Can I pass on the PPWR obligation to my packaging supplier?

No – responsibility under Regulation (EU) 2025/40 lies with the person placing the product on the market, i.e. the company that first makes the packaged goods available on the EU market. This is generally you as the manufacturer or importer, not your packaging supplier.

A contractual transfer of compliance obligations is not legally possible. Authorities and market surveillance bodies always address the person placing the product on the market – regardless of what has been agreed within your supply chain.

What your packaging supplier must provide:

Although the obligation lies with you, you depend on reliable data from your supplier:

- Material composition (plastic type, heavy metal content, component weights) - Recycled content documentation in accordance with the minimum proportions under Article 7 of the Regulation - Declaration of conformity from the packaging manufacturer confirming that the packaging meets the design requirements (Chapter III) - Technical documentation for the digital product labelling (GS1 Digital Link, QR code)

Without these documents, you cannot issue your own declaration of conformity – and that is precisely what you will need by 12 August 2026 at the latest.

Practical approach: Request a written, product-specific declaration of conformity pursuant to EU 2025/40 as well as the underlying test reports from each packaging supplier. Update your procurement terms and conditions accordingly.

For a binding legal assessment of your specific supply chain situation, please contact your local Chamber of Commerce (IHK) or a qualified legal adviser.