EU PPWR FAQs Updated August 2026 - Flipbook - Page 39
3) Should suppliers be required to mark 8plain9 packaging, such as plastic carrier bags,
with a serial number?
Suppliers of packaging or packaging material are not manufacturers according to the definition of
manufacturer in Article 3(1), point (13), except when the 8manufacturer9 is a microenterprise and
the supplier is located in the same Member State.
The Regulation does not require that suppliers of packaging are identifiable on the packaging or
via a data carrier. They must only ensure that the manufacturer has all the information and
documentation necessary to demonstrate packaging conformity.
The Regulation does not require either that suppliers identify packaging with a type, batch or a
serial number; this is an obligation that falls on manufacturers. However, in practice, it may well
be that it will be the suppliers of packaging who will ensure that packaging is identifiable, as this
is often done at the production stage.
4) What are the obligations of importers or distributors who supply packaging
materials? UPDATED!
In general, suppliers of packaging are not responsible for drawing up a declaration of conformity.
However, pursuant to Article 16 of the Regulation, they are required to provide the manufacturer
of the packaging 8with all the information and documentation necessary for the manufacturer to
demonstrate the conformity of the packaging with this Regulation9, including all the relevant
technical documentation. The company which places packaging or packaged products on the EU
market (manufacturer/importer) has the legal responsibility for ensuring overall compliance with
relevant PPWR requirements, including those stemming from Articles 5-12. It will therefore need
to ensure that compliant packaging is used by obtaining the required documentation from its
suppliers. Suppliers must provide this information and documentation, as established in Article
16(1), and can therefore not refuse to provide the relevant documentation to the manufacturer.
5) What should happen to packaging held in stock or already produced prior to 12
August 2026, but not yet placed on the market by that date? Will operators be obliged
to destroy, remanufacture or re-label it? NEW!
Packaging that has not been placed on the market by 12 August 2026, but that has already been
produced and sits in stock, does not have to be destroyed, remanufactured or re-labelled. To meet
the requirements under Article 15(5) and 15(6), which establishes that packaging must bear a
unique identification as well as the manufacturer9s name and address, it is possible to provide the
required information by means of an accompanying document. This is also the case for reusable
packaging already placed on the market. However, for packaging that is manufactured after the 12
August 2026, an accompanying document must only be used when it is not possible to affix the
unique identification and the name and address directly on the packaging.
Packaging that has been placed on the market before 12 August 2026 can remain on the market,
even if it is non-compliant with PPWR.
6) If the supplier of already produced packaging no longer exists, or if a supplier is
unwilling to provide the necessary information, how can the manufacturer of the
packaging show compliance? NEW!
Where the necessary information for packaging that is manufactured before 12 August 2026 is
missing or insufficient, the manufacturer under the PPWR must make best efforts to provide the
necessary information, for example by requesting it from the former supplier or, in the case of a
business takeover/merger/acquisition, from the new resulting company, or by making own
assessments.
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