The PPWR does not regulate the products themselves, but rather the packaging in which products are provided, transported, or sold. It generally applies to all packaging placed on the market in the European Union—regardless of whether,

• what material they’re made of,
• whether they are empty or full,
• whether they were manufactured inside or outside the EU,
• whether they are used in the B2C or B2B sectors.

This therefore includes, among other things, retail packaging, outer packaging, transport packaging, service packaging, and packaging for online retail.

Whether a specific item actually qualifies as packaging must be determined based on the definitions and examples provided in the PPWR. Items that are an integral part of a product, are required throughout the product’s entire lifespan, and are disposed of together with the product may fall outside the definition of Packaging.

Case-by-case assessment: A distinction may be necessary, particularly for reusable containers, product components, toolboxes, transport aids, and special containers.

Legal basis and sources: PPWR Articles 2 and 3, as well as Annex I; EU FAQ on the comprehensive scope of application. (EUR-Lex)

The PPWR distinguishes between several roles. What matters is not how a company describes itself, but rather what function it performs within the specific supply chain.

Producer

The manufacturer is responsible for the conformity of the packaging. In particular, the manufacturer must ensure that the applicable requirements are met, that the technical documentation is available, and that an EU Declaration of Conformity is issued.

Supplier

A supplier provides packaging, packaging materials, or information. The supplier must provide the manufacturer with the documentation and data the manufacturer needs to demonstrate compliance.

Importer

An importer, as defined by the PPWR, is a company established in the EU that first makes packaging or packaged products from a third country available on the EU market. The importer must verify that the producer has fulfilled its compliance obligations.

Distributor

A distributor supplies packaging or packaged products within the supply chain without being a manufacturer or importer. The distributor has a duty of due diligence and verification.

Manufacturers within the meaning of extended producer responsibility

The term “manufacturer” is also used in the PPWR in the context of extended producer responsibility—specifically, registration, reporting of quantities, and financing of collection and recycling. The producer and the EPR manufacturer may be the same company, but they do not have to be.

Case-by-Case Assessment: An importer or distributor may be considered a manufacturer if they place packaging on the market under their own name or brand, or modify it in a way that could affect its conformity.

Legal basis and sources: PPWR Art. 3 and Arts. 15–21; European Commission Guidelines on the Allocation of Roles. (EUR-Lex)

In the case of private label or contract bottling, the technical manufacturer or bottler is not automatically responsible for compliance.

In the case of sales packaging and outer packaging, the relevant party is generally the entity that manufactures the packaged product or has it manufactured. In the case of contract filling or contract manufacturing, the client is generally considered the manufacturer if the product or packaging is provided under the client’s name or brand.

Typical examples:

• A retail company has a product packaged under its own brand: As a rule, the retail company is the manufacturer.
• A brand owner contracts a contract manufacturer to handle production and packaging: As a rule, the brand owner—or the client—remains responsible.
• A bottler markets a product under its own name: The bottler may be the producer itself.

The following factors are particularly important:

• Name and brand on the product or packaging,
• Client commissioning the production,
• Impact on packaging design and specifications,
• Specific contract and supply chain.

Case-by-Case Review: The PPWR contains a special provision for micro-enterprises. In addition, complex situations involving multiple brands, importers, or distribution channels may require a separate review of roles.

Legal Basis and Sources: PPWR Art. 3, para. 1; European Commission Guidelines on the Definition of the Producer; BMLUK Fact Sheet on Contract Bottling and Private Label Products. (Environment)

The PPWR applies directly in all 27 member states of the European Union. Companies must therefore generally comply with the product-related requirements of the PPWR for all packaging placed on the EU market.

This is to be distinguished from national obligations arising from extended producer responsibility. Registration, volume reporting, system participation, and licensing must still be fulfilled in the Member State where the packaging is first made available or is expected to become waste.

A company with sales in several Member States may therefore, at the same time:

• play a role with EU-wide responsibility for packaging compliance and
• must comply with national EPR and registration requirements in several countries.

For countries outside the EU, including EEA member states, the United Kingdom, and Switzerland, the applicable regulations must be determined on a case-by-case basis.

Legal Basis and Sources: PPWR Art. 2, Art. 44, and Art. 45; EU Guidelines on the Delimitation of Product Conformity and EPR Responsibilities. (EUR-Lex)

There are two different types of authorization.

Authorized Representative for Product Law Matters

A producer may delegate certain administrative tasks in writing to an authorized representative, such as maintaining and submitting documents to government agencies. However, the ultimate responsibility for packaging compliance remains with the producer.

Authorized Representative for Extended Producer Responsibility

Under the current text of the PPWR, a company that supplies packaging directly to end users in another Member State where it is not established must, as a general rule, appoint an EPR representative.

Status: Under legal review. The European Commission has proposed suspending this mandatory authorization requirement for companies based within the EU until 2035. However, this legislative process will not be completed by July 16, 2026. The current PPWR should therefore not be presented as if the suspension had already been decided. (Environment)

A separate review is required for companies from third countries and for special national regulations.

Legal basis and sources: PPWR Art. 17 and Art. 45(3); ongoing EU procedure 2025/0395 (COD). (EUR-Lex)

There is no general exemption that would exempt an entire industry or all of a company’s packaging from the PPWR. Exemptions generally apply only to specific requirements.

Examples include special provisions for:

• certain types of packaging for drugs and medical devices,
• certain foods for infants and for medical purposes,
• Packaging for hazardous materials,
• certain types of packaging that are sensitive to contact,
• individual packaging formats made of lightweight wood, cork, textiles, ceramics, or wax,
• innovative packaging during a limited transition period,
• specific requirements regarding the proportion of recycled materials or reuse.

For example, packaging may be exempt from a recycled content requirement but may still be subject to material restrictions, documentation requirements, or other regulations.

Case-by-Case Review: Each exception must be assigned to the specific packaging and the relevant section of the PPWR and documented.

Legal basis and sources: in particular, Articles 5 through 12, Article 25, and Article 29 of the PPWR; EU guidelines on the application of specific requirements. (EUR-Lex)

Not all of the PPWR’s requirements take effect at the same time. Many provisions regarding recyclability, recycled content, labeling, packaging reduction, and reuse rates will not take effect until later.

Effective August 12, 2026, the following are particularly relevant in Austria:

• the new definitions of roles and terms,
• the general obligations of producers, importers, and distributors,
• the conformity assessment procedure,
• the technical documentation,
• the EU Declaration of Conformity,
• the substance restrictions under Article 5,
• the PFAS limits for food contact packaging,
• the limits already in effect for lead, cadmium, mercury, and hexavalent chromium,
• Requirements for new reusable and refillable systems.

The declaration of conformity need only cover those PPWR requirements that actually apply to the packaging in question at that time. Requirements for which the criteria and evaluation methods will not take effect until a later date do not need to be demonstrated prematurely using methods that do not yet exist.

Legal basis and sources: BMLUK fact sheet, overview of the provisions effective as of August 2026; PPWR Art. 5, Art. 15 through 22, and Art. 38 and 39; EU guidelines on phased implementation. (BMKRW)

Companies should organize their preparations in clear steps:

1. Clarify roles: For each relevant supply and distribution scenario, determine who is the producer, importer, distributor, and EPR manufacturer.
2. Document the packaging portfolio: Systematically document all sales, repackaging, shipping, service, and e-commerce packaging.
3. Determine which requirements apply: Check which requirements will take effect as early as August 2026.
4. Obtain supplier data: Request information on materials, components, and substances, as well as any available test reports.
5. Assess risks: Test food-contact packaging specifically for PFAS and all packaging for relevant heavy metals.
6. Creating Technical Documentation: Storing Documentation in a Traceable and Version-Controlled Manner.
7. Conduct a conformity assessment: Evaluate the applicable requirements for each package or appropriately defined package family.
8. Preparing an EU Declaration of Conformity: The responsible manufacturer must issue it before the product is placed on the market.

Interzero can assist companies with role clarification, data structure, packaging assessment, technical documentation, and the preparation of the declaration of conformity. Interzero’s existing communications identify these very steps as key preparations for August 12, 2026. (Interzero)

The production date alone is not the decisive factor. What matters, in principle, is whether the packaging or the packaged product was legally placed on the market before August 12, 2026.

Placed on the market before the deadline

Packaging or packaged products that were properly placed on the market before August 12, 2026, generally do not need to be recalled or reevaluated solely because of the effective date.

Only manufactured or stored internally

If packaging has been manufactured but not yet placed on the market, it must comply with the requirements in effect at the time it is first made available after the effective date.

This is particularly relevant for food-contact packaging: For existing stock that has not yet been placed on the market, there is no general transition period with regard to the new PFAS limits.

The date of placement on the market may vary depending on the type of packaging:

• in the case of sales and outer packaging, often in connection with the product it contains,
• for certain types of service and shipping packaging, as early as when the empty packaging is delivered,
• For imports, this may already apply upon release for free circulation.

Case-by-case assessment: Inventory should be evaluated separately based on packaging type, production date, filling date, import date, and the date of initial provision.

Legal basis and sources: PPWR Art. 3 on placing on the market; EU guidelines; BMLUK fact sheet on inventory and food contact packaging. (Environment)

Typical examples:

• A retail company has a product packaged under its own brand: As a rule, the retail company is the manufacturer.
• A brand owner contracts a contract manufacturer to handle production and packaging: As a rule, the brand owner—or the client—remains responsible.
• A bottler markets a product under its own name: The bottler may be the producer itself.

The following factors are particularly important:

• Name and brand on the product or packaging,
• Client commissioning the production,
• Impact on packaging design and specifications,
• Specific contract and supply chain.

Case-by-Case Review: The PPWR contains a special provision for micro-enterprises. In addition, complex situations involving multiple brands, importers, or distribution channels may require a separate review of roles.

Legal Basis and Sources: PPWR Art. 3, para. 1; European Commission Guidelines on the Definition of the Producer; BMLUK Fact Sheet on Contract Bottling and Private Label Products. (Environment)

The PPWR does not replace the Austrian packaging licensing system with a centralized EU license.

According to the BMLUK’s current assessment, Austria’s existing obligations remain in effect for the time being. This applies in particular to:

• the determination of the primary liable party,
• participation in a collection and recycling system,
• the existing quantity reports,
• the self-certification reports submitted to date.

The necessary changes are to be implemented through amendments to the AWG and the Packaging Ordinance. According to the BMLUK, adjustments to Austria’s data collection system are expected no earlier than the 2028 calendar year.

Companies should therefore:

• continue to comply with their existing licensing and reporting requirements,
• prepare their packaging data in parallel for the more detailed PPWR classification system,
• monitor future national changes.

Status: National implementation is still pending. Details regarding future tariff categories, register formats, and data requirements have not yet been fully determined.

Legal Basis and Sources: BMLUK Fact Sheet on Mandatory Participation, Reporting Requirements, and the Transition Period; PPWR Articles 44 and 45. (BMKRW)

The specific data required depends on the packaging and the applicable requirements. To ensure robust documentation, companies should record at least the following information in a structured manner:

• clear packaging or product description,
• Packaging type and packaging level,
• Purpose,
• all integrated and separate components,
• Materials and material proportions,
• Weights of the packaging and its components,
• Composite and layered structures,
• Closures, labels, sleeves, inserts, and separators,
• Printing inks, varnishes, adhesives, coatings, and barriers,
• Suppliers and production sites,
• existing substance and material declarations,
• Information on PFAS and heavy metals,
• Recycled content, where applicable,
• Information on reusability and cycles, where applicable,
• existing test reports and recyclability assessments,
• Version and Revision Status.

Not all information will be required for every type of packaging or to the same extent as early as August 2026. However, the data structure should be designed in such a way that any PPWR requirements added later can be incorporated.

Legal basis and sources: PPWR Annex VII on technical documentation; practical preparatory steps on the Interzero website. (EUR-Lex)

Typical internal data sources include:

• Product and packaging master data,
• ERP systems,
• Bill of Materials,
• Packaging specifications,
• technical drawings,
• Purchasing and quality management documents,
• existing test reports,
• Certificates and supplier declarations.

Any missing data should be requested in a structured manner from packaging suppliers, material suppliers, contract manufacturers, and fillers. Under the PPWR, suppliers are required to provide the information and documentation that the producer needs to demonstrate packaging compliance.

A general supplier confirmation is not always sufficient. The manufacturer must assess whether the information is plausible, up-to-date, and reliable for the specific packaging.

If data is incomplete or there are specific concerns, additional tests or laboratory analyses may be necessary.

Status: Some test methods are still pending. There is currently no fully harmonized EU testing method for PFAS in food contact packaging. The European Commission therefore recommends a risk-based approach.

Legal basis and sources: PPWR Art. 16; PPWR Annex VII; BMLUK fact sheet and EU guidelines. (EUR-Lex)

The PPWR provides for two main levels of documentation:

Technical Documentation

It contains the technical documentation on which the conformity assessment is based. Depending on the packaging and the requirements, this includes, in particular:

• General description of the packaging,
• Purpose,
• Designs and manufacturing drawings,
• Descriptions of materials and components,
• Explanations of how it works,
• Applicable standards and specifications,
• Calculations,
• Supplier declarations,
• Test and laboratory reports,
• Reasons for Exceptions.

EU Declaration of Conformity

With the EU Declaration of Conformity, the manufacturer confirms that the packaging meets the PPWR requirements in effect at that time. The declaration generally follows the structure of Annex VIII of the PPWR.

A recycling symbol, supplier certificate, or voluntary quality seal does not replace these documents. However, such evidence may be included in the technical documentation.

Legal basis and sources: PPWR Art. 15, Art. 38, and Art. 39, as well as Annexes VII and VIII; BMLUK Fact Sheet on Conformity. (EUR-Lex)

Legal responsibility lies with the producer.

The manufacturer may conduct the conformity assessment procedure itself or have it conducted by a competent body. However, the technical documentation and the EU Declaration of Conformity based on it must be clearly attributable to the manufacturer.

The statement must be signed by a person who is legally authorized to represent the company or who has been duly authorized to do so.

As a general rule, the documents must be available for inspection within ten days upon request by the authorities. The retention period is:

• five years for single-use packaging,
• Ten years for reusable packaging.

Importers must ensure that the required documentation is available. Distributors should also have compliance verifiably confirmed in cases of increased risk or when customers require it.

Legal basis and sources: PPWR Art. 15, Art. 18, Art. 19, and Art. 39; BMLUK Fact Sheet on Presentation and Retention Requirements. (EUR-Lex)

Not necessarily. Multiple packages may be included in a single declaration of conformity if they share the same relevant characteristics with respect to the applicable requirements and the products they contain.

For example, different sizes of packaging can be treated together if the difference in size does not affect the conformity being assessed.

Clustering requires that the following be documented in a transparent manner:

• which packaging is grouped together,
• which properties are identical,
• why differences do not affect conformity,
• which requirements apply to the entire group.

If there are changes to the material, coating, printing ink, adhesive, barrier, closure, or other relevant components, it must be determined whether the existing assessment remains valid.

Case-by-case review: What constitutes an acceptable summary depends on the specific requirement. A combined statement must not obscure relevant differences.

Legal Basis and Sources: EU FAQ on the Joint Declaration of Conformity for Comparable Packaging; PPWR Articles 38 and 39 and Annex VII. (Environment)

Starting in 2030, packaging must be recyclable in accordance with the future European “Design for Recycling” criteria. The specific criteria for different packaging categories will be established by additional legislation.

Three performance levels are planned:

• Class A: at least 95 percent recyclable,
• Class B: at least 80 percent,
• Class C: at least 70 percent.

Starting in 2038, only Class A and Class B packaging will generally be permitted to be placed on the market.

Starting in 2035, another question will arise: whether packaging is not only theoretically recyclable, but is actually collected, sorted, and recycled on a large scale within the EU.

Status: Assessment methodology still pending. The final “Design for Recycling” criteria and calculation methods have not yet been fully published. Until they take effect, the new PPWR conformity assessment procedure does not need to be conducted using a recyclability methodology that is not yet available. However, existing requirements and relevant standards remain in effect. (EUR-Lex)

The entire package or individual components?

As a general rule, the entire packaging unit is taken into account.

• Integrated components are assessed together with the primary packaging.
• Separate components are generally valued separately.
• Components that become mechanically detached during collection, transport, or sorting may also need to be assessed separately.

Labels, closures, sealing films, coatings, printing inks, and adhesives can affect the recyclability of the packaging as a whole.

Legal Basis and Sources: PPWR Art. 3 and Art. 6; EU Guidelines on the Assessment of Integrated and Separate Components. (EUR-Lex)

Mandatory minimum recycled content requirements will apply to certain types of plastic packaging starting in 2030. The specific requirements depend on the type of packaging and its intended use.

Among other things, the PPWR distinguishes between:

• contact-sensitive PET packaging,
• other contact-sensitive plastic packaging,
• Single-use plastic beverage bottles,
• Other plastic packaging.

As a general rule, post-consumer recycled material is required. Exceptions apply, among other things, to certain pharmaceutical, medical, hazardous materials, and food packaging, as well as to packaging in which the plastic content accounts for less than five percent of the total weight under certain conditions.

Status: Calculation methods still to be determined. The precise calculation, verification, and certification of recycled content are specified in additional EU legal acts.

Legal Basis and Sources: PPWR Art. 7; European Commission on the Phased Introduction of Recycled Content Targets. (EUR-Lex)

The harmonized PWR labeling will generally take effect on August 12, 2028, or 24 months after the entry into force of the implementing act adopted for this purpose—whichever date is later.

Until the new system is implemented, existing material codes and legally permissible symbols may generally continue to be used, provided they are not misleading. Once the harmonized labeling system takes effect, conflicting national material and sorting labels will largely be phased out.

Status: The designation has not yet been finalized. The final pictograms, colors, formats, and technical specifications will be established by an implementing act.

Is a QR code enough?

Generally speaking, no. A QR code does not automatically replace physical labeling.

He can:

• contain additional information,
• can be used to provide information about individual packaging components,
• provide specific information regarding reusable packaging,
• may be used in certain exceptional cases when physical labeling is not possible due to the size or type of Packaging.

The PPWR also permits the use of digital solutions for providing producer or importer information. However, this does not mean that all labeling requirements can be met exclusively through a QR code.

Legal Basis and Sources: PPWR Art. 12 and Art. 15; EU Guidelines on Labeling and Digital Media. (EUR-Lex)

The PPWR provides that EPR fees will in the future be differentiated more strongly based on the environmental quality of packaging. This so-called eco-modulation is intended to take recyclability into account in particular.

The logic:

• Packaging that is easier to recycle should receive financial incentives,
• Heavy or non-recyclable packaging may result in higher fees,
• Other factors, such as the proportion of recycled material or problematic substances, can also be taken into account.

The specific fees will be determined at the national level. Therefore, there will be no uniform EU license fee.

Status: Details still to be determined. The harmonized criteria and the specific Austrian implementation have not yet been finalized. Interzero is already pointing out that packaging design and recyclability will be more closely linked to EPR costs in the future. (EUR-Lex)