How to Create PPWR Technical Documentation

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PPWR Technical Documentation

EU Packaging and Packaging Waste Regulation (PPWR) 2025/40 introduces technical documentation requirements for packaging. This guide explains how to create technical documentation based on Annex VII.

  • Manufacturers must create technical documentation
  • Importers must review technical documentation
  • Must be kept for 5 to 10 years
  • Include artwork, dielines, test reports, and other files

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How to Create a PPWR Declaration of Conformity

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PPWR Declaration of Conformity

The EU Packaging and Packaging Waste Regulation (PPWR) 2025/40 requires that companies defined as manufacturers must issue a Declaration of Conformity (DoC).

This guide explains how to create a PPWR DoC based on the model structure in Annex VIII.

  • The manufacturer must create the PPWR DoC
  • A DoC is required for each packaging type
  • Importers must request the DoC from the manufacturer

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Guide to EU PPWR Testing Requirements

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Packaging testing

The EU Packaging and Packaging Waste Regulation (PPWR) 2025/40 sets requirements concerning the design and materials of packaging. The purpose of testing is to validate that a particular packaging type is technically compliant with these requirements.

This guide explains when testing is required to validate PPWR compliance, and to what extent you can use existing documentation and self-assessments.

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PPWR Requirements for Transport Packaging: Boxes, Pallets & More

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Transportation packaging

The Packaging and Packaging Waste Regulation (PPWR) 2025/40 sets requirements for packaging used for handling and delivery of products. This includes shipping cartons, pallets, protective plastic and other packaging used for transporting cargo.

Does this mean that you now need to create or obtain a DoC and other documentation for every single cardboard box arriving in your warehouse? The answer is that it depends.

This is a complex area, and this guide is our effort to piece together what we could find about transportation packaging in the PPWR text. It may not cover everything, and it will likely be updated, but it can hopefully help you understand some areas.

  • The PPWR covers packaging used for transportation
  • Transportation packaging is defined under Article 3
  • Specific requirements apply to certain types of transportation packaging
  • Transport packaging is exempt from some PPWR requirements
  • EPR obligations also apply to transportation packaging

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PPWR Producers Requirements in 3 Steps

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Companies that first introduce packaging or packaged products in an EU member state are generally considered to be producers under the Packaging and Packaging Waste Regulation (PPWR) 2025/40. This can also be the case for companies selling directly to end users in other EU member states.

The entity defined as a producer is generally responsible for extended producer responsibility tasks. This includes reporting packaging materials and volumes, and paying corresponding fees.

This guide explains how you can determine which company is the PPWR producer. I also share several practical examples of supply chains involving both EU and non-EU-based companies.

  • Manufacturers, importers, and distributors can be defined as producers
  • The producer is often the first entity that introduces packaging in a particular EU member state
  • The producer must comply with EPR obligations

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Who is Responsible for EU PPWR Compliance?

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The Packaging and Packaging Waste Regulation (PPWR) 2025/40 sets requirements applicable only to certain types of entities. In plain language, this means that what you must do to comply with the PPWR differs depending on whether your company is defined as a:

a. Manufacturer
b. Importer
c. Supplier
d. Distributor

It is therefore critical that you understand their respective definitions and can accurately find your place in the PPWR supply chain.

Further, companies can also be defined as producers (in addition to their primary definition), which results in additional extended producer responsibility (EPR) obligations applying.

Why should I read this guide?

Read this guide if you want to understand whether you are defined as a producer, manufacturer, importer, distributor, supplier, or other entity. You can read this guide to learn more about PPWR requirements:

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EU Packaging Regulation (PPWR) Timeline: 2026 to 2040

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The Packaging and Packaging Waste Regulation (PPWR) 2025/40 is applicable from 12 August 2026. That said, the PPWR contains many requirements concerning labelling, documentation, EPR, and other aspects that only start to apply years later.

This guide serves as a timeline for PPWR requirements and their respective dates.

Methodology

Step 1: I mapped out all the articles mentioning a date*

Step 2: I determined if the requirement is relevant to either:

  • Manufacturers, importers, distributors, and other economic operators, or
  • EU Commission or Member States

Step 3: The respective PPWR requirements tied to a particular date were added to one of the two tables below

*Note that the table contains the dates identified during this stage. I cannot guarantee that I identified every single article or requirement tied to a specific date.

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EU Packaging (PPWR) Authorised Representatives Guide

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The Packaging and Packaging Waste Regulation (PPWR) 2025/40 requires that companies selling products in the EU appoint an authorised representative for extended producer responsibility in the EU member states where they themselves are not established.

In this guide, we explain what EU and non-EU companies must know about the new authorised representative for extended producer responsibility requirements.

  • You may need an authorised representative for EPR in each EU member state
  • The requirement applies where you make packaging available
  • Applies to EU and non-EU companies
  • Some companies offer AR EPR solutions covering all 27 EU member states

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Guide to PPWR Requirements for Micro-Enterprises

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Companies defined as manufacturers under the Packaging and Packaging Waste Regulation (PPWR) 2025/40 must generally ensure that their packaging is compliant with the following areas:

  • Packaging design and materials
  • Substances
  • Labelling
  • Documentation
  • EPR

It is therefore essential to determine which company in the supply chain is defined as the manufacturer. This is not always obvious, as certain exemptions apply to companies defined as micro-enterprises.

This guide explains what these exemptions are and how packaging suppliers and companies selling products are impacted by exemptions applicable to micro-enterprises.

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EU Packaging Regulation (PPWR): How to Comply in 5 Parts

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Trying to understand what you must do to comply with the Packaging and Packaging Waste Regulation (PPWR) 2025/40? This guide serves as a practical step-by-step guide to PPWR compliance for manufacturers and importers.

Methodology

1. Article 62 lists the specific documents, labels, and other areas the authorities review to determine if your packaging is non-compliant with the PPWR.

2. As such, I used Article 62 to create a roadmap of what you must actually do to comply with the PPWR in practical terms.

Note: This guide does not cover every single requirement or aspect of the PPWR. Further, we only focus on requirements impacting manufacturers and importers.
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