PPWR deadline brings new duties for plastics companies

Key requirements of the EU Packaging and Packaging Waste Regulation (PPWR) will take effect on 12 August 2026, creating new obligations not only for packaging manufacturers but also for many companies in the plastics industry. The SKZ Plastics Center is supporting companies in assessing whether and how they are affected, identifying their role in the supply chain and preparing for implementation of the new regulatory requirements. The date marks an important milestone for the European packaging sector. With the entry into application of key PPWR provisions, companies will need to correctly determine their position in the packaging life cycle and address the obligations linked to that classification. This includes firms supplying packaging materials, producing packaging or packaged products, placing imported packaging on the EU market, or using transport packaging in industrial supply chains.

Uniform requirements across the EU

With the PPWR, the European Union aims to make packaging more sustainable, resource-efficient and transparent. The regulation establishes, for the first time, a largely uniform legal framework for packaging in the European single market.

From 12 August 2026, producers must demonstrate compliance with certain substance restrictions, including those concerning PFAS and heavy metals, and provide a corresponding declaration of conformity. Further obligations, including registration and producer responsibility requirements, will start to apply from 2027. In subsequent years, further requirements will be introduced concerning recyclability, the use of recycled materials and the reuse of packaging.

Determining the company’s role

For many companies, one of the main challenges will be to correctly identify their own role within the packaging life cycle. The PPWR distinguishes in particular between suppliers, producers, manufacturers and importers. The respective obligations and responsibilities depend on this classification.

Suppliers provide packaging or packaging materials and must provide relevant information for the conformity assessment. Producers manufacture packaging or packaged products and are responsible for demonstrating compliance. Manufacturers are entities that first make packaged products available in an EU member state and, in future, will also be subject to extended producer responsibility. Importers are the first to place packaging from third countries on the EU market and must ensure that it meets the requirements of the PPWR.

Transport packaging requires detailed assessment

In the case of transport packaging in particular, the question of who qualifies as a producer is often not clear at first glance. Companies that produce transport, service or primary production packaging in its final form and place it on the market for the first time are generally considered producers under the PPWR. They are therefore responsible for carrying out the conformity assessment and for preparing and providing the EU Declaration of Conformity.

It must also be determined in each case whether the criteria for the role of importer are met for imported packaging. This applies in particular when a company established in the Union procures packaging or packaged products from a third country and makes them available on the Union market for the first time. In such cases, companies are also subject to the specific obligations of an importer or producer under the PPWR.

As a general guideline, producers of rigid empty transport packaging, such as crates or pallets, are usually classified as producers. For flexible packaging, such as stretch film or strapping, the PPWR often provides for a different allocation of roles. Because these materials often take their final form only when used by the customer, the producer of the packaging material is usually considered a supplier. The company that packages or fills the product, by contrast, regularly assumes the role of producer and, where applicable, also that of manufacturer.

Depending on the business model, several roles may apply at the same time, for example supplier as well as producer or importer. A detailed analysis of the company’s own supply and value chain is therefore essential.

Preparation before implementation

The effective date of 12 August 2026 marks the start of practical implementation of the PPWR. Additional requirements relating to design for recycling, the use of recycled materials, chemical recycling, reusable packaging obligations and producer responsibility will enter into force gradually through 2030 and beyond.

Companies in the plastics industry should therefore assess at an early stage what types of packaging they use, what role they play in the supply chain and what requirements follow from this. SKZ supports this process through role and impact analyses, compilation of the technical information required for PPWR conformity assessment, training and expert guidance on implementing the regulation.