---
title: "Frequently Asked Questions on the PPWR (Packaging and Packaging Waste Regulation)"
id: "76341"
type: "cpt_resources"
slug: "resources-ppwr-faq"
published_at: "2026-06-26T06:25:00+00:00"
modified_at: "2026-06-26T07:26:49+00:00"
url: "https://www.enhesa.com/resources/article/resources-ppwr-faq/"
markdown_url: "https://www.enhesa.com/resources/article/resources-ppwr-faq.md"
excerpt: "Enhesa’s PPWR experts answer frequently asked questions on practical compliance with the Packaging and Packaging Waste Regulation (PPWR). Use this resource to support your company’s preparations ahead of its application from August 2026."
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taxonomy_resources_type:
  - "Article"
taxonomy_resources_topic:
  - "Chemical Management"
  - "Corporate Sustainability"
  - "Packaging"
taxonomy_resources_region:
  - "Asia Pacific"
  - "Europe"
taxonomy_resources_category:
  - "Product Intelligence"
---

# Frequently Asked Questions on the PPWR (Packaging and Packaging Waste Regulation)

Enhesa’s regulatory experts answer common questions companies have about PPWR compliance.

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Thank you to all the companies that joined our PPWR webinar on 23 April 2026. During the session we received many questions about the practical steps involved in complying with the packaging regulation. On this page, Enhesa’s regulatory experts have brought together their answers.

For advice on how the PPWR applies to your specific situation, please get in touch via the form at the bottom of this page.

## As of 12 August 2026, what are the minimum compliance actions companies should have in place?

**Yujing Pan:** As of 12 August 2026, companies should ensure that any packaging placed on the EU market from that date complies with the substance restrictions under Article 5 to minimise substances of concern, especially regarding heavy metal limits and PFAS restrictions in food-contact packaging. However, it should be noted that further guidance may still be needed regarding practical implementation.

Moreover, packaging must be supported by a Declaration of Conformity (DoC) that can be made available to authorities upon request.

A critical step is to clearly distinguish between packaging that has already been placed on the market before the application date—which can continue to circulate without needing to meet new sustainability or labelling requirements—and stock that has not yet been placed on the market, which must be assessed and, if necessary, reworked or repackaged into compliant packaging before being supplied. Companies should also ensure they correctly apply the definition of “placing on the market,” as it determines whether the new requirements apply. While detailed recyclability criteria are not yet enforceable at this stage, it is recommended to begin aligning packaging with design-for-recycling principles and preparing internal documentation processes, but full compliance with future technical or labelling requirements is not yet mandatory.

Furthermore, companies must ensure that packaging or its accompanying documentation visibly display the manufacturer’s registered trade name and contact details.

Because the PPWR takes effect directly as an EU Regulation rather than a Directive, these Day-One compliance steps apply uniformly across all EU Member States simultaneously, without national grace periods.

## For requirements where implementing acts or detailed rules are not yet available, how should companies approach compliance after 12 August 2026? Will there be any practical grace period or enforcement flexibility?

**YP:** Where implementing acts or detailed technical rules are not yet available, companies are expected to take reasonable and well-documented steps to prepare for future compliance rather than achieve full technical alignment by 12 August 2026.

In particular, certain requirements—such as recyclability performance (e.g. “recyclable at scale”)—are not yet operational, as the detailed assessment criteria will only be defined through future delegated and implementing acts. As a result, there is no immediate obligation to demonstrate full compliance with these criteria at the application date, which in practice provides a degree of enforcement flexibility during the transition period.

In the meantime, companies should rely on available tools such as harmonised standards published in the EU Official Journal, which provide a presumption of conformity, or otherwise follow general design requirements (e.g. packaging minimisation under Annex IV) and begin aligning with design-for-recycling (D4R) principles. At the same time, this does not suspend all obligations, and companies are still expected to comply with applicable baseline requirements under the Regulation.

Importantly, organisations should ensure that their approach is well documented and defensible, including internal assessments and design rationale, to demonstrate reasonable efforts to comply until more detailed methodologies and benchmarks are formally adopted.

## In the absence of fully defined requirements, how should companies prepare the Declaration of Conformity (DoC) and technical documentation?

**YP:** In the absence of fully defined requirements or standardised formats, companies should prepare the Declaration of Conformity (DoC) and technical documentation by strictly following the core content requirements set out in Articles 39–41, while adopting a flexible but structured approach to format and organisation. The PPWR does not prescribe a mandatory template, but it does require that technical documentation be comprehensive and sufficiently detailed to allow authorities to assess conformity without further investigation. At a minimum, this includes information on packaging design and manufacturing, material composition, identification of regulated substances, relevant concentration data, and justification of compliance, supported where necessary by supplier declarations, specifications, safety data sheets or analytical reports. The DoC must be formally drawn up by the manufacturer and made readily available to authorities upon request, even if it is not systematically provided with shipments. In practice, companies should focus on building a robust and traceable documentation system, relying on available data and supplier information, and ensuring that their compliance rationale is clear, consistent, and defensible, while remaining adaptable to future guidance or standardised templates once these are adopted. The supporting technical documentation must be kept and made available to authorities for 5 years for single-use packaging and 10 years for reusable packaging.

## Should DoCs and conformity assessments be prepared at the product level or can they be consolidated at the packaging type level ?

**YP:** DoCs and conformity assessments can be prepared with a degree of flexibility in scope, depending on how the packaging is placed on the market, provided that clarity, traceability, and completeness of information are ensured. Article 41 requires that the DoC clearly identify the packaging covered (e.g. by specification, trade name or batch), and a single DoC can cover a full packaging system or packaging type—including multi-component packaging—if all components are properly identified and their compliance is demonstrated. Where packaging components are placed on the market separately, separate DoCs could be necessary. Even where packaging is marketed as a system, companies can choose to maintain separate supporting documentation for individual components.

From a practical standpoint, this means companies may consolidate DoCs at the packaging type or system level, rather than strictly at the individual product level, as long as traceability to the specific packaging used is maintained through the technical documentation. At the same time, conformity assessment under Annex VII requires that compliance be demonstrated at the level of each packaging component and material, so the technical file must contain sufficient detail for each element even if the DoC is consolidated. In practice, companies should adopt a hybrid approach: structure DoCs at a manageable level (e.g. packaging type), while ensuring that underlying documentation allows full traceability and verification of each component placed on the market.

## For plastic components representing less than 5% of the total packaging weight, how should the exemption from recycled content requirements be applied (e.g. inner bags, trays)?

**YP:** Under the PPWR, plastic components—such as an inner bag or tray—that represents less than 5% of the total weight of a packaging unit is exempt from the 2030 and 2040 recycled content targets without requiring prior authorization. This threshold is applied on a component-by-component basis, meaning each plastic element must be assessed individually against the total packaging weight. As a result, these minor components fall outside the scope of recycled content obligations, and recycled content requirements apply only to the in-scope plastic components. The exemption is intended for identifiable packaging components rather than individual layers within inseparable composite materials. Importantly, exempt components must still comply with general PPWR requirements, including recyclability and Design for Recycling criteria. In practice, components below the 5% threshold are not required to meet recycled content targets, while plastic components at or above this threshold remain fully subject to recycled content obligations.

## How will chemically recycled materials and non-EU recycled content be treated, and what is the expected outlook for future recycled content requirements?

**YP:** Chemically recycled materials and non-EU recycled content are both permitted to count toward recycled content targets, provided they qualify as post-consumer recyclate (PCR) and meet strict traceability, certification, and verification requirements. Chemical recycling is expected to be recognised, typically via mass balance accounting, but its acceptance will depend on detailed methodologies to be defined in future implementing acts, so full flexibility cannot yet be assumed. Similarly, recycled content from outside the EU is allowed, but will need to comply with future verification and certification requirements demonstrating compliance with PPWR rules.

Looking ahead, the PPWR establishes progressively increasing recycled content targets for 2030 and 2040. Further secondary legislation will define technical rules (e.g. calculation, mass balance, certification), and requirements are expected to tighten over time, indicating a move toward more stringent, harmonised, and rigorously verified recycled content obligations across all plastic packaging.

## When can we expect more clarity on the list and scope of Substances of Concern under PPWR?

**YP:** More clarity on the list and scope of Substances of Concern (SoC) under the PPWR is expected by 31 December 2026, when the European Commission and ECHA are required to publish a comprehensive assessment identifying problematic substances and potentially proposing new restrictions.

In the meantime, the PPWR already sets general minimisation obligations and includes specific restrictions (e.g. PFAS, heavy metals), but does not yet provide a complete SoC list. While this master list is pending, the broad scope is already anchored to existing REACH SVHC lists and CLP hazard classes, alongside substances that physically hinder the recycling process. Further detail will therefore be developed progressively through secondary legislation after 2026, meaning companies should expect a phased tightening and expansion of substance requirements over time.

## When using recycled materials, how should companies ensure compliance with REACH requirements (e.g. SVHCs, Annex XVII restrictions)?

**YP:** When using recycled materials under the PPWR, companies must ensure full compliance with REACH requirements, as Recital 25 clarifies that PPWR applies without prejudice to REACH. The use of recycled materials does not remove the need to comply with applicable REACH restrictions, SVHC communication obligations and other relevant chemical compliance requirements . All verified chemical information must be integrated into PPWR technical documentation (Article 39), ensuring that recycled content is subject to the same compliance standards as virgin materials.

## Can recycling pictogram requirements be fulfilled through digital means (e.g. QR codes, web links), and if so, to what extent?

**YP:** Recycling pictogram requirements generally cannot be fulfilled solely through digital means such as QR codes or web links, as core labelling elements must remain physically visible, legible, and affixed on the packaging. However, Article 12 allows digital tools to supplement more detailed information, such as material composition, sorting instructions for individual components, and reusability details, provided the information is accessible and durable. QR codes are even mandatory for reusable packaging, but serve specific tracking purposes rather than replacing recycling pictograms. Overall, digital labelling is intended as a supplementary layer, while physical pictograms remain the baseline, with the exact extent of digital substitution depending on future harmonisation and implementing acts.

## Once PPWR pictograms are introduced, will existing markings (such as the Triman logo or material identification codes) still be required, or can they be replaced?

**YP:** Once the PPWR harmonised pictograms become applicable, Member States will be required to align or repeal conflicting national labelling schemes, meaning that mandatory national markings such as the Triman logo or country-specific disposal labels cannot be maintained. Under Article 12(8), economic operators are explicitly banned from displaying markings that could confuse or mislead consumers alongside the new EU symbols. However there will be a designated transitional window for manufacturers to update their packaging artwork.

## What level of detail is required for packaging identification and manufacturer/importer information under Article 15? Must this be physically marked on the packaging?

**YP:** Under Article 15, the packaging manufacturer must ensure that the packaging is both compliant and properly identified. This includes providing the manufacturer’s name, registered trade name or trademark, postal address, and, where available, electronic contact details, along with traceability information such as a type, batch, or serial number to enable clear identification of the packaging.

With regard to how this information is presented, it is not strictly necessary for all traceability details to be physically printed or engraved directly on the packaging. Article 15 allows manufacturers to provide this information either on the packaging itself or through a QR code or another digital data carrier. Where a digital solution is used, the information must remain clearly visible, legible, and readily accessible to market surveillance authorities.

## For traceability purposes, is it sufficient to rely on product-level tracking, or is batch/lot traceability required specifically for packaging as well?

**YP:** Batch or lot traceability is required at the level of the packaging, not only at the product level. While integrated product traceability systems can be used to support compliance, they must ensure that packaging can be independently traced to its specific batch, composition, and conformity documentation.

## What is the current timeline and status of implementation for the producer register under Article 44?

**YP:** Under Article 44 of the PPWR, all EU Member States must establish or upgrade their national producer registers within 18 months of the entry into force of the implementing acts that establish the standardized format for registration and reporting, and specify the granularity of data. Currently, these relevant implementing acts have not yet been published by the European Commission. According to official FAQ guidance, producers are required to report their data by June for each preceding full calendar year; therefore, once the registers are updated, it is reasonable to expect producers to report to the national EPR registers according to the new harmonized rules for the first time by 1 June 2029.

## When are EPR-related costs expected to start, and how will these fees be determined?

**YP:** EPR-related costs under the PPWR will effectively apply from 12 August 2026, when the Regulation becomes applicable, although in practice these obligations largely build on existing national EPR schemes already in place across Member States. Fees are primarily determined based on the quantity (e.g. weight) and type of packaging materials placed on the market. However, the PPWR strengthens the principle of eco-modulation, meaning that fee levels will increasingly reflect the environmental performance of the packaging, particularly its recyclability, and potentially factors such as recycled content and overall design. The PPWR does not prescribe a uniform EU-wide fee structure or mandate a specific annual fee. Instead, fees remain determined at Member State level, where competent authorities or EPR schemes may levy registration or administrative charges. The Regulation requires that such fees be cost-based and proportionate.

## Who is primarily responsible for conformity assessment and technical documentation of packaging—the product manufacturer, the packaging manufacturer, or both?

**YP:** Under the PPWR, responsibility for conformity assessment, technical documentation, and issuance of the Declaration of Conformity rests primarily with the “manufacturer,” defined as the economic operator placing the final packaging or packaged product on the EU market under its name or trademark . This actor must ensure compliance of the entire final packaging configuration—including all components such as materials, inks, adhesives, and closures—and cannot transfer this legal responsibility to upstream suppliers. While packaging manufacturers and suppliers must provide relevant technical data (e.g. material declarations, test reports) to support compliance, they are not primarily responsible unless they themselves place the packaging on the market. In cases of import, the EU importer assumes this role. Overall, the PPWR establishes a single-point responsibility model, where the obligation is anchored to the entity that first makes the packaging available on the EU market, even if compliance relies on supply chain information.

## Does PPWR apply equally to packaging used in B2B contexts, internal logistics, or exports from outside the EU, and are there any exemptions in such cases?

**YP:** The PPWR applies broadly to all packaging placed on the EU market, regardless of whether it is used in B2B, B2C, or transport contexts, meaning that B2B and industrial packaging are generally in scope, although some requirements (e.g. consumer labelling) may differ.

The key determining factor is market placement in the EU, not the type of use: thus, imported goods are covered, with the EU importer assuming manufacturer-level obligations where the supplier is non-EU. Packaging used exclusively for exports outside the EU or shipment portions that never enter EU circulation are out of scope, provided traceability is ensured. Additionally, purely internal, closed-loop logistics packaging or transport packaging removed before entering EU circulation may also fall outside the PPWR’s scope.

Overall, there are no blanket exemptions based on B2B use, internal logistics, or export status—the decisive criterion remains whether the packaging is first made available on the EU market. It should be noted that specific, highly targeted exemptions do exist for specific transport formats. For instance, PPWR exempted certain types of pallet wrapping films and straps from the 100% reuse rules during transport due to disproportionate adaptation costs.

For advice on how the PPWR applies to your own situation, please get in touch via the **form at the top of this page**.