The manufacturer is responsible for preparing a Technical Documentation file and signing a Declaration of Conformity for each packaging type before it is placed on the EU market. A company using five different packaging formats needs five separate DoCs. Each must be retained for five years in the case of single-use packaging and ten years for reusable packaging. A unique identifier, such as a batch number, barcode or QR code, must also be assigned to each packaging unit from August 12, 2026.

The PPWR introduces a clear distinction between the manufacturer, who designs and produces the packaging and prepares the documentation, and the producer, who first places packaging or packaged products on a specific national market. A US-based manufacturer who sells through European distributors is typically not the producer: the distributor who first makes the product available in a given country is. That distributor bears the EPR registration obligations in that country, not the manufacturer. The answer changes country by country and depends on who actually introduces the packaging into each national market.

Extended Producer Responsibility obligations apply from August 12, 2026.

Producers must register in each EU member state where they first place packaging or packaged products on the market, and they must finance or organize the collection and recycling of packaging waste. Registration is not a one-time EU-wide process: it is a country-by-country obligation, and the requirements, fields, and procedures vary significantly between member states. Producer Responsibility Organizations can fulfil these obligations on behalf of producers, but registration remains the direct responsibility of the producer.

From August 12, 2026, packaging placed on the EU market must comply with substance restrictions covering PFAS in food-contact materials and heavy metal concentration limits.

From 2030, all packaging must achieve a minimum recyclability grade of C under the Annex II classification system, with grades A and B becoming the only permitted options from 2038. These requirements affect material selection, supplier qualification, and packaging design decisions that need to be made well before each deadline arrives. The empty space in grouped, transport and e-commerce packaging is also limited to avoid unnecessary volume.

The PPWR introduces a phased series of digital and physical marking obligations. Harmonised recycling and material composition labels become mandatory from August 2028. From the same date, certain packaging categories will require a Digital Product Passport accessible via a QR code or GS1 Digital Link.

Labels applied to products, including sticky labels on garments or footwear, are considered packaging under the PPWR and subject to the same requirements. Manufacturers who are already building DPP infrastructure for their products under the ESPR will find that the data requirements overlap significantly, making a single integrated data management approach more efficient than two parallel processes.