Article
PPWR Frequently Asked Questions guide
By Caoilinn O’kelly
24 avril 2026
Key takeaways
Check out our Frequently Asked Questions about the PPWR.
Learn about the different roles and responsibilities, what should be in the Declaration of Conformity and much more.
With the PPWR now formally in force and the first compliance deadline, (August 2026) approaching, understanding your obligations has never been more pressing, particularly for companies placing packaged products on the EU market.
The Packaging and Packaging Waste Regulation (PPWR) is one of the most significant regulatory developments to affect the food and consumer goods industry in recent years, with far-reaching implications for QA, sustainability, and compliance professionals across the supply chain. At Simvia, we work closely with companies navigating this regulation every day and we have compiled the questions we hear most often into one practical reference guide.
Missing a question? Submit yours using the form below and receive a direct answer from our PPWR experts.
We have organised the questions into 9 topics to help you find the answers quickly.
Scope and Applicability
Roles and responsibilities
Documentation and compliance
Materials and scope
Testing, PFAS and substances
Recycling and reuse
Timing & Deadlines
Systems, Tools & Integration
Authorities and enforcement
Scope and Applicability
Does PPWR apply to all packaging? Imports, B2B etc.
Yes, it applies to all packaging placed on the EU market including all packaging waste whether empty or filled, regardless of the material used, and whether produced within the EU or imported from third countries.
Do requirements apply to secondary and tertiary packaging (e.g. stretch film, pallet paper)?
The regulation covers primary production packaging (for unprocessed products), sales packaging (goods sold to final customer), grouped packaging (grouping products at the point of sale), and transport packaging including e-commerce packaging.
How are multi-layer packaging and flow packs handled?
These are in scope. The EC guidance clarifies that packaging containing 5% or more plastic will be subject to single-use plastic packaging restrictions even if the primary material is something else, such as paper. Components must be considered individually for recyclability grading.
What rules apply to cardboard packaging?
In scope as either sales, grouped, or transport packaging depending on its use. All packaging must meet recyclability requirements from 2030 under Article 6.
What is considered a “display” in retail?
This depends on function. If a display serves primarily as a presentation or grouping mechanism for products at point of sale, it is likely considered grouped (secondary) packaging and falls within scope. The EC guidance published in March 2026 is the authoritative reference for borderline cases.
Roles and Responsibilities
What is the difference between a producer, manufacturer, importer, and distributor?
The PPWR introduces a significantly expanded definition of "economic operator" compared to previous directives. Unlike earlier frameworks, it creates parallel accountability, every actor in the chain carries its own compliance duties and cannot rely solely on upstream assurances.
The table below sets out the key roles and how they apply in common scenarios:
Role | Definition | Common scenarios |
Manufacturer | Any actor responsible for manufacturing packaging or packaged goods, including those who have goods designed or manufactured under their own name or trademark | Packaging producers, brand owners who commission packaging design |
Producer | Any actor that first makes packaging or packaged products available in a Member State, or unpacks packaged products without being the end user | It varies, it can overlap with manufacturer, importer, or distributor depending on who first places goods on the market in a given country |
Supplier of packaging materials | Any actor that supplies packaging or packaging materials to a manufacturer | Packaging material suppliers, raw material providers |
Importer | Any actor that places packaging from a third (non-EU) country onto the EU market for the first time | Companies sourcing packaged goods from outside the EU; carries the same obligations as manufacturers and must verify non-EU supplier compliance |
Distributor (incl. wholesalers & retailers) | Any actor in the supply chain who makes packaging or packaged products available on the market | Wholesalers, retailers if selling own-brand or private-label goods, they are normally considered the manufacturer under the PPWR |
Fulfilment service provider | Companies that store, package, address, or dispatch packaged products (e.g. e-commerce logistics providers) | Must ensure services do not result in non-compliance; directly liable if they handle non-compliant packaging |
Authorised representative | A representative appointed to act on behalf of a producer (especially non-EU companies) for national registration and EPR obligations | Non-EU exporters placing goods on EU markets without a physical EU presence |
Can a company have multiple roles (e.g. importer and distributor)?
Yes, and this is common in practice. A company can simultaneously hold multiple roles under the PPWR, and its obligations will be the sum of all roles it performs.
For example:
A company that imports packaged goods from outside the EU and distributes them under its own brand is both an importer and a manufacturer
A retailer that sources from third countries and sells under a private label is a manufacturer, importer, and potentially the producer in each Member State where it first places the product on the market.
The key principle is that each role carries its own distinct obligations, and a company cannot use one role to shield itself from the obligations of another. Each actor must verify, document, and retain its own evidence of compliance independently.
Important nuance: A distributor cannot be an importer for the same product, but roles can differ per product.
Documentation & Compliance
Do declarations of conformity (DoC) need to be provided to customers or only upon request?
There is generally no obligation to proactively pass the DoC to all downstream parties. Under Articles 18 and 19, importers must hold DoCs and make them available to authorities on request within 10 days. However, the DoC should be shared downstream when there are justified doubts about a packaging item's compliance, or when a distributor or importer requests it to fulfil their own verification obligations. Importers must collect and hold the DoC per packaging type for 5 to 10 years.
Who must create and sign the declaration of conformity (supplier vs packer)?
This is one of the most common misconceptions around the PPWR. The manufacturer, defined as the entity that places packaging on the EU market under its own name or trademark is responsible for issuing the DoC.
This is not necessarily the company that physically produced the packaging. For example, if a company commissions packaging from a supplier but sells it under its own brand, the brand owner is the manufacturer under the PPWR and must issue the DoC, the physical supplier does not bear this obligation.
The manufacturer signs the DoC, maintains the technical documentation, can be audited by market surveillance authorities, and must hold data that supports every claim in the declaration.
How many declarations of conformity are needed for multi-component packaging?
Each unique packaging type requires its own specific declaration. For multi-component packaging (e.g. a tray with a lid and a label), the question of whether one or multiple DoCs are required depends on whether the components are assessed as a single packaging unit or as separate items. Where packaging is subject to multiple EU legal regimes, a single combined declaration of conformity can be used, provided that the relevant Union acts are clearly identified
Can packaging materials be grouped in one declaration of conformity?
The DoC is issued per packaging type, so genuinely distinct packaging formats require separate declarations. However, where packaging items share identical material composition, design, and compliance characteristics such as the same format in different sizes or colour variants it may be possible to group them under a single DoC, provided all variants are clearly identified and the technical documentation covers each one. Each declaration must contain a unique EU-wide identification of the packaging, such as a batch or serial number, as well as the name, registered trade name, and postal address of the producer or manufacturer. Grouping is not a shortcut — every item covered must be individually traceable to the declaration.
Can Simvia generate a DoC based on uploaded data?
Yes. Simvia's platform allows you to generate a Declaration of Conformity based on the packaging and material data uploaded into the system. The DoC is pre-structured to align with the requirements of Annex VIII of Regulation (EU) 2025/40 and references the technical documentation held in your Simvia account. Note that the legal responsibility for the accuracy and completeness of the DoC always rests with the manufacturer. Simvia facilitates the process, but your team must verify the underlying data before signing.
Can conformity management be handled via Simvia?
Yes. Simvia supports end-to-end conformity management, including data collection from suppliers, document storage, DoC generation, and tracking of compliance status across your packaging portfolio. This is particularly valuable for companies managing large numbers of packaging types, where maintaining up-to-date documentation manually becomes unworkable. When packaging changes, the DoC must be updated so it always reflects the current version. Simvia's version control functionality supports this ongoing requirement.
Labelling & Marking
Must producer/importer contact details be printed on packaging?
Yes, from 12 August 2026. The manufacturer's name, trade name or trademark and postal address must appear on the packaging or via a data carrier such as a QR code (Article 15(6)). For importers, the same requirement applies to importer contact details under Article 18(3). Where the importer's name or brand already appears on the packaging under Article 21, the importer is the manufacturer for PPWR purposes and must meet Article 15(6) directly.
Importantly, the information does not have to be physically printed on the packaging itself, it can be provided via a QR code or other data carrier, or in an accompanying document where the size or nature of the packaging makes direct labelling impractical.
Is electronic contact information (e.g. QR code) mandatory or optional?
At the moment QR codes are accpeted as an alternative to physical printing for contact and identification information, not as a requirement from August 2026. However, from 2027, packaging must carry digital identifiers such as QR codes linking to structured information including material composition, recyclability and reuse details.
Testing, PFAS and Substances
Are PFAS and heavy metals analyses mandatory?
Yes, for food-contact packaging from 12 August 2026. The PPWR establishes two distinct substance obligations under Article 5:
Heavy metals Article 5(4):The combined concentration of lead, cadmium, mercury, and hexavalent chromium in all packaging not just food-contact must not exceed 100 mg/kg. This limit carries over from Directive 94/62/EC, so companies already meeting the previous directive's requirements need to update their technical documentation to reference Regulation (EU) 2025/40, but are unlikely to require new testing if materials are unchanged.
PFAS Article 5(5): Food-contact packaging may not be placed on the EU market from 12 August 2026 if it contains PFAS at or above the following thresholds:
· 25 ppb for any individual non-polymeric PFAS (targeted analysis)
· 250 ppb for the total sum of non-polymeric PFAS (targeted analysis)
· 50 ppm for all PFAS including polymeric PFAS (total fluorine screening)
Evidence of compliance with these thresholds must be included in the technical documentation file supporting the Declaration of Conformity.
Is “non-intentionally added” sufficient for PFAS compliance after 2026?
No, This is an important clarification confirmed by the EC's March 2026 guidance and the regulation itself. The PPWR does not distinguish between intentionally added and non-intentionally added PFAS when determining compliance — the concentration thresholds apply regardless of how PFAS entered the packaging. This is particularly significant for recycled paper and cardboard, which may contain PFAS from previous use cycles without any deliberate addition. Companies cannot simply declare that PFAS was not intentionally added and consider the matter closed. Actual measurement or verified supplier data demonstrating compliance with the concentration thresholds is required.
How should PFAS data be collected if no standard method exists?
The EC's guidance document published 30 March 2026 sets out an official stepwise approach to PFAS compliance testing in the absence of fully harmonised standard methods:
1. Total fluorine (TF) screening: Test the packaging for total fluorine content. If TF is below 50 ppm, the material can be considered compliant and no further testing is required.
2. Organic/inorganic differentiation: If TF exceeds 50 ppm, differentiate between organic and inorganic fluorine (e.g. using pyrolysis-GC/MS). If total organic fluorine (TOF) is below 50 ppm, the material can be considered compliant.
3. Targeted TOP analysis: If steps 1 and 2 do not produce a clear compliant result, a Total Oxidizable Precursor (TOP) assay is recommended to verify whether the 25 ppb and 250 ppb individual and sum thresholds are exceeded.
This stepwise approach is the Commission's current interpretative guidance, not a binding standard but it represents the best available official guidance for companies operating before harmonised analytical standards are published.
Are tests required for all packaging types or only primary packaging?
The PFAS limits under article 5(5) apply specifically to food-contact packaging. The heavy metals limits under Article 5(4) apply to all packaging placed on the EU market regardless of whether it is food-contact, primary, secondary or tertiary. Technical documentation demonstrating compliance with substance limits must therefore be maintained for all packaging types.
Can suppliers refuse to provide test reports?
No, not lawfully. Article 16(1) of Regulation (EU) 2025/40 places a specific obligation on suppliers of packaging materials to provide accurate and complete information to their downstream customers to enable them to fulfil their own compliance obligations. This includes data on chemical composition, recyclability performance, and compliance with PFAS and heavy metal thresholds. A supplier who refuses to provide the necessary documentation is in breach of their own Article 16 obligations. In practice, manufacturers and importers who cannot obtain the required information from a supplier cannot lawfully issue a Declaration of Conformity and therefore cannot place the packaging on the EU market.
Who is responsible for test results in global supply chains?
Responsibility is layered but ultimately rests with the manufacturer as defined under the PPWR. Suppliers of packaging materials bear their own obligation to provide accurate compliance data but the manufacturer must obtain, vertify and retain the necessary documentation.
Recycling, Reuse & Sustainability
How to handle recyclability requirements if recycling compromises food safety?
The regulation recognises that in certain cases, the obligation to make packaging recyclable must yield to overriding food safety and product safety requirements including contact-sensitive plastic packaging (infant formula, foods for medical purposes etc.). For food packaging that does not fall under these named exemptions, the expectation is that manufacturers design for recyclability within the constraints of food safety law for example, through the use of functional barriers or material redesign rather than claiming a blanket food safety override. The EC has indicated that delegated acts may be adopted to address additional specific cases.
What happens if no disposal route exists for a packaging material?
This is one of the most practically challenging aspects of the recyclability framework. The PPWR grades packaging recyclability from A (≥95%) to E (<40%), based on Design for Recycling (DfR) criteria set out in Annex II. From 1 January 2030, packaging with less than 70% recyclability, Grade D or below, cannot be placed on the EU market. From 1 January 2038, only Grades A and B will be permitted.
Critically, recyclability under the PPWR is assessed against existing collection, sorting, and recycling infrastructure across the EU, not theoretical recyclability. If a packaging material has no viable disposal or recycling route in practice, it is likely to score poorly under the DfR criteria and may fall into a non-compliant grade after 2030.
Packaging exempted from Design for Recycling criteria including lightweight wood, cork, textile, rubber, ceramic, porcelain and wax, alongside medical devices and transport packaging for dangerous goods is also considered exempt from the ban on incineration and landfilling.
For materials in the grey area, the Commission is required to adopt implementing acts by 1 January 2028 establishing the DfR criteria and recyclability performance grades. Companies using novel or difficult-to-recycle materials should engage with this process and, in the meantime, document their recyclability assessment against current best available guidance such as the RecyClass Design for Recycling Guidelines.
Timing & Deadlines
When do specific requirements apply? (e.g. PFAS, labelling, reuse)
What about the packaging already in stock?
Packaging already placed on the market before 12 August 2026 does not need to meet new requirements.
Systems, Tools & Integration
Can Simvia be integrated with ERP systems?
Yes. Simvia is designed to integrate with existing ERP systems through API connections and established technology partnerships. The platform supports integration with widely used ERP solutions such as SAP, Microsoft Dynamics 365 Business Central, and Oracle, as well as implementation partners like Modus Consult, B:Team, Freshfin, and Aptean.
Authorities & Enforcement
Which authorities will enforce PPWR requirements?
Market surveillance authorities in each EU member state are responsible (varies by country).
Netherlands
The Netherlands Food and Consumer Product Safety Authority (NVWA — Nederlandse Voedsel- en Warenautoriteit) is the primary market surveillance authority for packaging compliance in the Netherlands. For violations, the NVWA primarily imposes penalty payments, which typically amount to €5,000 per week with a maximum of €50,000. It can also impose direct sales bans for non-compliant products.
Germany
In Germany, the Central Agency Packaging Register (Zentrale Stelle Verpackungsregister, ZSVR) remains the central authority responsible for monitoring compliance with packaging law obligations. Market surveillance ie. verifying whether packaging on the market actually meets PPWR requirements falls under the competent authorities of the federal states (Länder). The ZSVR actively refers suspected cases of non-compliance to these state-level authorities. Registration in the LUCID register remains mandatory, and violations of registration or reporting obligations can result in fines of up to €200,000 as well as sales bans.
Staying ahead of PPWR compliance
The PPWR is a genuine shift in how the EU regulates packaging: one enforceable framework, parallel accountability across every role in the supply chain, and a schedule of obligations stretching from August 2026 out to 2040.
The questions above are the ones we hear most often, but they are a starting point rather than the full picture. Declarations of Conformity, PFAS testing, recyclability grading, and importer obligations all interact and gaps made early (an incomplete technical file, a missing supplier attestation, an untested assumption about who counts as the manufacturer) tend to compound as deadlines approach.
If your question is not covered above, submit it using the form and one of our PPWR experts will get back to you directly. And if you would like to see how Simvia supports end-to-end conformity management from supplier data collection to DoC generation get in touch. We are happy to walk through your specific packaging portfolio.
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