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PPWR Frequently Asked Questions

Your questions about EU Packaging and Packaging Waste Regulation (PPWR) answers by Macfarlane Packaging

From 12 August 2026, EU PPWR comes into effect. This new and evolving legislation will impact businesses shipping packaging that will end up in the EU

Our FAQs are here to help you understand PPWR

These FAQs provide general guidance based on Regulation (EU) 2025/40 and the information available at the date of writing. PPWR responsibilities depend on the packaging, branding, contractual arrangements and route to market. This information is not formal legal or compliance advice and businesses should confirm their individual obligations with their compliance or legal advisers.

 

Updated: August 2026

About PPWR

PPWR is the EU's new Packaging and Packaging Waste Regulation. It replaces the old 1994 Packaging Directive and covers all packaging placed on the EU market.

Essentially, the law says that all packaging that's on the EU market but be simpler, smaller, safer and easier to recycle. PPWR also provides clear requirements for compliance.

There are six key aspects to be aware of:

  • Packaging must be safe & free from harmful substances
  • Packaging must be fully recyclable
  • Plastic must be reduced & optimised
  • Packaging must be minimised and right-size
  • Packaging must traceable & documented
  • Producers must take greater responsibility for waste


Yes, it does matter.

A directive had to be written into each country's own law, so rules varied by member state. In contrast, a regulation applies directly and identically across all EU member countries. This means there's the same rules everywhere, with less room for local interpretation.

PPWr comes into force from 12 August 2026. From this date, businesses sending packaging in to the EU market need to be able to provide Declarations of Conformity that confirm there are no harmful chemicals in the packaging.

However, many of the hard targets are phased in later. For example labelling requirements are yet to be confirmed and recycled-content minimums and some bans land in 2028 and 2030, with waste-reduction milestones in 2030/2035/2040.
If you place packaging or packaged goods on the EU market, or sell into the EU, yes. It's about market access, not where you're based.

"Producer" is defined broadly. This can be manufacturers, importers, and distributors who first make packaging available in a member state, even if they didn't make the packaging themselves.

Everyone in the chain (suppliers, importers, distributors, online platforms, fulfilment providers) has defined duties.
Non-compliant packaging can be kept off the market. Plus, each member state can enforce penalties. So, you could be subject to both access risks and fines.

PPWR Product Scope and Application

“Placed on the market” generally means making packaging or a packaged product available on the EU market for the first time.

PPWR therefore applies where packaging or packaged goods enter the EU market, regardless of whether they originated in the UK. It does not apply to packaging that is placed only on the Great Britain market, although separate UK packaging regulations may apply.

Where goods are supplied from the UK into the EU, the manufacturer and the EU-established importer have separate responsibilities. The manufacturer will generally be responsible for completing the conformity assessment and preparing the technical documentation and EU Declaration of Conformity. The EU importer must verify that these requirements have been met and retain the necessary documentation.

The precise responsibilities will depend on the contractual arrangements and route to market, including who manufactures or commissions the packaging, who imports the goods and who first makes them available in the EU.

No. PPWR is not limited to packaging displaying a company name, logo or trademark. Plain boxes, unprinted film, tape, bags, transit packaging and other non-branded packaging can all fall within its scope.

Branding is one of the factors used to determine who is considered the manufacturer but so is who controls the design of the packaging. A business will therefore often be considered the manufacturer under PPWR, even when they are not physically making the packaging product. A business may be treated as the manufacturer where it manufactures packaging or packaged products—or has them designed or manufactured for their specific needs. The brand does not therefore need to appear on the packaging for a business to be responsible.

An importer or distributor may also become the manufacturer where it places packaging on the market under its own name or trademark or modifies it in a way that could affect compliance.

Businesses should generally work on the basis that PPWR covers all packaging placed on the EU market, subject to specific exemptions and the phased introduction of individual requirements.

An importer or distributor may also become the manufacturer where it places packaging on the market under its own name or trademark or modifies it in a way that could affect compliance.

Businesses should generally work on the basis that PPWR covers all packaging placed on the EU market, subject to specific exemptions and the phased introduction of individual requirements.
Under the Windsor Framework, many of PPWR’s product-related requirements will apply to packaging placed on the Northern Ireland market. These include requirements relating to areas such as:

  • packaging composition and substances;
  • recyclability;
  • recycled content;
  • packaging minimisation;
  • labelling and identification;
  • technical documentation; and
  • Declarations of Conformity.


However, certain PPWR provisions will not apply in Northern Ireland. The European Commission and the Northern Ireland Department of Agriculture, Environment and Rural Affairs have confirmed that this includes PPWR provisions covering Extended Producer Responsibility, Deposit Return Schemes, reuse and refill targets, and Member State recycling and waste-reduction targets.

Northern Ireland businesses will instead continue to have obligations under the applicable UK packaging Extended Producer Responsibility regime.

The Republic of Ireland is an EU Member State and will apply PPWR in full, alongside its national EPR registration, reporting and fee arrangements. Packaging supplied from Northern Ireland into the Republic of Ireland may therefore create separate Irish obligations for the business considered to be the producer in Ireland.

Businesses trading in both Northern Ireland and the Republic of Ireland should not assume that one report will satisfy both regimes. They should identify:

  • where the packaging is first placed on the market;
  • which business is the producer in each jurisdiction;
  • what UK packaging data must be reported; and
  • whether registration and reporting are also required in Ireland.


PPWR product-compliance documentation and EPR reporting are related but separate obligations.
Labels attached to packaging are generally treated as packaging components and therefore fall within the PPWR framework.

An A4 sheet of unused address labels is a product before the labels are applied. Once a label is attached to a parcel, box, envelope or other packaging to support its presentation, identification or delivery, it will generally form part of that packaging.

The relevant compliance information should normally come from the label manufacturer or supplier. The business applying the label should also include it when assessing the material composition and recyclability of the completed packaging, particularly where the label or adhesive could affect the recyclability of the main packaging material.

A label used only on the product itself, rather than on packaging, may require a separate assessment and will not automatically be packaging under PPWR.
Readiness is likely to vary considerably between businesses. Organisations with established packaging specifications, supplier declarations and product-data systems will generally be better prepared than those that do not currently hold detailed packaging information at SKU level.

It is also important to recognise that PPWR is being introduced in phases with the more extensive requirements around recyclability, recycled content and minimisation not being introduced until 2030.

UK businesses supplying the EU or Northern Ireland should initially make sure they can:

  • identify the packaging they place on the European markets;
  • determine whether they are acting as manufacturer, importer, distributor, packer or producer;
  • Develop Declarations of Conformity for in-scope products;
  • maintain packaging specifications and traceability records;
  • identify the EU importer or other relevant economic operator;
  • meet the requirements that apply from 12 August 2026; and
  • monitor later implementing legislation and application dates.


Where information is incomplete, businesses should prioritise higher-volume and bespoke packaging, engage with suppliers and document the steps being taken to close any gaps.
Yes. Packing tape used to close, secure or support a box, parcel or other package is generally considered a packaging component and falls within the scope of PPWR.

The way tape is classified and documented may depend on how it is supplied and used. Tape placed on the market as an empty packaging product may require its own traceable conformity information. Once applied, it also forms part of the overall packed configuration.
Potentially, yes. If both the inner and outer boxes perform a packaging function, they will generally be treated as separate items or levels of packaging. For example, the inner box may be sales or grouped packaging, while the outer box may be transport packaging.

Each packaging type must be identifiable and traceable to the relevant conformity information. This does not necessarily mean that every individual physical box needs its own serial number. A product code, packaging reference, type number or batch number may be used, provided it clearly identifies the packaging.

Both packaging types may be managed through consolidated documentation, provided each one is clearly identified and the applicable technical information can be traced. However, an identifier on the outer box should not automatically be assumed to cover the inner box.

If an inner box is part of the product and is not performing a packaging function, its classification may be different and should be assessed separately.
The important date is when the packaging or packaged product is first placed on the EU market, rather than when it was manufactured or packed.

Packaging already placed on the EU market before 12 August 2026 may generally continue to move through the supply chain. However, stock held by a manufacturer or exporter outside the EU, or not yet supplied into the EU, may not have been legally placed on the EU market.

Consequently, simply packing goods before 12 August does not automatically exempt them. Businesses should establish whether each consignment was legally placed on the EU market before the application date and retain evidence supporting that decision.

The EU has confirmed it will allow separate identification paperwork to accompany packaging while businesses work through existing stocks.

PPWR Manufacturer, Producer and Supply Chain Responsibilities

The terms have different meanings and relate to different responsibilities.

A manufacturer is generally the business that manufactures packaging or a packaged product - or has it designed or manufactured - and markets it under its own name or trademark. The manufacturer is responsible for product conformity, including the conformity assessment, technical documentation and EU Declaration of Conformity.

An importer or distributor may also become the manufacturer if it markets packaging under its own name or trademark or modifies the packaging in a way that could affect compliance.

A producer, for Extended Producer Responsibility (EPR) purposes, is generally the business that first makes packaging or packaged products available within a particular EU Member State. The precise definition depends on how and where the packaging is supplied, including whether it is sold directly to an end user through a distance contract.

The producer is responsible for obligations such as national registration, packaging-data reporting and EPR fees in the relevant Member State. A business can be both the manufacturer and producer, but this is not always the case. A packaging manufacturer may be responsible for product conformity while its customer, importer or distributor is the producer responsible for EPR.

A customer cannot transfer its EPR responsibility to a packaging supplier simply by requesting that the supplier accepts it. Responsibility must be determined from the PPWR definitions, the supply chain and the national market in which the packaging is first made available.
When a business has bespoke packaging designed or manufactured or uses packaging with its branding, that business will generally be responsible for completing the Declaration of Conformity for that packaging type.

For standard stock products, the manufacturer of the packaging will generally be responsible for completing the Declaration of Conformity, However, if a business combines multiple packaging components, they will also need to complete a declaration at the overall packaging unit level.

Responsibility should therefore be determined using the actual design, branding and contractual arrangements rather than assuming it always sits with either the packaging supplier or the packer.
For bespoke packaging, generally responsibility will sit with the business who control the packaging design, but it is important that this is assessed on a case-by-case basis. Relevant considerations include:

  • who commissioned and controls the packaging design;
  • whose name or trademark the packaging is supplied under;
  • who manufactures or has the packaging manufactured;
  • whether the packaging has subsequently been modified; and
  • who imports or first places it on the EU market.


Responsibility should not automatically be assigned to either the supplier or the customer simply because the packaging is bespoke. Where customers are responsible for preparing Declarations, suppliers should provide information to help the customer in doing so.

For supplier-branded standard stock packaging, the supplier will be the manufacturer and therefore responsible for preparing the relevant EU Declaration of Conformity and retaining technical documentation.

However, if a customer is combining multiple packaging components together for transit, e.g. boxes, void and tape, then it is likely that they will also need to complete a further declaration, at the complete packaging unit level.
For bespoke packaging, generally responsibility will sit with the business who control the packaging design, but it is important that this is assessed on a case-by-case basis. Relevant considerations include:

  • who commissioned and controls the packaging design;
  • whose name or trademark the packaging is supplied under;
  • who manufactures or has the packaging manufactured;
  • whether the packaging has subsequently been modified; and
  • who imports or first places it on the EU market.


Responsibility should not automatically be assigned to either Macfarlane or your business, simply because the packaging is bespoke. Where your business is responsible for preparing Declarations, Macfarlane will provide the information and evidence required to help complete them.
For Macfarlane-branded standard stock packaging, Macfarlane will be the manufacturer. We will be responsible for preparing the relevant EU Declaration of Conformity and retaining technical documentation.

If you are combining multiple packaging components together for transit (supplied by us or other suppliers), e.g. boxes, void and tape, then it is likely that you will also need to complete a further declaration, at the complete packaging unit level.

Please get in touch with us for further information.
The requirement relates to the PPWR “manufacturer” of the packaging. This will generally be the business which has it designed or manufactured and places it on the EU market under its own name or trademark, even when the packaging is unbranded.

This should be considered separately from “producer” responsibility under Extended Producer Responsibility. The producer is generally the business that first supplies the packaging or packaged product in a particular Member State and may not always be e the same business as the packaging manufacturer.
For standard stock packaging, such as boxes or packaging tape, responsibility will depend on who is legally considered the manufacturer.

Where Macfarlane distributes standard stock packaging manufactured and branded by another company, the original manufacturer is normally responsible for the manufacturer identification and technical documentation. As a distributor, Macfarlane must check that the applicable manufacturer information and conformity documentation are available.

Where packaging is manufactured for Macfarlane and placed on the EU market under a Macfarlane name or trademark, Macfarlane could be considered the manufacturer and would therefore assume the relevant obligations.

If customers are pack filling and using multiple packaging components, for example boxes, void and tape, then it is likely that a further Declaration will be required at the overall packaging unit level.

PPWR Product Labelling, Identification and Traceability

You do not need to apply to an EU authority for a packaging identification number. A business can use an existing SKU, product code, type number, batch number, serial number or another internal reference, provided it clearly identifies the packaging and links it to the relevant Declaration of Conformity and technical documentation.

The number does not necessarily need to be unique to every individual physical item. It may identify a packaging type, production batch or series.

It is also important to distinguish between the identifier displayed on the packaging and the identification number assigned to the EU Declaration of Conformity. Both should form part of a clear and traceable PPWR audit trail.

Identification is only required at a packaging unit level, i.e one for primary packaging, one for secondary packaging – not every component part
  • A brand name or trademark on its own is unlikely to be sufficient.
  • From 12 August 2026, the packaging manufacturer must provide:
  • Its name, registered trade name or registered trademark.
  • Its postal address.
  • Where available, electronic contact details, such as an email address or website.
  • A type, batch, serial number or another element that enables the packaging to be identified.


The manufacturer’s contact information may be provided on the packaging itself, through a QR code or another standardised digital data carrier. Where the nature or size of the packaging makes this impossible, the information may be included in documentation accompanying the packaged product.

The identification number does not necessarily need to be unique to every individual box. A packaging SKU, product code or batch number may be suitable, provided it enables the relevant packaging specification and supporting records to be traced.
Manufacturers must ensure that packaging carries a type, batch, serial number or another identifier that enables it to be traced. Where the size or nature of the packaging does not allow the identifier to be displayed, it may be provided in an accompanying document. For example, it may be impractical to apply an identifier to certain film-based packaging like stretch wrap, shrink wrap or bubble wrap, so an accompanying document offers a way to identify it.

The manufacturer’s name or registered trade name or trademark, postal address and, where available, electronic contact details must also be provided. PPWR allows this contact information to appear directly on the packaging or through a QR code or another data carrier.

Importers have corresponding requirements to provide their own identifying and contact information.

The key requirement is that the packaging and responsible economic operators can be clearly identified and traced to the correct Declaration of Conformity and technical documentation.

Identification is only required at a packaging unit level, i.e one for primary packaging, one for secondary packaging – not every component part
A QR code is not generally mandatory for all packaging from 12 August 2026.

Under the manufacturer-traceability requirements, a QR code is one permitted way of providing the manufacturer’s name and contact information. It is not compulsory if the required information is provided directly on the packaging or, where permitted, in accompanying documentation.

The packaging must also have a type, batch, serial number or other identifying element. This should identify the relevant packaging type or production batch; supplier details alone would not provide sufficient product traceability. It does not normally require a unique code for every individual packaging unit.

Separate QR-code requirements will apply to certain reusable packaging under the future harmonised labelling regime. These should not be confused with the manufacturer-identification obligations applying from August 2026.
Transport packaging remains subject to the relevant manufacturer traceability and technical-documentation requirements. Manufacturer contact details may be supplied using a QR code, but the QR code is an option rather than a blanket requirement.

Reusable transport packaging may eventually require the reusable-packaging label and associated QR code or digital data carrier once those specific requirements become applicable.
PPWR does not provide a general confidentiality exemption from manufacturer traceability.

However, the manufacturer’s name and contact information can be provided through a QR code or another standardised digital data carrier. This may help avoid displaying the underlying manufacturer prominently on white-label packaging. It can also be printed internally on the pack or on a hidden flap.

The legally responsible manufacturer must still be identifiable, so complete anonymity cannot be guaranteed. Where a customer markets packaging under its own name or trademark, it may itself be treated as the manufacturer and assume the associated responsibilities.

A producer’s Extended Producer Responsibility (EPR) registration number is a separate matter and is not subject to a general PPWR requirement to print it on every item of packaging.

Declarations of Conformity and Technical Documents

PWR provides an official model structure for the EU Declaration of Conformity in Annex VIII of Regulation (EU) 2025/40.

Although the European Commission may not provide an editable form for businesses to complete, Annex VIII sets out the required structure and information. This includes:

  • an identification number for the declaration;
  • the manufacturer’s name and address;
  • a description that enables the packaging to be identified and traced;
  • confirmation that the declaration is issued under the manufacturer’s sole responsibility;
  • the relevant PPWR requirements;
  • applicable harmonised standards, common specifications or other technical specifications;
  • details of any approved body involved, where applicable; and
  • the name, position, date and signature of the person issuing the declaration.


Businesses may use templates developed by compliance schemes or other organisations, provided they include all the information required by Annex VIII.
The EU Declaration of Conformity should reference any applicable harmonised standards, common specifications or other technical specifications used to demonstrate that the packaging meets PPWR requirements.

Most of the supporting standards and methodologies are still being developed, including those relating to areas such as packaging minimisation, recyclability and recycled content. These should only be referenced once they are applicable and have been used as part of the conformity assessment.

Businesses should therefore avoid listing draft or anticipated standards. The Declaration of Conformity and its supporting technical documentation should be reviewed as new standards and specifications are formally introduced.
For packaging first placed on the EU market from 12 August 2026, the manufacturer must complete the required conformity assessment, establish the technical documentation and draw up the EU Declaration of Conformity before placing that packaging on the market.

An agreement from a supplier to provide information at a later date would not, by itself, replace the need for the manufacturer to hold sufficient evidence to demonstrate conformity.

Supplier declarations and agreements can contribute to the evidence, but the relevant minimum documentation should be available when the packaging is placed on the market.

The technical documentation and Declaration of Conformity must generally be retained for:

  • Five years for single-use packaging.
  • Ten years for reusable packaging.


Suppliers of packaging or packaging materials must also provide manufacturers with the information and documentation necessary to demonstrate conformity.
Macfarlane’s priority is to ensure that customers receive the relevant information and evidence needed to support the PPWR requirements applying from 12 August 2026.

A new Declaration of Conformity is not necessarily required for every order or every year. However, the declaration and technical documentation must be kept up to date and should be reviewed where:

  • the packaging design, specification or material changes;
  • the manufacturing process changes in a way that could affect compliance;
  • applicable PPWR requirements change;
  • relevant standards or common specifications change; or
  • new evidence affects the conformity assessment.


Manufacturers must retain the Declaration of Conformity and supporting technical documentation for five years after single-use packaging is placed on the market and ten years for reusable packaging. Importers must also retain a copy of the declaration for the applicable period.

These documents must be available to the relevant authorities, but PPWR does not require a new copy to be issued automatically with every customer order. Macfarlane intends to make relevant packaging information available through its normal specifications, reporting systems and customer-support processes as requirements develop.
The Declaration of Conformity and technical documentation are separate, although closely related, records.

The Declaration of Conformity is the signed statement confirming that the identified packaging meets the applicable PPWR requirements. The technical documentation is the supporting evidence behind that declaration and may include:

  • a description of the packaging and its intended use;
  • design or manufacturing information;
  • materials and components;
  • packaging weight and composition;
  • relevant calculations and assessments;
  • standards or technical specifications applied;
  • supplier declarations;
  • test reports; and
  • evidence supporting recyclability, minimisation or recycled-content claims where applicable.


Macfarlane will provide customers with the relevant specifications and compliance information needed to support their own obligations. However, PPWR does not necessarily require the complete manufacturer’s technical file to be routinely supplied with every order.

Some elements may contain confidential or proprietary manufacturing information. The full technical documentation must nevertheless be retained by the responsible manufacturer and made available to the relevant market-surveillance authority when required.

The documentation available to customers will depend on Macfarlane’s role in the supply chain and the product concerned.

Packaging Data, Materials and Supporting Evidence

Each packaging type should be linked to a clear product or packaging reference within the relevant data-management system. The supporting records may include its materials, components, weight, recycled content, supplier information, technical evidence and Declaration of Conformity.

Where packaging contains multiple materials or components, each relevant material should be recorded as part of the overall packaging specification and technical documentation.

Macfarlane are able to provide you with this information at a packaging SKU level for all products supplied. As PPWR evolves the Group will continue to develop its systems and processes to enable easy access to this data and help ensure continued compliance requirements are met.
Yes. Core information such as packaging weight, material composition and components is held within Macfarlane’s systems where it is available from the relevant manufacturer or supplier.

This information can be provided through Macfarlane’s packaging waste reports (on request) and, for some customers, through platforms such as Simplicit.e, our B2B trading portal. Customers who do not currently have access should contact their usual Macfarlane representative.

Additional information, including UK EPR reporting data, recycled content and carbon information is to also be available. However, these are separate from the standard mandatory content of a PPWR Declaration of Conformity. UK EPR is a separate regulatory regime and a product carbon footprint is not currently a standard mandatory field in the PPWR declaration
PPRW limits the combined concentration of lead, cadmium, mercury and hexavalent chromium in packaging and packaging components to no more than 100 mg/kg by weight, subject to specified exemptions.

Macfarlane risk assesses its supplier base and has established processes and controls to minimise the risk of any substances of concern being present within packaging supplied.

Speak to the experts at Macfarlane, who can help you prepare your packaging for EU Packaging and Packaging Waste Regulations. 

Get more in-depth information about PPWR from the Macfarlane Packaging team. Download our full PPWR 20-page explainer. 

Our 2-page guide gives you the PPWR basics and a handy flowchart that can show you if your UK business could be in scope of the legislation.