Have you already taken the necessary steps to comply with the first PPWR deadline, which will apply from 12 August 2026?
As of 12 August 2026, the “manufacturer” (as defined in the PPWR) must have drawn up an EU Declaration of Conformity and made it available to the competent authorities.
Organisations placing packaging on the European market will be subject to new documentation obligations. Depending on your role in the supply chain, you are responsible for drawing up an EU Declaration of Conformity or for providing the necessary information required to prepare it.
The PPWR introduces new documentation obligations for all packaging placed on the European market. Preparing the EU Declaration of Conformity requires information from various actors throughout the supply chain. Depending on your role, you may be required to provide information to the manufacturer, or you may be responsible for drawing up and maintaining the EU Declaration of Conformity yourself.
The obligations applicable to your organisation depend on several factors, including the type of packaging, your position within the supply chain and which party places the packaging on the market under its own name or trademark. Verpact has developed various documents that can help determine your organisation’s role and responsibilities: https://www.verpact.nl/nl/alles-over-de-ppwr.
Determine your position in the supply chain
To determine which obligations apply to your organisation, the following steps are important.
- What is your role in the supply chain?
| Role | Activity |
| Manufacturer | The party placing the packaging on the Union market under its own name or trademark. In practice, this is often the brand owner |
| Supplier | Supplies empty packaging (or packaging components) or packs products on behalf of the manufacturer |
| Importer | Any company importing packaging (empty) or packaged products into the European Union. |
| Distributor | Any organisation within the EU that receives packaged products from a manufacturer or importer and makes them available further down the supply chain |
- Which types of packaging do you have?
- Service packaging (filled at the point of sale).
- Take-away packaging (filled with food or beverages at the point of sale).
- Primary production packaging.
- Sales packaging (the sales unit purchased by the end user).
- Grouped packaging (used to group a number of sales units, for example for restocking purposes).
- Transport packaging (designed to facilitate the handling and transport of sales units).
- What are you responsibilities in the supply chain?
| Role | Responsibilities |
| Manufacturer | Draw up an EU Declaration of Conformity for each packaging type |
| Supplier | Provide the necessary information required for drawing up the Declaration of Conformity |
| Importer | Obtain the Declarations of Conformity for the packaging and/or packaged products they import |
| Distributor | Verify that the packaging complies with the PPWR and that the required information is available when needed |
- Which information do you still require?
- Once you have identified your role and packaging types, determine which information is still missing in order to comply with the PPWR.
Declaration of Conformity
In accordance with the PPWR, the EU Declaration of Conformity maintained by the manufacturer should include the following:
- Name and address of the “manufacturer”.
- A clear reference to the packaging to which the declaration applies (product name, product code, etc.).
- Product specification.
- Technical specifications.
- Recycling information, where available. The official methodology for determining the recyclability performance grade (A, B or C) is expected to be established in 2028 and will only become mandatory from 2030 onwards.
- Heavy metals: confirmation (including test results) that the combined concentration of Lead (Pb), Cadmium (Cd), Mercury (Hg) and Hexavalent Chromium (Cr VI) does not exceed 100 mg/kg.
- Confirmation (including test results) that no substances listed in Annex XVII to Regulation (EC) No 1907/2006 (REACH) have been used.
- For food contact packaging, additional PFAS requirements apply.
- Signature of the “manufacturer”, including date and place.
How can Q-Point support you?
The PPWR requires cooperation throughout the entire supply chain. Q-Point supports organisations in determining their role, collecting the required documentation and preparing the EU Declaration of Conformity, ensuring that your organisation complies with the new legislation in time.
Do you have any questions or would you like to get in touch with one of our consultants? Please do not hesitate to contact us!
Also take a look at our training course on the requirements for food contact materials!
https://q-point-bv.nl/en/trainings/assessment-packaging-material-documentation/
