List of Packaging Covered by the EU Packaging Regulation (PPWR)

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The Packaging and Packaging Waste Regulation (PPWR) 2025/40 sets new, extensive requirements for packaging in the European Union. That said, it’s not always clear what sort of items are deemed to be packaging in the meaning of the PPWR.

In this guide, we take a closer look at the types of packaging that are subject to the PPWR and exempt. Note that the exact same item (i..e, a clothing hanger) can be deemed packaging when sold with a product, while it’s not deemed packaging if sold separately.

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Guide to EU Packaging Regulation (PPWR) Labelling Requirements

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The Packaging and Packaging Waste Regulation (PPWR) introduces new labelling requirements applicable to packaging (including product packaging) in the European Union. This guide serves as an introduction to several key labelling requirements.

  • Packaging will require a harmonised label
  • QR codes are required
  • Type, batch or serial number
  • Manufacturer and importer information

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PPWR Documentation Requirements

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The Packaging and Packaging Waste Regulation (PPWR) introduces new documentation requirements for packaging (including product packaging). This guide serves as an introduction to several key documents required under the PPWR.

  • Supplier documentation
  • Declaration of Conformity (DoC)
  • Technical documentation

Manufacturers

The company, defined as the manufacturer (of packaging or packed products), is generally responsible for creating the DoC and the technical documentation. There are also some circumstances in which the packaging supplier is responsible.

Suppliers

A supplier is the entity that supplies packaging or packaging materials to a manufacturer. Most product manufacturing companies do not produce packaging (or at least not the materials) in-house and procure from upstream suppliers instead. This entity is also responsible for providing certain documentation.
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Guide to EU PPWR Substance Restrictions

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The Packaging and Packaging Waste Regulation (PPWR) restricts substances in packaging materials, specifically heavy metals and PFAS. This guide provides an overview of the substance restrictions in Article 5 of the PPWR and how you can demonstrate compliance.

  • PPWR restricts lead, cadmium, mercury and hexavalent chromium
  • PPWR restricts PFAS in food-contact packaging
  • Testing is generally required to verify the substance contents

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List of EU Packaging Producer Responsibility Organisations (PRO) 2026

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Companies supplying packaging (including product packaging) must report and contribute financially to the collection and recycling of their packaging waste. Doing so generally requires that you register with a Producer Responsibility Organisation (PRO) in each EU member state where you supply products.

In practice, this means that you pay a fee to a PRO, which in turn collects, disposes of, and recycles your packaging. PROs can also help you to comply with registration, reporting, and other requirements.

In this guide, we list packaging PROs in Germany, France, Italy, the Netherlands, Sweden, and other EU member states.

2026 update: We have updated the list of packaging PROs based on companies that claim to provide packaging EPR solutions.

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