Who is affected by the PPWR?
The EU Packaging Regulation (PPWR, Regulation (EU) 2025/40) enters into force on 12 August 2026 and applies to all businesses that place packaging on the EU market — regardless of size or sector. The decisive factor is not who manufactures the packaging, but who makes it available on the EU market for the first time. If you sell products in packaging or import packaged goods, you are most likely affected.
Who qualifies as a responsible party under the PPWR?
The PPWR applies to so-called economic operators — all natural or legal persons who place packaging or packaged products on the EU market. The Regulation distinguishes four core groups:
1. Manufacturers
Companies that produce packaging or packaged goods themselves and distribute them under their own name in the EU bear full responsibility. This also applies to contract manufacturers where the client specifies the packaging. The determining factor is whose brand or name appears on the packaging.2. Private-Label Retailers
Anyone who sells products under their own brand — i.e. as a so-called private-label retailer — is treated legally as a manufacturer. This applies equally to supermarkets, online retailers and B2B distributors that carry own-brand products. The fact that a third party physically produces the goods does not alter the obligations.3. Direct Importers
Companies that import packaged goods directly from third countries (e.g. China, USA, Turkey) into the EU become manufacturers within the meaning of the PPWR — provided that no EU-established intermediary is interposed who assumes the obligations. If you purchase from an importer established in your EU member state who has already placed the goods on the market, responsibility lies with that importer, not with you.4. Authorised Representatives
Manufacturers established outside the EU may designate an Authorised Representative with an EU registered office to assume the obligations. Without such a representative, liability falls on the party who first places the goods on the EU market.---
Special cases in B2B trade
The same fundamental principles apply in purely B2B contexts, but with one important nuance: if, as a distributor, you sell exclusively to commercial buyers and the packaging has already been lawfully placed on the market in a compliant manner by your supplier (established in the EU), many obligations transfer to the upstream actor. Nevertheless, you remain jointly responsible for take-back obligations and the correct labelling of the packaging.
Micro-enterprises and exemptions
The PPWR provides no general exemption for micro-enterprises (fewer than 10 employees and annual turnover below EUR 2 million). However, some national implementing legislation may provide for simplified reporting obligations. For the exemptions under Art. 2 PPWR — such as certain packaging for medicinal products, medical devices or live animals — a case-by-case assessment is recommended.
Important: The labelling requirement (QR code, material identification) applies from 12 August 2026 to all affected packaging newly placed on the market. Stock already in circulation benefits from a transitional period.
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This article provides a general overview and does not substitute legal advice. For a binding assessment of your specific situation, please contact your local Chamber of Commerce and Industry or a lawyer specialising in packaging law.
Häufige Fragen
- As an online retailer selling pre-packaged branded goods, am I affected?
- No — if you resell original packaging from a manufacturer with an EU registered office without modification, manufacturer responsibility lies with the brand manufacturer. However, as soon as you repackage the goods yourself or offer them under your own brand, you become the responsible party.
- I import directly from China without an EU intermediary — do I qualify as a manufacturer?
- Yes. As the first importer into the EU, you assume all obligations of a manufacturer under the PPWR. You are personally responsible for labelling, recyclability and registration obligations, unless an EU-established Authorised Representative formally assumes those obligations on your behalf.
- From when do the obligations apply, and what happens to existing stock?
- The reference date is 12 August 2026. Packaging lawfully placed on the market before that date benefits from transitional periods — specifically, such stock may continue to be sold until 12 August 2028, provided it meets the national requirements applicable up to that point.
- Does the PPWR also apply to small family businesses with fewer than 10 employees?
- The PPWR contains no general SME exemption. Micro-enterprises are in principle affected, but may benefit from simplified registration and reporting procedures insofar as national law provides for corresponding relief. Consulting your relevant industry association or Chamber of Commerce is advisable.
- What if my product is sold to both consumers and business customers?
- The decisive factor is not the recipient, but the placing of the packaging on the market. As soon as your packaging could potentially reach the end consumer — i.e. is available through retail channels — all PPWR requirements for consumer packaging apply. Purely industrial and transport packaging is subject to a partly different set of requirements.
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