The PPWR follows a structure that looks familiar to anyone who has gone through CE marking: a manufacturer, a Declaration of Conformity, a technical file. That resemblance holds only up to a point. Regulation (EU) 2025/40 borrows the shape of CE marking and applies it to packaging, but four differences change what a manufacturer actually has to do, and four similarities mean the underlying discipline is not entirely new.
Main Difference #1: The Scope
CE marking regulates the product. The PPWR regulates the packaging that product ships in. The two frameworks operate independently under CE marking, and a company can stay fully compliant under one while still carrying gaps under the other.
The manufacturer role can differ between the two as well. The company that designs a product for CE marking purposes is not automatically the company that designs its packaging under the PPWR, particularly when packaging comes from a different supplier than the product itself.
Packaging carries no physical mark equivalent to the CE marking. Conformity under the PPWR lives in the documentation behind it, the Declaration of Conformity and the technical file, not in a symbol printed on the box.
Main Difference #2: The “Producer” Role
CE marking already assigns four roles that every manufacturer selling into the EU recognizes: manufacturer, importer, distributor, and authorised representative.
The PPWR adds a role none of those four frameworks needed.
The producer role tied to EPR obligations belongs to whoever places packaging on a national market for the first time, and that is not necessarily the company that manufactures it.
A manufacturer selling exclusively through EU distributors can carry zero producer obligations across every country it sells into, while the distributors carry all of them.
CE marking has nothing that plays this role. Once a manufacturer identifies who holds the four established roles, the framework does not add a fifth party defined by where a sale happens to land.
Main Difference #3: The Labeling
Labeling under CE marking settled years ago. Most frameworks ask for the CE mark itself and the manufacturer’s identification, occasionally a warning tied to a specific product category. The requirements rarely change once a product family is established.
Labeling under the PPWR is still being written. The harmonized format covering material composition and recycling symbols depends on an implementing act the European Commission has not published yet. Our PPWR compliance timelinealready covers a digital data carrier requirement and separate labeling rules for reusable packaging, neither of which has any equivalent under CE marking.
Main Difference #4: Recyclability Grading and Substance Restrictions
The PPWR introduces a recyclability grading system, classes A, B, and C, that determines whether packaging can stay on the market from 2030 onward. No CE marking framework grades a product’s recyclability as a condition for market access.
Substance restrictions are not unique to the PPWR. RoHSÂ already restricts specific substances in electronics under a genuine CE marking framework, so this particular difference narrows for that sector. But most of the substance restriction work across the EU sits with REACH, and REACH is not a CE marking regulation. It runs alongside CE marking as a separate compliance track today, the same way it will run alongside the PPWR.
Main Similarity #1: The Declaration
Both frameworks converge on the same instrument, a Declaration of Conformity:
Under CE marking, the declaration covers the product. Under the PPWR, it covers the packaging.
The legal structure works the same way in both cases: a manufacturer states, under its sole responsibility, that the object described meets the applicable requirements. Only the object changes.
Main Similarity #2: The Technical File
Both frameworks require a technical file that supports the declaration and stays available for inspection. Content requirements differ by regulation, and retention periods are not identical between the two, but the underlying obligation is the same discipline applied to a different object.
Main Similarity #3: The Optional AR
Both frameworks use the same wording for the authorised representative. The manufacturer MAY appoint one, and neither regulation states that doing so is mandatory. What happens in practice depends heavily on the sales channel.
Under CE marking, a manufacturer selling through an EU-based importer already has an economic operator established in the Union to answer to market surveillance authorities. Appointing an authorised representative stays genuinely optional in that scenario. The practical obligation only appears when a non-EU manufacturer sells directly into the EU, through its own web shop or without an EU importer in the chain. Without an importer filling that role, an AR becomes the only way to have a legal presence in the Union.
The PPWR’s Article 17 representative does not carry this same mechanism. It stays optional whether or not the producer sells directly. This makes the similarity closer for manufacturers who go through EU distributors, and considerably weaker for manufacturers who sell straight to EU consumers.
Main Similarity #4: Self-Assessment as the Default Route
Most manufacturers never deal with a notified body under either framework. Internal production control, Module A or its equivalent, covers the large majority of products under CE marking and the large majority of packaging under the PPWR. A notified body enters the picture only for the narrower set of categories specific legislation calls out for external review.
A manufacturer already comfortable running self-assessment for CE marking purposes is running the same kind of exercise under the PPWR, applied to a different object against different criteria.
The similarities explain why the PPWR feels approachable to a manufacturer who already runs CE marking. The differences explain why treating it as a small extension of that existing system leaves gaps: EPR registration, labeling requirements still taking shape, and a recyclability grading system with no CE marking precedent all demand attention on their own terms.
We offer a PPWR onboarding service built around this gap. Instead of running your compliance for you indefinitely, we transfer the knowledge and the tools your team needs to manage PPWR compliance on your own, through an hours package sized to your needs. Request a quote and tell us what you need covered.
