Who is affected and what they must do
PPWR assigns obligations by role a company plays in the supply chain, not by industry sector or company size. A single company can hold more than one role at the same time, and the same product can place a company in different roles across EU Member States.
Find the role your company actually plays, then read the obligations that apply. Multiple roles, mean the obligations stack.
Manufacturers and brand owners
The manufacturer under PPWR is the entity placing the packaging on the EU market under its own name or trademark. A brand owner that fills purchased empty packaging is the manufacturer, even if a converter physically made the pack. This role carries the most obligations.
- Issue an EU Declaration of Conformity for each packaging type (Article 39, Annex VIII)
- Maintain the underlying technical file under Annex VII (Module A, Internal Production Control)
- Substance compliance under Article 5 (PFAS in food contact, heavy metals)
- Recyclability scoring under Article 6 (Grade A, B or C from 2030)
- Recycled content under Article 7 (post-consumer only, from 2030)
- Packaging minimisation under Article 10
- Labelling and pictograms under Article 12 (from 2028)
- EPR registration and eco-modulated fees per Member State (from 2027)
- Retention: 5 years (single-use), 10 years (reusable)
Importers
Importers do not issue the Declaration of Conformity. They must verify that one exists, that the non-EU manufacturer has actually done the conformity assessment, and that the technical file is available on request. Watch out for Article 21: an importer that places packaging on the EU market under its own name becomes the manufacturer for PPWR purposes.
- Verify the manufacturer’s DoC and technical file are in place
- Check that labelling, traceability and contact information comply
- Ensure EPR registration in the Member State of first placement
- Retain a copy of the DoC and supporting documentation
Retailers and distributors
Distributors must act with due care when making packaging available on the market. The biggest operational changes for retail land from 2028 onwards.
- Verify the producer is registered in the national EPR register
- Verify labelling and material composition codes are compliant
- Confirm manufacturer and importer contact information is on the packaging
- Final distributors with a sales area over 400 m² must allocate at least 10% of sales area to refill stations from 1 January 2030 (Article 32)
- Single-use plastic packaging consumed on the premises is banned from 2030
HORECA (hotels, restaurants, catering)
HORECA is where the consumer-facing changes arrive fastest.
- Accept the consumer’s own container at no extra charge from 12 February 2027
- Offer reusable take-away options at no extra charge from 12 February 2028
- Single-use plastic packaging for on-premises consumption banned from 1 January 2030 (Article 25)
- Miniature sachets in hotels banned from 2030 (Annex V)
E-commerce operators
For e-commerce, the empty-space and transport-reuse rules bite hard.
- Empty-space ratio capped at 50% from 2030 (includes air cushions, bubble wrap, paper void fill)
- Transport packaging reuse: 40% by 2030, 70% by 2040
- Transport packaging between sites of the same or partner enterprises: 100% reuse by 2030
- Labelling and EPR obligations as for other operators
Fulfilment service providers
Fulfilment service providers (warehousing, third-party logistics, marketplaces operating their own fulfillment) carry their own due-care obligations.
- Ensure packaging is compliant from warehousing through to dispatch
- Request remediation from the upstream operator if non-compliance is found
- Suspend services if the upstream operator does not remedy the issue
Conclusion
Misclassifying your position in the supply chain means either missing obligations that apply to you or over-investing in compliance that isn’t yours to carry. Both are costly. Additionally, remember that dual roles are common, meaning the same company can be a manufacturer in one Member State and an importer in another, with the full weight of obligations stacking accordingly.