PPWR: Answers to Our Customers’ Most Frequently Asked Questions

What is PPWR?

PPWR is the new European Regulation on Packaging and Packaging Waste. It entered into force in February 2025 and starts to apply generally across the EU from 12 August 2026.

However, not all requirements take effect at the same time. Some apply from August 2026, while others will be introduced gradually over the following years. Key changes include restrictions on PFAS in food-contact packaging, new requirements for packaging documentation and traceability, and, in the future, harmonised labelling, recyclability requirements and minimum recycled content.

What about packaging you are currently buying from us or already have in stock?

There is no need to worry about our current packaging.

We prepared for the PPWR requirements well in advance. The doypacks and flexible packaging materials in rolls that we manufacture today meet the PPWR requirements relevant from 12 August 2026. We have been manufacturing them in this way for approximately six months.

This means that if you have our packaging in stock that was manufactured during this period, you can continue to use it as usual after 12 August 2026.

What about older stock?

Older packaging does not automatically need to be discarded either. However, in these cases, we recommend checking the specific order.

PPWR takes into account when the packaging was actually placed on the market, and this point in time may not always be the same as the date on which we delivered the empty packaging or roll material to you. For packaging supplied in rolls and certain pre-formed packaging, subsequent filling, sealing or other finalisation of the packaging may also be relevant. For example, the European Commission states that for food sales packaging, where the final filling or sealing process may affect the packaging’s compliance, placing on the market generally occurs only at that stage.

If you therefore have older stock of our packaging that you intend to use after 12 August 2026, please contact us. Based on the order number or batch number, we will verify the material structure used and let you know whether everything is compliant with the current requirements.

Packaging that was actually placed on the market before 12 August 2026 may remain on the market even if it does not meet certain newly applicable PPWR requirements. However, the date of manufacture or delivery of empty packaging alone is not decisive in every case.

Do I need to change the material of my packaging because of PPWR?

Not automatically.

PPWR introduces individual requirements gradually. For this reason, we always assess your existing packaging based on its specific material structure and intended use.

For new projects, we already recommend material solutions with future requirements in mind – particularly recyclability requirements from 2030 onwards and other rules applying to plastic packaging.

The goal is not to replace functional packaging simply because a new regulation has been introduced. The aim is to choose a solution that meets current requirements while also being as well prepared as possible for the rules that will apply in the years ahead.

Will I need to change the artwork or labelling on my packaging?

You do not automatically need to redesign all your packaging artwork because of 12 August.

PPWR introduces several different types of labelling requirements, and it is important not to confuse them. The harmonised European packaging labelling system for waste sorting will only start to apply from 2028.

At the same time, certain requirements relating to packaging identification and the manufacturer’s identification or contact details will start to apply under PPWR from 12 August 2026. In some cases, the required information may also be provided in accompanying documentation, so a complete artwork change may not be necessary.

For each new order, we will therefore assess whether anything needs to be added to the artwork. If so, we will let you know before production.

What documentation will I need and who will prepare it?

PPWR introduces a system of conformity assessment, technical documentation and the EU Declaration of Conformity.

There is one important distinction here: under PPWR, the manufacturer of the packaging material itself is not necessarily considered the legal “manufacturer” of the final packaging. For standard sales packaging, this is generally the company that fills the packaging and places the packaged product on the market. The packaging supplier, on the other hand, is required to provide that manufacturer with the information and documentation needed to demonstrate compliance.

However, we will make the paperwork related to our packaging as simple as possible for you.

For our packaging, we will provide the necessary technical and material documentation to support compliance with PPWR. This means you will not have to search for detailed information about the packaging materials used or their properties yourself.

If, under PPWR, you are considered the manufacturer of the final packaging, the formal responsibility for the final technical documentation and the EU Declaration of Conformity remains with you. However, we will provide you with the supporting information you need for that documentation. The European Commission explicitly states that packaging suppliers must provide manufacturers with all the necessary information and documentation, while the final legal responsibility for compliance remains with the manufacturer of the final packaging.

Not sure how PPWR applies to your specific packaging?
Send us your order number or packaging specification. We will verify the material structure used and let you know whether you can continue using the packaging without any changes, or what may need to be adjusted.