PPWR Packaging Update: Information for Our EU Customers
The EU Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, started to apply on 12 August 2026. It creates a common framework for packaging and packaging waste across the EU. The Regulation covers packaging placed on the EU market, regardless of its material or country of origin.
For wholesale buyers, the practical question is straightforward: the cartons, plastic bags, tape and other packaging used to deliver products must be assessed against the PPWR requirements that apply at the time they are placed on the market. Requirements are phased in. Not every future PPWR target applies from August 2026.
What PPWR Means in Practice
PPWR is intended to reduce unnecessary packaging, improve recyclability and increase the use of recycled materials. Its principal requirements include:
- limits on substances of concern, including PFAS in food-contact packaging;
- packaging minimisation requirements, including future controls on excessive empty space in e-commerce and transport packaging;
- recyclability requirements for packaging from 2030, followed by a requirement that recyclable packaging is recycled at scale from 2035;
- minimum recycled-content targets for plastic packaging from 2030, with targets varying by packaging category.
- extended producer responsibility (EPR), registration and reporting obligations in the Member State where packaging is first made available and becomes waste.
The legal text is directly applicable across the EU, but EPR registration, reporting and fee arrangements remain organised by individual Member States. Buyers should therefore check the rules in every country where they sell or make packaged products available.
Our Packaging Documentation
H&L Furs has reviewed the packaging used for our outgoing orders and changed the suppliers for our shipping cartons, plastic bags and tape. For these packaging materials, we hold the supplier documentation and test reports obtained for the relevant material specifications.
EU customers may contact H&L Furs to request the available documentation for a specific order or packaging format. Please include the product or order reference, destination country and the packaging item needed (carton, plastic bag or tape). We can then provide the applicable supplier documents and reports for review.
Important: a test report or a supplier declaration is evidence for a defined material or requirement; it is not a blanket certification that every future PPWR obligation has been met. Compliance also depends on the packaging design, the applicable date, the role of the economic operator and the Member State in which the packaging is placed on the market.
Packaging Compliance Evidence Available on Request
To protect supplier confidentiality, we do not publish copies of test reports or supplier identities on this page. For the packaging components below, H&L Furs maintains the relevant independent test records and can provide the applicable documents to EU customers on request.
| Packaging component | Requirement assessed | Result recorded | Documentation |
|---|---|---|---|
| Brown corrugated shipping carton with black/white printing | PPWR Article 5(4): total lead, cadmium, mercury and hexavalent chromium | Pass: each analyte was reported as not detected; the combined limit is 100 mg/kg. | Independent test record and carton-specific DoC available on request. |
| Transparent BOPP adhesive tape | PPWR Article 5(4): total lead, cadmium, mercury and hexavalent chromium | Pass: each analyte was reported as not detected; the combined limit is 100 mg/kg. | Independent test record available on request. |
This public summary is limited to the tested requirement and identified packaging format. It does not disclose supplier information or replace the underlying technical documentation.
Does My Company Need to Register?
There is no single EU-wide PPWR registration website. Packaging EPR registration is completed through the producer register and/or producer responsibility organisation (PRO) of the relevant Member State.
In general, the responsible party is the “producer” under the national EPR rules: the company that first makes the packaging or packaged product available in that Member State. In a direct-to-consumer online sale, this can be the seller offering the packaged product to the end user in that country. In other supply chains, responsibility may sit with the importer, brand owner, distributor or another operator, depending on the packaging format and transaction.
Before registering, confirm these four points with your local compliance adviser or PRO:
- Which Member State(s) receive the packaged goods?
- Who first makes each packaging item or packaged product available in that Member State?
- Which packaging categories and annual quantities must be reported?
- Whether an authorised representative or PRO membership is required for your business model?
The correct starting point is the relevant national packaging producer register or a recognised PRO in the destination Member State. For example, businesses placing packaging on the market in Germany can start with the LUCID Packaging Register; in France, see ADEME SYDEREP; in Italy, see CONAI; and in Spain, see the Ministry’s Packaging Producer Register. These are country-specific examples, not a substitute for checking which entity is the producer in your particular transaction.
The European Commission’s PPWR FAQ and its implementation guidance explain the EU framework. They do not replace a Member State registration portal.
How to Prepare an EU Declaration of Conformity (DoC)
Under PPWR, the manufacturer must complete a conformity assessment, prepare technical documentation and draw up an EU Declaration of Conformity once compliance with the applicable requirements has been demonstrated. The required DoC structure is set out in Annex VIII of Regulation (EU) 2025/40.
A DoC should be issued by the economic operator that qualifies as the “manufacturer” for the specific packaging format under Article 3(1)(13) of PPWR. In a conventional B2B export transaction, this is commonly H&L Furs for packaging specified and used by H&L Furs. Where an EU customer has the packaging or packaged product made under its own name or trademark, that customer may instead be the manufacturer. A DoC should not be copied as a generic statement for every shipment: it must identify the exact packaging format and the evidence supporting the declaration.
| Required DoC item | What to include |
|---|---|
| 1. DoC number | A unique document number and the packaging identification or SKU. |
| 2. Manufacturer details | Legal name and postal address of the manufacturer; add the authorised representative where applicable. |
| 3. Responsibility statement | “This declaration of conformity is issued under the sole responsibility of the manufacturer.” |
| 4. Object of the declaration | A traceable description: packaging type, material composition, dimensions, weight, supplier reference, batch or production period. |
| 5. Legislation | State Regulation (EU) 2025/40 and only the other Union legislation that actually applies to the packaging. |
| 6. Technical basis | The harmonised standards, common specifications or other technical specifications used, plus the test-report references. |
| 7. Notified body | Include only if a notified body was involved; otherwise write “Not applicable”. |
| 8. Additional information and signature | Supporting information, place and date of issue, signer’s name, job title and signature. |
Keep the technical documentation and DoC for at least five years after a single-use packaging item is placed on the market, or ten years for reusable packaging. The records should be available in electronic form and supplied to a competent authority if requested.
Reference Links
- Regulation (EU) 2025/40: official PPWR text — see Articles 15, 38 and 39, Annex VII and Annex VIII.
- European Commission notice on PPWR application from 12 August 2026.
- European Commission PPWR FAQ.
- European Commission PPWR implementation guidance.
This article provides general commercial information, not legal advice. EPR registration and reporting responsibilities should be confirmed for the customer’s specific supply chain and destination country.
