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Most discussions about PPWR revolve around the same few points: the 12 August 2026 date, the PFAS ban, the recycled content targets from 2030. These are real and important. But in consultancy practice, we observe a series of equally significant obligations and clarifications that go almost unnoticed, even though the implementation guidance published by the European Commission on 30 March 2026 addresses them explicitly.
This article covers these less-discussed aspects, which nonetheless have direct impact on how companies need to prepare.
The Declaration of Conformity becomes mandatory for every packaging type
From 12 August 2026, any packaging placed on the EU market must be accompanied by a Declaration of Conformity. This is a legally binding self-declaration by which the manufacturer confirms that the packaging meets PPWR requirements on hazardous substances, minimisation, recyclability, recycled content, and reuse, where these are already applicable.
The Declaration is not a routine administrative form. It is a technical document backed by supporting evidence that must be made available to market surveillance authorities on request. The retention period is five years for single-use packaging and ten years for reusable packaging.
What this means in practice: any company placing packaging on the EU market under its own name or registered trademark must prepare this documentation for every packaging type in its portfolio not per finished product, but per packaging format. If the portfolio includes dozens or hundreds of formats, the scope of the task becomes significant.
PPWR draws a clear distinction between manufacturer and producer
This is one of the clarifications with the greatest practical impact in the Commission's March 2026 guidance, and one of the most frequently confused in discussions about PPWR.
Under PPWR, the term manufacturer designates the economic operator responsible for the technical compliance of the packaging with design, substance, and labelling requirements. Most often, this is the brand owner or trademark holder, regardless of whether the packaging is physically produced by a third party. If your product carries your company's name or logo on the packaging, you are the manufacturer under PPWR not the packaging supplier.
The producer, on the other hand, is the economic operator responsible for fulfilling EPR obligations: registration in the national register, data reporting, and fee payment. This is determined by where the packaging is expected to become waste that is, the market where the product is sold.
The distinction is particularly relevant for companies selling through distributors or on online platforms across multiple Member States. Manufacturer obligations remain with the brand owner regardless of the distribution channel. Producer obligations may fall on a different economic operator in the supply chain, depending on who places the packaging on the market of a specific Member State first.
The Commission's guidance specifies that there is always only one manufacturer per packaging unit in any supply chain. If your brand is on the packaging, that manufacturer is most likely you.
Environmental claims on packaging become subject to strict restrictions
An aspect almost entirely absent from public debate: PPWR introduces direct restrictions on environmental statements applied to packaging.
Under the regulation, an environmental claim on packaging such as "recyclable", "made from recycled materials", "eco-friendly", or their equivalents may only be legally communicated if the packaging's performance exceeds the minimum requirements set by PPWR, and if the claim clearly specifies what it refers to: the packaging unit as a whole, a specific component, or the total packaging placed on the market.
This overlaps with the Green Claims Directive and with the Empowering Consumers Directive (EU) 2024/825, which already tightened restrictions on greenwashing in commercial communications. In practice, vague statements such as "environmentally friendly packaging" or "sustainable packaging" without a verifiable technical basis become exposed under both PPWR and anti-greenwashing legislation. Companies currently using such formulations on packaging sold in the EU must audit and align them before August 2026.
Online platforms are explicitly included in the scope
PPWR explicitly addresses online marketplace operators as responsible actors when they handle packaging or logistics on behalf of third-party sellers. This clarifies and harmonises an area previously treated inconsistently at national level.
In concrete terms: if an e-commerce platform physically handles products and packages them for shipment, it may be considered the producer in the Member State of delivery, with all associated EPR obligations. If the third-party seller is established outside the EU, responsibility may shift entirely to the platform or to the seller's authorised representative.
For marketplace operators and fulfilment service providers serving the European market, the clarifications in the Commission's 2026 guidance require a careful analysis of the operating model and the resulting obligations.
There is no grace period for existing packaging stocks
Another aspect with direct operational implications: PPWR does not provide a transitional period for packaging stocks already in a company's possession on 12 August 2026.
Packaging produced and placed on the EU market before that date may remain in circulation. But any packaging placed on the market after 12 August 2026 must comply with the PFAS ban and all other requirements applicable at that date, without exception. This means that packaging materials purchased before August 2026 but not yet used at that date fall under the regulation if they are placed on the market afterwards.
Companies holding large stocks of non-compliant packaging materials have a limited window to use them and must plan the transition to compliant materials with sufficient lead time.
Deposit and return systems become mandatory from 2029
By 2029, Member States must implement mandatory deposit and return systems for plastic bottles and metal cans for beverages, unless they already achieve a collection rate above 80% in 2026. These systems will be harmonised at European level to facilitate cross-border use.
For beverage producers and distributors, this means that the logistics infrastructure for returns including markings, identification codes, and reporting systems must be planned well ahead of the 2029 deadline.
The Environmental Omnibus and current uncertainty
One reality companies must understand: PPWR is also subject to the broader legislative simplification process known as the Environmental Omnibus, initiated by the European Commission. Industry discussions focus on potential flexibilities, particularly regarding reuse requirements and how chemically recycled plastics may count toward recycled content targets.
The dominant position of the industrial sector, expressed through organisations such as EUROPEN, is that companies need clarity now, not a reopening of negotiations. Investments in packaging redesign, supplier qualification, and documentation system development cannot be deferred pending the outcome of a potential Omnibus.
Our recommendation aligns with the industry position: prepare according to PPWR as it currently stands. Any future simplification will be a benefit, not a penalty for those who have already complied.
The penalties are not symbolic
Member States set their own penalty regimes, but sector experts estimate fines of up to 4% of turnover for non-compliance with EPR obligations or for incorrect reporting a level comparable to the GDPR framework. Non-compliance may also result in market access being blocked, not just fines, which means the business risk significantly exceeds the cost of proactive compliance.
How all of this integrates into a sustainability strategy
The technical aspects of PPWR from the Declaration of Conformity to restrictions on environmental claims are not separate from ESG reporting. They constitute the operational evidence that a sustainability strategy is functioning in practice, not just at the level of commitments.
Companies reporting under CSRD will need to demonstrate in ESRS E5 that their packaging management is aligned with the circular economy. Those going through EcoVadis assessments will find that PPWR documentation, if correctly structured, directly supports the environmental categories in the EcoVadis scoring methodology. And for companies developing or updating a Life Cycle Assessment, PPWR's clarifications on recyclability grades and accepted methods for calculating recycled content change the end-of-life modelling assumptions for packaging.
ECONOS supports companies in building PPWR documentation integrated with sustainability reporting, so that the same effort serves regulatory compliance, CSRD reporting, and EcoVadis score improvement simultaneously. If you want to understand what this approach means concretely for your company, contact our team.