PPWR is Regulation (EU) 2025/40, the EU’s Packaging and Packaging Waste Regulation. The European Parliament and the Council adopted it on 19 December 2024, it was published in the Official Journal on 22 January 2025, entered into force on 11 February 2025, and applies in general from 12 August 2026. It replaces the Packaging and Packaging Waste Directive 94/62/EC, and as an EU regulation it applies directly in all Member States. Sources: the European Commission’s PPWR overview and its PPWR FAQ, second edition, August 2026.
What Counts as Packaging Under PPWR
The Regulation defines packaging as an item, whatever it is made of, that an economic operator uses to contain, protect, handle, deliver or present products, to another business or to an end user. It covers packaging whether empty or filled, whether made in the EU or imported. Items that form an integral part of a product and are disposed of together with it are excluded. Annex I gives an indicative list of examples, and the Commission stresses that it is not exhaustive.
For merchandise, that means gift boxes, polybags, shipping cartons and e-commerce mailers are packaging. Whether a display case or a hanger counts depends on its function, and a hanger sold together with a garment is a commonly cited example. Check the definition and Annex I for each item rather than assuming.
Who Is the “Manufacturer” of Packaging
This question decides who carries the obligations. According to the Commission FAQ, if the packaging bears a name or trademark, the manufacturer is the company under whose name or trademark it is placed on the market, even if another company makes or fills it. For custom packaging without a name, the company that places the order and sets the design specifications is the manufacturer. For licensed products, the FAQ says a licensor who specifies the packaging design is the manufacturer, while a licensor whose trademark merely appears on the packaging is not, and the contractual arrangement decides each case.
What Has Applied Since 12 August 2026
Several obligations apply from the general application date to all packaging placed on the EU market:
- The manufacturer must carry out a conformity assessment, draw up an EU declaration of conformity and compile technical documentation (Articles 38 and 39, Annexes VII and VIII). The technical documentation must be kept for five years for single-use packaging. Our guide to the PPWR declaration of conformity shows what it must contain, point by point.
- Packaging must carry a type, batch or serial identifier and the manufacturer’s name or trademark, postal address and, where available, electronic contact details, on the packaging or in an accompanying document (Article 15, paragraphs 5 and 6).
- The manufacturer must minimise substances of concern (Article 5, paragraph 1), and the sum of lead, cadmium, mercury and hexavalent chromium may not exceed 100 mg/kg (Article 5, paragraph 4). The PFAS limits in Article 5, paragraph 5, apply to food-contact packaging only.
- Importers must check that the non-EU manufacturer completed the assessment and declaration before placing packaging on the market (Article 18).
The Commission states that enforcement of these obligations should not disrupt trade. An authority that finds non-compliance must first ask the operator to end it, and only if it persists can it prohibit, recall or withdraw the packaging.
What Comes Later
Many design requirements apply from 1 January 2030 or after Commission acts: binding recyclability performance criteria, packaging minimisation, and the maximum empty space of 50% for grouped, transport and e-commerce packaging. Certain single-use formats are banned from 1 January 2030. Producers must also register with the producer register of each Member State where they first make packaging available (Article 44), with fewer reporting duties below 10 tonnes a year. In Germany that register is LUCID, run under the VerpackDG.
Frequently Asked Questions
Does PPWR apply to merchandise packaging?
Yes. Any packaging placed on the EU market is in scope, including the gift boxes, polybags and cartons used for merchandise. The obligations fall on the packaging’s manufacturer as the Regulation defines that role, not automatically on the factory.
Is there an exemption for small businesses?
The Commission FAQ sets out specific rules for microenterprises, for example that the supplier counts as the manufacturer when the brand owner is a microenterprise in the same Member State, but it does not describe a general exemption from the conformity obligations. For producer registration it states there is no general micro-enterprise exemption, although reporting duties are lighter for producers below 10 tonnes a year.
Where can I read the rules?
Start with the Commission’s PPWR overview and FAQ. For a binding answer on your own packaging, ask your national authority or a lawyer. For how PPWR applies to merchandise, read PPWR for Merchandise: Who Is the Packaging Manufacturer?.
<nav class="article-breadcrumb"><a href="https://www.amball.com/magazine">Magazine</a><span class="article-breadcrumb__sep">/</span><a href="https://www.amball.com/glossary">Glossary</a><span class="article-breadcrumb__sep">/</span><span class="article-breadcrumb__current">PPWR (EU Packaging and Packaging Waste Regulation)</span></nav> <h1 class="article-h1">PPWR (EU Packaging and Packaging Waste Regulation)</h1> <p class="article-byline"><span class="cluster-badge">Licensing, Manufacturing & Compliance</span> · Updated October 14, 2026</p> <div class="article-intro"><p>PPWR (Regulation (EU) 2025/40) is the EU's Packaging and Packaging Waste Regulation. It applies from 12 August 2026 to all packaging placed on the EU market, including the gift boxes, polybags and cartons used for merchandise.</p></div> <ul><li>PPWR (Regulation (EU) 2025/40) has applied in general since 12 August 2026 and replaces Directive 94/62/EC.</li><li>The manufacturer of the packaging, defined by name or trademark and design control, must run a conformity assessment, draw up a declaration of conformity and keep technical documentation.</li><li>Recyclability, minimisation and empty-space rules follow from 1 January 2030, and the Commission says enforcement should not disrupt trade.</li></ul><p>PPWR is Regulation (EU) 2025/40, the EU’s Packaging and Packaging Waste Regulation. The European Parliament and the Council adopted it on 19 December 2024, it was published in the Official Journal on 22 January 2025, entered into force on 11 February 2025, and applies in general from 12 August 2026. It replaces the Packaging and Packaging Waste Directive 94/62/EC, and as an EU regulation it applies directly in all Member States. Sources: the European Commission’s <a href="https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste_en">PPWR overview</a> and its <a href="https://op.europa.eu/en/publication-detail/-/publication/ad14cb8f-8d4f-11f1-9262-01aa75ed71a1/language-en">PPWR FAQ, second edition, August 2026</a>.</p><h2>What Counts as Packaging Under PPWR</h2><p>The Regulation defines packaging as an item, whatever it is made of, that an economic operator uses to contain, protect, handle, deliver or present products, to another business or to an end user. It covers packaging whether empty or filled, whether made in the EU or imported. Items that form an integral part of a product and are disposed of together with it are excluded. Annex I gives an indicative list of examples, and the Commission stresses that it is not exhaustive.</p><p>For merchandise, that means gift boxes, polybags, shipping cartons and e-commerce mailers are packaging. Whether a display case or a hanger counts depends on its function, and a hanger sold together with a garment is a commonly cited example. Check the definition and Annex I for each item rather than assuming.</p><h2>Who Is the “Manufacturer” of Packaging</h2><p>This question decides who carries the obligations. According to the Commission FAQ, if the packaging bears a name or trademark, the manufacturer is the company under whose name or trademark it is placed on the market, even if another company makes or fills it. For custom packaging without a name, the company that places the order and sets the design specifications is the manufacturer. For licensed products, the FAQ says a licensor who specifies the packaging design is the manufacturer, while a licensor whose trademark merely appears on the packaging is not, and the contractual arrangement decides each case.</p><h2>What Has Applied Since 12 August 2026</h2><p>Several obligations apply from the general application date to all packaging placed on the EU market:</p><ul><li>The manufacturer must carry out a conformity assessment, draw up an EU declaration of conformity and compile technical documentation (Articles 38 and 39, Annexes VII and VIII). The technical documentation must be kept for five years for single-use packaging. Our guide to the <a href="https://www.amball.com/magazine/ppwr-declaration-of-conformity-merchandise-packaging">PPWR declaration of conformity</a> shows what it must contain, point by point.</li><li>Packaging must carry a type, batch or serial identifier and the manufacturer’s name or trademark, postal address and, where available, electronic contact details, on the packaging or in an accompanying document (Article 15, paragraphs 5 and 6).</li><li>The manufacturer must minimise substances of concern (Article 5, paragraph 1), and the sum of lead, cadmium, mercury and hexavalent chromium may not exceed 100 mg/kg (Article 5, paragraph 4). The PFAS limits in Article 5, paragraph 5, apply to food-contact packaging only.</li><li>Importers must check that the non-EU manufacturer completed the assessment and declaration before placing packaging on the market (Article 18).</li></ul><p>The Commission states that enforcement of these obligations should not disrupt trade. An authority that finds non-compliance must first ask the operator to end it, and only if it persists can it prohibit, recall or withdraw the packaging.</p><h2>What Comes Later</h2><p>Many design requirements apply from 1 January 2030 or after Commission acts: binding recyclability performance criteria, packaging minimisation, and the maximum empty space of 50% for grouped, transport and e-commerce packaging. Certain single-use formats are banned from 1 January 2030. Producers must also register with the producer register of each Member State where they first make packaging available (Article 44), with fewer reporting duties below 10 tonnes a year. In Germany that register is LUCID, run under the <a href="https://www.amball.com/glossary/verpackdg">VerpackDG</a>.</p><h2 id="frequently-asked-questions">Frequently Asked Questions</h2><h3>Does PPWR apply to merchandise packaging?</h3><p>Yes. Any packaging placed on the EU market is in scope, including the gift boxes, polybags and cartons used for merchandise. The obligations fall on the packaging’s manufacturer as the Regulation defines that role, not automatically on the factory.</p><h3>Is there an exemption for small businesses?</h3><p>The Commission FAQ sets out specific rules for microenterprises, for example that the supplier counts as the manufacturer when the brand owner is a microenterprise in the same Member State, but it does not describe a general exemption from the conformity obligations. For producer registration it states there is no general micro-enterprise exemption, although reporting duties are lighter for producers below 10 tonnes a year.</p><h3>Where can I read the rules?</h3><p>Start with the Commission’s <a href="https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste_en">PPWR overview</a> and <a href="https://op.europa.eu/en/publication-detail/-/publication/ad14cb8f-8d4f-11f1-9262-01aa75ed71a1/language-en">FAQ</a>. For a binding answer on your own packaging, ask your national authority or a lawyer. For how PPWR applies to merchandise, read <a href="https://www.amball.com/magazine/ppwr-merchandise-packaging-manufacturer">PPWR for Merchandise: Who Is the Packaging Manufacturer?</a>.</p><hr class="faq-end"> <section class="related-section"><h2>Related Glossary Terms</h2><div class="related-grid"><a href="https://www.amball.com/glossary/reach" class="related-card"><p class="related-label">Licensing, Manufacturing & Compliance</p><p class="related-title">REACH (EU Chemicals Regulation)</p><p class="related-snippet">REACH is the EU's core chemicals regulation, controlling which substances can be used in a product sold into the EU and how their presence has to be disclosed. For merchandise, the parts that matter most are the Substances of Very High Concern (SVHC) disclosure duty and specific Annex XVII restrictions like the nickel release limit on metal goods.</p></a></div></section> <section class="from-blog-section"><h2>From the Magazine</h2><a class="from-blog-link" href="https://amball.com/magazine/eco-friendly-merchandising-a-2026-guide-for-buyers">Eco-Friendly Merchandising: A 2026 Guide for Buyers</a><a class="from-blog-link" href="https://amball.com/magazine/custom-merchandise-cost-and-minimum-order-quantity">Custom Merchandise Costs and Minimum Orders: What Drives the Price</a></section>
