EU PPWR FAQs Updated August 2026 - Flipbook - Page 38
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OBLIGATIONS OF MANUFACTURERS
1) Article 15(1) states that manufacturers must place on the market only packaging
which complies with the requirements set out in Articles 5 to 12. Does this obligation
apply exclusively to packaging manufacturers?
The obligation to place on the market only compliant packaging does not apply only to economic
operators defined as the manufacturer, but also to importers and distributors.
Pursuant to Article 15(1), 8manufacturers shall only place on the market packaging which is in
conformity with the requirements laid down in or pursuant to Articles 5 to 12.9 The conformity
assessment procedure (Article 38) can be carried out by the manufacturer or by someone else on
their behalf (e.g. a laboratory or a certification scheme), in accordance with Article 15(2). The EU
declaration of conformity (Article 39) must be drafted by the manufacturer, based on the
information and documentation provided by suppliers pursuant to Article 16(1), or by an authorised
representative, appointed by the manufacturer by a written mandate pursuant to Article 17. This
means that the manufacturer is the sole economic operator bearing legal responsibility for
packaging compliance with the sustainability and labelling requirements, regardless of the fact
who might have actually drafted the EU declaration of conformity or parts of it.
2) When is the effective date of application of Articles 15 and 18 of the PPWR on
obligations of importers and manufacturers?
PPWR will become applicable on 12 August 2026, and this includes provisions on the obligations
of manufacturers and importers. However, these provisions must be read in conjunction with the
substantive obligations, as defined in various provisions of the Regulation, notably in Articles 5 3
12. Some substantive provisions have different application dates, which are often linked to the
adoption of a specific implementing measure by the Commission.
For example, as regards recyclability, manufacturers must comply with the recyclability
requirements and perform the conformity assessment procedure in accordance with Article 38 and
Annex VII of the PPWR only two years from the adoption of the delegated act on design for
recycling requirements. On the assumption that this delegated act will be adopted by the
Commission in January 2028 and will fully harmonise design for recycling requirements and the
related assessment methodology, the binding recyclability performance criteria will only apply
from 1 January 2030 or two years from the date of entry into force of the delegated act.
Other effective dates of application of sustainability and other key requirements under PPWR:
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Recycled content in plastic packaging: 1 January 2030 or three years from the date of entry
into force of the implementing act referred to in Article 7(8) PPWR.
Minimisation (Article 10(1) 3 (2)): 1 January 2030.
Void space requirement for transport, grouped and e-commerce packaging: from 1 January
2030 or three years after the entry into force of the implementing act under Art. 24(2); as
regards void space in sales packaging, see Art. 10.
Reusable packaging (Art. 11): from the date of entry into force of the Regulation (11
February 2025), but minimum number of rotations will have to be complied with
depending on the date that will be specified in the implementing act referred to in Article
11(2) to be adopted by 12 February 2027.
Reuse targets: from 1 January 2030 or 18 months from the date of entry into force of the
implementing act on the calculation of reuse targets, referred to in Article 30(3), to be
adopted by 30 June 2027.
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