The EU Regulation on Packaging and Packaging Waste – how to prepare your business for the new obligations

For many businesses, the entry into force of the PPWR Regulation represents not only a change in legislation but also the need to reorganise operational processes. The new regulations cover the entire life cycle of packaging and require a systematic approach – from design, through logistics, to documentation and environmental compliance. In practice, this means that packaging is becoming an area of risk management and regulatory compliance. Businesses will have to adapt not only the packaging itself, but also their internal processes and cooperation with suppliers. How can they prepare?

1. Packaging audit – the first step towards compliance

The basis for implementing the PPWR is a thorough analysis of the packaging currently used by the company. The audit should cover all types of packaging – including unit, collective and transport packaging – and take into account their function, material composition and how they are used throughout the supply chain.

In practice, this means collecting data on, amongst other things, the raw materials used, the weight of the packaging, its recyclability and compliance with future requirements for design for recycling.

The following questions must be answered:

• Is the packaging recyclable within existing systems?
• Does it contain a sufficient proportion of recycled materials?
• Are its volume and weight justified, and can they be optimised?
• Does the packaging’s design hinder its recycling?

A well-conducted audit not only identifies areas of non-compliance but also highlights opportunities for cost optimisation, for example by reducing materials or changing the packaging design.

2. New documentation requirements

One of the key requirements will be the preparation of a Declaration of Conformity for packaging (EU Declaration of Conformity). This document confirms that the packaging in question meets all the requirements of the PPWR and may be placed on the EU market. Importantly, it will have to be made available to the supervisory authorities for the entire period during which the packaging or product is made available on the market.

In practice, this means that data on the materials used, their origin and technical specifications must be systematically collected and updated. Close cooperation with packaging suppliers will also be essential, as they must provide reliable and complete information, and internal quality control procedures will need to be implemented to ensure the consistency and compliance of data throughout the supply chain.

3. Cooperation within the supply chain

The PPWR places responsibility on the entity placing the product on the market – but in practice, it requires cooperation across the entire supply chain.

Companies will have to:

• obtain data from packaging manufacturers,
• verify the compliance of materials,
• require declarations from suppliers.

This means greater transparency – but also greater risk if the data is incomplete or incorrect.

4. Changes to the business model

For many businesses, the PPWR means they must change their approach to packaging. Among other things, this involves switching to reusable packaging, implementing return schemes, optimising logistics and investing in new materials. In practice, the regulation enforces the implementation of circular economy principles.

5. Risks and sanctions

Although specific penalties will be determined at national level, non-compliance with the PPWR may result in financial penalties, a ban on placing products on the market, and the risk of reputational damage. It is worth bearing in mind that the regulation covers virtually all sectors – from FMCG to e-commerce – so its impact will be wide-ranging and felt throughout the supply chain.

Get in touch with us – we’ll help you prepare your business to meet the requirements of the PPWR and plan the steps needed to implement them effectively.