Glossary

PPWR & Packaging Glossary

The key terms surrounding the EU Packaging Regulation, labeling, and recycling — clearly and comprehensively explained.

Article 21: The PPWR's "Article 21 trap": if your name or your brand appears on the packaging, or if you modify the packaging before placing it on the market, you are legally deemed to be the producer — regardless of who physically manufactured it. You must then issue the declaration of conformity yourself.
Authorised representative— authorised representative: A person or body established in the EU that an economic operator without an EU establishment mandates in writing to fulfil certain PPWR obligations on its behalf. Required for third-country sellers in the Member State of import.
Certificate of Analysis— CoA: A test report from an accredited laboratory that states the measured substance concentrations per material. It is the mandatory proof of compliance with the substance limit values — a supplier's self-declaration does not replace it.
Chain of Custody: An unbroken chain of evidence that demonstrates where a material originates from and that the stated post-consumer recycled content is actually present. Issued by the recycler, documented by the producer.
Collection fraction: The bin or collection stream a packaging belongs in (e.g. paper bin, yellow bag, waste glass, deposit return). The PPWR requires sorting instructions that are comprehensible for end consumers.
Conformity assessment: The procedure by which a producer verifies and demonstrates that a packaging type meets all PPWR requirements (substance limit values, recyclability, minimisation). The result feeds into the technical documentation and the declaration of conformity.
Declaration of Conformity— DoC: Declaration of Conformity: the signed document per packaging type that legally binds the declaration of conformity. It contains nine mandatory elements pursuant to Annex VIII. The producer issues it; the importer keeps a copy.
Design for Recycling— DfR: The methodology used to assess the recyclability of a packaging (sortability, separability, material recovery). From 2030, the PPWR links minimum grades and, in part, the fees to the result (Art. 6).
Digital Product Passport— DPP: Product information that is digital and retrievable via a data carrier (e.g. a QR code). For packaging, mandatory information is increasingly provided digitally rather than printed — which is precisely what a dynamic QR code is suited for.
Distributor— distributor: PPWR role (Art. 3(16)): anyone who makes packaging available on the EU market without being a producer or importer (wholesale/retail). No obligation to draw up documentation, but a duty to verify: not to pass on non-conforming packaging.
EPR— Extended Producer Responsibility: The fundamental principle whereby manufacturers are responsible for the entire lifecycle of their packaging — including collection, sorting and recovery. It is financed through system participation fees.
GS1 Digital Link: A standardised URL format from GS1 that packs a GTIN (article number) and further data fields such as batch or serial number into a single QR code. It enables the same code to be used for checkout, logistics and consumer information (Sunrise 2027).
GTIN— Global Trade Item Number: The globally unique article number (formerly EAN). It forms the core of a GS1 Digital Link and identifies the product at the point of sale.
Importer: PPWR role (Art. 3(14)): anyone who brings packaging from a third country onto the EU market. They do not draw up the documentation themselves, but must obtain, verify and retain the producer's declaration of conformity and technical documentation for 5–10 years.
LUCID: The public packaging register of the Central Agency Packaging Register Foundation. Every first-time distributor of packaging must register there free of charge before placing it on the market.
Manufacturer: PPWR role (Art. 3(15)): anyone who places a packaged product on the national market of a Member State for the first time. It triggers extended producer responsibility (EPR) — registration, volume reporting and financial contributions in each affected Member State.
Mass balance— mass balance: An accounting procedure that allocates the proportion of recyclate across the entire production chain and makes it auditable. Together with chain-of-custody certificates, it is the common proof of recycled content.
Material code: Harmonised coding scheme for material labelling (e.g. PAP 20 for corrugated board, GL 70 for clear glass, PP 5 for polypropylene, ALU 41 for aluminium). The current basis is Decision 97/129/EC, which remains in force until the new implementing act applies.
Mono-material: Packaging made from a single, sorted-pure material. It is considered highly recyclable because it can be recovered without separating different materials — a central design objective of the PPWR.
Packaging types: The PPWR distinguishes, among others, sales, grouped and transport packaging as well as e-commerce packaging. Obligations and labelling may differ depending on the type.
Party placing on the market: Anyone who makes packaging or packaged goods available on the EU market for the first time — manufacturers, importers and online retailers. The PPWR obligations primarily affect the party first placing the product on the market.
PFAS— per- and polyfluoroalkyl substances: Persistent "forever chemicals". In food-contact packaging, limit values of 25 ppb per individual substance and 250 ppb in total apply. A blanket "PFAS-free" statement is not sufficient — a specific test report is required.
Placing on the market: The first making available of a packaging on the Union market. From the time of placing on the market on 12 August 2026, the PPWR mandatory information must be fulfilled.
Post-consumer recyclate— PCR: Secondary raw material from packaging that has already been used and disposed of (consumer waste) — as distinct from production waste. Only post-consumer content counts towards the PPWR recycled-content quotas.
PPWR— Packaging and Packaging Waste Regulation: The EU Packaging Regulation (EU) 2025/40. It replaces the previous Packaging Directive, applies directly in all Member States and is in effect since 12 August 2026. Among other things, it governs the labelling, recyclability and recycled content of packaging.
Producer: PPWR role (Art. 3(13)): anyone who manufactures a packaging, or has it manufactured under their own name or brand. The producer bears the main burden: conformity assessment, technical documentation and declaration of conformity (DoC). Not to be confused with the "manufacturer".
Recyclability: A measure of how well a packaging can be recovered in the real-world collection and sorting system. The PPWR links obligations and, in part, the system participation fees to recyclability (Design for Recycling).
Recycled content: The proportion of recycled secondary raw material in a packaging. For plastic packaging, the PPWR requires the declaration of the recycled content present and progressively mandates minimum quotas.
Substance limit values: Maximum values for substances of concern in packaging. The sum of lead, cadmium, mercury and hexavalent chromium must not exceed 100 mg/kg (Art. 5, Annex I). Proof is provided by an analysis certificate from an accredited laboratory.
System participation: The fee-based participation in a dual system through which manufacturers finance the collection and recovery of their sales packaging. It is a prerequisite for placing products on the market in Germany.
Technical documentation: A structured file per packaging type (Annex VII PPWR) that substantiates every statement in the declaration of conformity — with a description, design drawings, material composition, test reports and assessment results. Retention of 5 years (single-use) or 10 years (reusable), to be submitted to authorities within 10 days.
VerpackG— German Packaging Act: The German Packaging Act. It governs system participation (licensing) and LUCID registration. It remains in force alongside the PPWR — the PPWR supplements it across the EU with labelling and design obligations.
ZSVR— Central Agency Packaging Register: The foundation that operates the LUCID register and monitors compliance with registration and licensing obligations in Germany.

Stand: 17.08.2026 · geprüft von Erik Eggerth

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