commercial risk therefore rarely sits with the fine. It sits with not being able to ship a product because the packaging cannot be evidenced as compliant. With lead times of several months for new packaging, that is not a problem you solve at short notice.
Key point The first lever market surveillance pulls is not the fine. It is market access.
The PPWR and the Digital Product Passport
This is the most important fork in the road for many companies, and it is rarely described correctly.
First, to be clear: the PPWR does not require a general packaging passport. It does not ask you to create a standalone Digital Product Passport for every packaging.
What it does require is different, and further reaching. Article 12(5) provides that where other Union law requires information about the packaged product to be made available on a data carrier, in particular in a Digital Product Passport, a single shared data carrier must be used for the required product and packaging information. Both sets of information must remain easy to tell apart. Recital 70 confirms this integration logic explicitly for products subject to the Ecodesign Regulation or other Union law with a data carrier obligation.
In practice: as soon as your product falls under the Ecodesign Regulation and needs a Digital Product Passport, the shared data carrier for product and packaging information stops being a design choice and becomes a conditional legal obligation. The same applies to products with sector-specific data carrier obligations such as the Battery Passport.
Set the PPWR and the Digital Product Passport up as two separate projects and you build two systems you will have to merge later. The underlying data is the same either way: materials, weights, components, evidence, product assignment.
So the question is not whether you need a packaging passport. The question is whether you structure your packaging data so it works equally for conformity documentation, EPR reporting, eco-modulation and the later product data carrier. Collecting this data is not optional. The only optional part is deciding to hold it in a structured way.
Key point The PPWR requires no packaging passport, but it does require a shared data carrier as soon as the product itself is subject to a data carrier obligation.
One data foundation instead of two projects
In 30 minutes, work out which packaging data you are missing today and what that means for the PPWR and the Digital Product Passport.
Where implementation goes wrong
What we see again and again: the regulation is not the problem. The matching is. Almost everyone in the companies affected knows the PPWR is coming. Very few can say which data points are actually required.
Confusing it with sustainability reporting
Many companies handle the PPWR in the same process as their ESG reporting. That fails because the two work in fundamentally different ways. A sustainability report is organisation-level, produced once a year, and ends as a document for human readers. The PPWR is product-level: it requires separate data and evidence per packaging type, changing with every supplier switch and every material change.
The difference lies in volume, frequency and linkage. You do not package your company. You package many different products in many different types of packaging. Tools built for an annual report hit their limit there.
Isolated documents
A test report as a PDF and a weighing record as a spreadsheet can be technically flawless and still barely usable operationally. They do not reliably answer which packaging type and version they cover, whether the delivered version is still unchanged, whether the document is still valid or was long since superseded, and which products are affected.
No versioning logic
Packaging changes more often than compliance documentation reflects. A different board weight, a new supplier, a changed coating. Without versioning, after two years nobody can reconstruct which evidence belongs to which delivery.
Separated processes
Conformity sits in quality assurance, EPR in finance or sustainability, packaging development in product management. All three work with the same material data, usually in their own spreadsheets.
Data availability in the supply chain
You do not automatically hold all the packaging data. Components, individual weights, substance evidence, test reports, data on recyclability and recycled content originate with the packaging supplier and their own suppliers. Article 16 obliges them to hand it over, but not in any particular format.
Key point The requirements are not the problem. The missing link between evidence, packaging version and product is.
The five-step roadmap
Five steps that hold up in practice. The critical path is not the conformity assessment. It is the change process that follows.
The roadmap reads like a year-long project. It is not. For a defined packaging portfolio, steps one to four are achievable in a few weeks if supplier data is collected in a structured way rather than as a pile of PDFs. The effort sits in the sourcing, not the assessment. Starting today does not make you too late. It just means working to a tighter schedule.
01
Clarify roles and markets
For every product and target market, determine whether you are the manufacturer, the producer for EPR purposes, or both. Check the special cases: the micro enterprise rule, neutral packaging, imports from third countries, unusual routes to market. This assessment underpins everything else and cannot be done retrospectively.
02
Map your packaging portfolio
Give every packaging type a unique identity with a version. Record components, materials and individual weights. Assign each packaging version to the products that use it. Without that assignment neither the conformity documentation nor the EPR reporting holds together.
03
Close the data gaps with suppliers
Ask your packaging suppliers, in a structured way, for the information Article 16 obliges them to hand over: specifications, material evidence, test reports, data on recyclability and recycled content. Define a format you can process rather than accepting PDFs.
04
Build the conformity evidence
Carry out the conformity assessment, produce the technical documentation under Annex VII and issue the EU declaration of conformity per packaging type. Set the process up so that it actually holds the ten-day deadline for requests from authorities.
05
Establish a change process
Define who creates and approves a new packaging version, how affected products and markets are identified, how superseded evidence is locked without losing historical states, and how downstream outputs are updated. This step decides whether conformity holds over time or falls apart with the first material change.
Key point The critical path is not the conformity assessment. It is the change process that follows.
Structuring packaging data with Narravero
Narravero operates an infrastructure for product data. For the PPWR that means packaging master data, supplier evidence, packaging versions, product assignments and market-specific EPR data are brought together in one place and held with versioning.
The result is a packaging record that answers four questions at any time: which packaging version applies? Which evidence belongs to it and is it still valid? Which products and markets are affected? What changes when the packaging changes?
What the platform does
- Assign packaging data to the right products and markets
- Aggregate material and weight volumes per reporting period
- Prepare and export data for national EPR reporting using configurable rules
- Provide recyclability and recycled content data for eco-modulation
- Make changes to a packaging version traceable across all affected products and analyses
- Document the origin, version and validity of the data in an auditable way
Because the same data foundation also feeds the Digital Product Passport, the shared data carrier under Article 12(5) is not a second project. It is an output of the same structure.
“We did not set the product passport up as a compliance exercise but as a data foundation. So when the packaging data for the PPWR started running into the same structure, it was not a new project. It was another dataset.”
B&W International runs its product data on the Narravero platform and builds its PPWR packaging data on the same foundation. No second system, no duplicate data maintenance, no later merge.
The Narravero PPWR software page shows what this looks like in practice: how the packaging record is built, how the declaration of conformity is produced, and how the platform connects to your existing systems. An English version of that page is in preparation.
What the platform does not replace
The legal assessment of roles, registration in the member states and the appointment of a national producer responsibility organisation. The specific reporting categories, interfaces and fee rules remain dependent on the respective national system.
Regulatory context
Thomas Rödding, founder and CEO of Narravero, is Co-Chair of CEN-CENELEC JTC 24 and Vice Chairman at DIN, in a personal capacity. Both bodies develop the European standards for data models and interoperability of the Digital Product Passport, neutral as to manufacturer, vendor and technology. The aim is that product passports remain transferable between providers regardless of the system used.
Key point The same packaging data foundation serves conformity evidence, EPR reporting, eco-modulation and the later shared data carrier.
Frequently asked questions about the PPWR
What is the PPWR?
The PPWR is the EU Packaging and Packaging Waste Regulation, formally Regulation (EU) 2025/40 on packaging and packaging waste. It replaces the previous Packaging Directive and applies directly in every member state, with no national transposition required. It governs both the requirements for the packaging itself and extended producer responsibility.
What does the abbreviation PPWR stand for?
PPWR stands for Packaging and Packaging Waste Regulation. It refers to Regulation (EU) 2025/40 on packaging and packaging waste, which applies from 12 August 2026 and replaces the earlier Packaging Directive.
When does the PPWR start to apply?
The PPWR applies from 12 August 2026 directly in every EU member state. That does not mean every substantive requirement in Articles 5 to 12 is fully applicable on that day. Several requirements phase in through 2030 and beyond, depending on when the relevant acts enter into force.
Who is responsible under the PPWR, the packaging supplier or the brand owner?
The manufacturer carries responsibility under product law. That is whoever has packaging or packaged products designed or made and places them on the market under their own name or trademark, which is usually the brand owner rather than the contract packaging company. That company is the supplier and must hand over the information the manufacturer needs to demonstrate conformity.
Does the PPWR require a QR code on packaging?
Not in general. For standard packaging labelling the digital data carrier is optional. It becomes mandatory for reusable packaging under Article 12(2), from 12 February 2029 or 30 months after the relevant implementing act enters into force, whichever is later. Open loop systems without a system operator under Annex VI are exempt.
Does my packaging need a Digital Product Passport?
The PPWR does not require a general packaging passport. However, if the packaged product is subject to a data carrier obligation under other Union law, for example through the Ecodesign Regulation, Article 12(5) requires a single shared data carrier for product and packaging information. Both sets of information must remain easy to tell apart.
What is the difference between the PPWR and national packaging law?
National packaging law, such as the German VerpackG, mainly governs waste responsibility within one country. The PPWR adds a harmonised European product conformity for the packaging itself, with conformity assessment, technical documentation and an EU declaration of conformity.
What data do I need from my packaging suppliers?
Components, materials and individual weights, technical drawings and specifications, material and substance evidence, test reports and assessments, data on recyclability and recycled content, the production site, and every change to material, design, manufacturing or evidence. Article 16 obliges the supplier to hand this over but leaves the format open.
How quickly do I have to respond to authorities?
Under Article 15(10) the required information, including the technical documentation, must be provided electronically within ten days of receiving a reasoned request.
Does the PPWR also apply to B2B packaging?
Yes. The PPWR does not distinguish between consumer and business packaging. What matters is that the packaging or packaged product is placed on the EU market. Transport, service and primary production packaging fall into specific categories that need to be assessed case by case.
What happens if I do not comply with the PPWR?
The PPWR does not set the penalties itself. Article 68 requires member states to provide for effective, proportionate and dissuasive penalties. A fine is usually the last step: first comes a request for documentation, then corrective measures, and in serious cases withdrawal from the market or a recall. Non-compliant packaging may not be placed on the market.
Who is legally responsible when retailers pass requirements down the chain?
Who holds the manufacturer role depends on whose name or trademark the packaged product is placed on the market under. That role cannot be passed on by contract. What can be agreed contractually is the obligation to supply data. For the question of who answers to the authority, that distinction is what counts.
Next steps
You now have the overview. Three possible next steps, depending on where you stand:
01 · Stay up to date
When the acts arrive
Several PPWR deadlines depend on acts that have not yet been adopted. We set out what changes and what it means for your packaging data.
Subscribe to the regulatory update →02 · Go deeper
Dig into the detail
Whitepapers, checklists and guides on implementing product and packaging data, sorted by regulation and industry.
To the knowledge hub →03 · Get started
Start now
In 30 minutes, work out where your company stands on packaging data and what that means for the PPWR and the Digital Product Passport.
Book a demo →