Author: Jenny Mae Vansteenlandt

As of 12 August 2026, the first provisions of the European Packaging and Packaging Waste Regulation (PPWR) will come into force. Although the implementation date is approaching quickly, the impact of this new regulation is still not sufficiently clear for many companies.

Yet a large number of organisations will be affected. Do you work with packaged products, place goods on the market, or use packaging in your logistics processes? If so, there is a strong likelihood that the PPWR will introduce obligations for your business as well.

Why was the PPWR introduced?

With the PPWR, the European Union aims to reduce packaging waste and stimulate the circular economy. The regulation not only replaces existing rules but also significantly tightens them.

Where the focus previously lay mainly on packaging waste, the PPWR now covers the entire lifecycle of packaging: from design and material choice to use, reuse, recycling, and reporting.

For companies, this results in additional responsibilities, more extensive documentation requirements, and a greater need for reliable data.

Which companies fall under the PPWR?

The regulation is not limited to packaging producers. Almost any party that places or uses packaging on the European market will be affected.

The PPWR is generally relevant if you:

• sell packaged products within the EU;
• import products from outside the European Union;
• use packaging for storage, shipping, or transport;
• operate as a manufacturer, importer, distributor, or retailer.

Even companies that do not design packaging themselves may still carry responsibilities under the new rules.

Who carries which responsibility?

A key principle of the PPWR is that multiple parties within the same supply chain can have obligations. Two roles are particularly important:

The manufacturer

The manufacturer is responsible for ensuring the packaging complies with the PPWR requirements. They must be able to demonstrate this compliance.

This is achieved through:

• a conformity assessment;
• a declaration of conformity;
• technical documentation supporting compliance.

From August 2026 onwards, packaging may only be placed on the market if these documents are available.

 

The producer or ‘first placer on the market’

The producer is the party that introduces packaging to the European market for the first time.
This is not necessarily the manufacturer. An importer, distributor, or retailer may also assume this role.

The producer must:

• be registered where required;
• comply with reporting obligations;
• hold the necessary documentation;
• be able to present a declaration of conformity to authorities.
  
  

The different roles within the chain

Manufacturer

If you develop or produce packaging under your own name, you are considered the manufacturer. You are responsible for:

• packaging design;
• materials used;
• demonstrating compliance with the PPWR;
• preparing the required documentation.

Importer

If you import packaged goods from outside the EU, you must verify in advance that:

• the packaging is compliant;
• a declaration of conformity is available;
• technical documentation is present.

If the packaging does not comply, it may not be placed on the market.

Distributor

Distributors mainly have a monitoring role.
They must check whether:

packaging complies with the PPWR;
the required documents are available;
there are no indications of non-compliance.

• packaging complies with the PPWR;
• the required documents are available;
• there are no indications of non-compliance.

Appropriate action must be taken if there is any doubt.

 

Final distributor

Companies selling directly to consumers must, among other things, verify that packaging is correctly labelled and that the required information is available.

When are you considered a producer? Two practical examples

Example 1: Belgian wholesaler
An Italian manufacturer supplies packaged goods to a Belgian wholesaler. The Belgian company places these products on the Belgian market for the first time.
In this case, the Belgian wholesaler is considered the producer.

Example 2: Private label
A retailer has products manufactured in Asia and sells them under its own brand name in Belgium.
Because the retailer imports and introduces the products to the European market, it is considered the producer under the PPWR.

 

What obligations does the PPWR impose?

1. Less packaging waste
The regulation aims to reduce unnecessary packaging and promote alternatives to single-use packaging.

2. Use of recycled materials
Minimum targets are introduced for the use of recycled materials in plastic packaging towards 2030 and 2040.

3. Improved recyclability
Packaging must be sufficiently recyclable. Non-compliant packaging will gradually disappear from the marke

4. More reuse
Reuse of packaging is becoming increasingly important, especially within logistics and transport chains.

5. New labelling requirements
From 2028, a harmonised European labelling system will be introduced, providing information on material composition and proper sorting.

Several technical implementing rules are still being further developed.

 

What must be in place by August 2026?

For many companies, the current focus is on preparation. By 12 August 2026, producers must at least have:

• a declaration of conformity for each type of packaging;
• access to the technical documentation supporting that conformity.

This requires a structured approach, reliable supplier information, and clear visibility across the full packaging chain.

How to prepare

Step 1: Create an inventory of all packaging
Map all packaging used:

• material types;
• weight;
• dimensions;
• application;
• use within logistics, retail, or e-commerce.

This inventory forms the basis for further compliance.

Step 2: Analyse your role
Your role may differ per product or packaging type.

A single company may simultaneously act as manufacturer, importer, and distributor. A thorough analysis is therefore essential to determine the correct obligations.

Step 3: Gather the necessary data
For many organisations, the main challenge lies not in the regulation itself, but in the availability of accurate data.

Ensure timely access to:

• declarations of conformity;
• technical files;
• supplier information;
• data on materials and composition.
  
  

Conclusion

The PPWR is currently still in a transition phase. Not all technical guidelines have been finalised, and many companies do not yet have all the required data. However, waiting is not an option. Companies are expected to demonstrate that they are actively working towards compliance, have insight into their packaging flows, and are setting up the necessary processes to meet future obligations.

Those who start now with inventorying, documenting, and analysing will be best positioned to be ready by August 2026.