PPWR for Non-EU Exporters and Packaging Manufacturers

What is the PPWR, and when did it start to apply?

The PPWR (Packaging and Packaging Waste Regulation) is Regulation (EU) 2025/40 of 19 December 2024 on packaging and packaging waste. Published in the Official Journal of the European Union on 22 January 2025, it entered into force on 11 February 2025 and has applied since 12 August 2026. It replaces Directive 94/62/EC, repealed on that date, although some of the Directive’s provisions continue to apply afterwards, according to the Commission.

Three points matter for an exporter outside the EU:

• it is a regulation: one text applies in every Member State, with no national transposition;
• it covers all packaging placed on the EU market, empty or filled, whatever the material, whether made in the EU or imported from third countries;
• it has no single date: the Commission’s implementation page lists milestones running to 2034, and several obligations wait for implementing or delegated acts.

On 5 June 2026 the Commission issued a guidance document, C(2026) 3702, answering some thirty interpretation questions, followed by an FAQ in August 2026. It stresses that the guidance does not replace the Regulation: only the legal text is binding, and binding interpretation belongs to the Court of Justice of the European Union. The interpretations on this page come from that guidance and from the Commission’s official pages; the dates and articles in the table below have been checked against the official text of the Regulation on EUR-Lex.

Does the PPWR apply to exporters outside the EU?

Yes, as soon as their packaging or packaged products are destined for the EU market. The PPWR imposes nothing in Casablanca, Abidjan or Alexandria; it applies to the packaging the day it is placed on the EU market. But your EU customers have obligations they can only meet with your information, and in some cases you are the "manufacturer".

Start with the definition of manufacturer. Under the Regulation, it is the person who has the packaging, or the packaged product, designed or manufactured under its own name or trademark. The Commission draws several conclusions:

• there is only one manufacturer per packaging item in a supply chain;
• for sales and grouped packaging, the manufacturer is normally the filler, which is often also the brand owner;
• for transport packaging, the manufacturer is normally the company that makes it, unless it clearly carries the user’s brand;
• where no brand is shown, the deciding factor is who places the order and sets the design specifications.

The importer is a person established in the EU who places packaging from a third country on the market. A branch is not enough: according to the Commission, a non-EU manufacturer with only a branch in the EU must incorporate a subsidiary or appoint an authorised representative where the Member State concerned requires it.

This table is a reading grid, not legal advice: roles are decided item by item and confirmed in writing with the customer. Extended producer responsibility (EPR) falls on the "producer" that first makes packaging available on a Member State’s territory, in practice usually the importer or distributor established in the EU. The Commission adds that a logistics company repacking imported goods inside the EU becomes the producer of the transport packaging.

Which obligations apply, and when?

There is no single date. The table lists obligations on economic operators whose dates we verified in the Commission’s guidance or on its official pages. Where an article says "this date or X months after a Commission act, whichever is later", the date shown is a minimum.

Two obligations need a separate explanation. First, minimum recycled content in plastic packaging (Article 7): it applies from 1 January 2030, or three years after the implementing act on the calculation and verification method enters into force if that is later, and the Commission must adopt that act by 31 December 2026. The percentages refer to recycled content recovered from post-consumer plastic waste, in each plastic part of the packaging, calculated as an average per manufacturing plant and per year:

Second, the EU declaration of conformity, covered below: the Regulation sets no separate date for it. Before placing packaging on the market, the manufacturer carries out the conformity assessment procedure, draws up the technical documentation and signs the declaration (Article 15), an obligation that applies with the Regulation from 12 August 2026; the declaration attests compliance with the requirements of Articles 5 to 12 that apply to the packaging (Article 39).

What does the PFAS restriction change for food packaging?

Since 12 August 2026, packaging intended for food contact may no longer be placed on the EU market if its PFAS (per- and polyfluoroalkyl substances) content reaches or exceeds any of the three limits in Article 5:

If total fluorine exceeds 50 mg/kg, the manufacturer, importer or downstream user of the substance under REACH must, on request, prove how much of the fluorine is PFAS or non-PFAS, so that the packaging manufacturer or importer can draw up its technical documentation.

The Commission’s guidance adds four points that matter for exporters:

• no sell-through period: packaging placed on the market before 12 August 2026 may stay there, but any packaging placed on the market after that date must meet the limits;
• no exception for recycled materials;
• the moment that counts: sales and grouped packaging are generally placed on the market once filled; for imported goods, it is release for free circulation at the end of customs clearance;
• a stepwise test approach, since there is no harmonised method: total fluorine first (below 50 mg/kg the sample may be considered compliant), then checking whether the fluorine is organic or inorganic, then direct total oxidisable precursor (TOP) analysis for the 25 and 250 ppb limits.

In practice, a board mill supplying grease-resistant cartons to a biscuit exporter, or a maker of pouches for dates and dried fruit, must know what its papers, coatings and inks contain. The first question for your suppliers is simple: do their materials contain intentionally added PFAS, and can they prove it with a total fluorine test?

Declaration of conformity and technical documentation: who does what?

The manufacturer carries compliance. Under Article 15, it may only place on the market packaging that meets the requirements of Articles 5 to 12. The Commission explains how tasks are shared:

• the conformity assessment (Article 38) may be carried out by the manufacturer or on its behalf, for example by a laboratory or a certification scheme;
• the EU declaration of conformity (Article 39) is drawn up by the manufacturer, based on the information and documentation its suppliers provide (Article 16), or by an authorised representative appointed in writing (Article 17);
• the manufacturer remains the only operator legally responsible for compliance with the sustainability and labelling requirements, whoever actually drafted the document;
• an importer or distributor becomes the manufacturer if it places packaging on the market under its own name or brand, or modifies it in a way that may affect compliance (Article 21).

For a supplier outside the EU, the consequence is direct: your EU customer cannot sign its declaration without your data. Prepare one information sheet per packaging reference: materials and composition, PFAS results for food contact, recycled content, recyclability and minimisation data. It is also how you stay on the approved supplier list.

On recyclability, the Commission states that the conformity assessment under Article 38 is not required until the delegated acts under Article 6(4) enter into force. The text sets the minimum content of both documents:

• the technical documentation (Annex VII) describes the packaging and its intended use, its design and manufacturing drawings and its materials, lists the harmonised standards, common specifications or other specifications applied, explains how the recyclability, minimisation and reuse assessments were carried out, attaches the test reports and includes an analysis of the risks of non-conformity;
• the EU declaration of conformity (Annex VIII) identifies the packaging uniquely, names the manufacturer and, where applicable, its authorised representative, states that it is issued under the manufacturer’s sole responsibility, cites the Union acts and the standards or specifications applied and any notified body involvement, and bears a dated signature. It is kept up to date and written in the language required by the Member State where the packaging is placed on the market; where relevant, a single declaration covers all the Union acts concerned (Article 39).

Both documents are kept for five years after a single-use packaging is placed on the market, and ten years for reusable packaging (Article 15).

Recyclability and recycled content: what to prepare before 2030?

Article 6 sets the principle: all packaging placed on the market must be recyclable. The Commission considers this has applied since 12 August 2026, but until the harmonised criteria apply, manufacturers only have to meet the former Directive’s requirements and the related harmonised standards, such as EN 13430:2004 on packaging recoverable by material recycling.

The timeline then has two stages:

1. Design for recycling: criteria set by delegated acts the Commission must adopt by 1 January 2028, applying from 1 January 2030 or 24 months after their entry into force, whichever is later.
2. Recycling at scale: from 1 January 2035, or five years after the implementing acts setting the method enter into force, whichever is later.

For recycled content in plastic packaging, two exemptions apply directly, with no authorisation needed: food-contact plastic packaging where the quantity of recycled content threatens human health and makes the product non-compliant with Regulation (EC) No 1935/2004, and any plastic part below 5% of the total weight of the packaging unit. The manufacturer must justify the exemption in its technical documentation. For food contact, recycled plastics must also meet Regulation (EU) 2022/1616, which covers recycling technologies among other things. The Commission must assess by 1 January 2028 whether further derogations are needed.

For a plastics converter in Morocco, Tunisia or Egypt, the work starts now: material data sheets, the make-up of multilayer structures, and batch-level traceability of recycled materials.

Harmonised labelling: why is nothing mandatory before 12 August 2028?

Because Article 12 sets harmonised marking of material composition from 12 August 2028, or 24 months after the implementing act defining the label enters into force if that is later. The label is based on pictograms and must be easy to understand, including for persons with disabilities. Article 12(6) required its adoption by 12 August 2026, but as of 6 November 2026 the Commission’s implementation page still says that implementing act is in preparation. Until it is in force, the actual deadline cannot be calculated; it will not fall before 12 August 2028.

What to know now:

• sorting labels and reuse labels are mandatory; recycled-content and bio-based content labels remain voluntary, but must follow the harmonised EU specifications once they apply;
• transport packaging, except e-commerce packaging, and packaging covered by a deposit and return system are excluded from sorting labels;
• labelling is fully harmonised: Member States will not be able to keep national sorting labels next to the EU label;
• the material identification abbreviations of Decision 97/129/EC will no longer be allowed after 12 August 2028;
• EPR information may only be provided in digital form.

For a label printer in Rabat or Nairobi, this means a wave of artwork changes across its exporting customers: better to plan it than to suffer it.

Minimisation, empty space and reuse: what affects exports?

Three 2030 obligations concern shipments to Europe:

• Minimisation (Article 10): by 1 January 2030, the manufacturer or importer reduces packaging weight and volume to the minimum needed for its function. Marketing and consumer acceptance no longer justify extra packaging on their own; EN 13428:2004 remains the reference until the end of 2029, and the Commission must ask for it to be updated by 12 February 2027.
• Empty space (Article 24): for grouped, transport and e-commerce packaging, the empty space ratio must not exceed 50%, from 1 January 2030 or three years after the implementing act on the calculation method.
• Reuse of transport packaging (Article 29): from 1 January 2030, at least 40% of the pallets, boxes, trays, crates, drums and similar formats used in the EU must be reusable within a re-use system.

Good news for exporters: according to the Commission, the transport packaging reuse targets only apply within the EU. For imported goods they apply from the first warehouse in the EU, and a consignment going to a single final destination does not have to be unpacked and repacked. The obligation lies with the operator that places the product on the EU market in that transport packaging.

How does the PPWR relate to BRCGS Packaging Materials Issue 7?

The PPWR is law; BRCGS Packaging Materials Issue 7 is a private, voluntary certification, audited since April 2025. Neither replaces the other, and the official BRCGS page for the Standard does not mention the PPWR. But Issue 7 already requires useful evidence:

• a statement of compliance for each food-contact product, confirming compliance with legal requirements in the country of manufacture and, where known, the country of use, and declaring post-consumer recycled content;
• a hazard analysis and risk assessment (HARA) that considers migration of substances and recycled materials;
• artwork, print and claims control, useful for labelling and recycled-content labels.

A packaging manufacturer aiming for both should build a single system: BRCGS’s HARA, specifications and statements of compliance become the base of its PPWR file. Issue 7 requirements are detailed on our BRCGS Packaging Materials Issue 7 page, and the choice between BRCGS standards on our BRCGS certification hub.

Is your company ready for the PPWR?

Review these points with your quality, purchasing and export teams.

• The list of packaging shipped to the EU is current: material, format, food contact, brand carried.
  
• Each party’s role (manufacturer, supplier, importer, producer) is written down and agreed with the EU customer.
  
• Ink, varnish, paper and polymer suppliers have confirmed, with evidence, that no PFAS are intentionally added.
  
• Total fluorine results exist for the most exposed food-contact packaging.
  
• An information sheet per reference is ready for the manufacturer’s EU declaration of conformity.
  
• Specifications state recycled content and its batch traceability.
  
• Multilayer structures and material combinations have been reviewed against future recyclability rules.
  
• The artwork change plan for harmonised labelling is dated.
  
• Transport packaging into the EU has been reviewed (empty space, reuse).
  
• Someone tracks Commission acts and updates the plan.
  

If more than three boxes are empty, start with a mapping and a gap analysis.

What ACG does for exporters and packaging manufacturers

ACG supports food exporters and packaging manufacturers in Morocco, Africa and the Middle East on the compliance of their packaging with the EU market. The firm reports 502 projects and brings together 32 consultants and experts. PPWR work sits within our ESG and CSR offer, alongside ESG reporting, carbon footprinting and EU customer requirements.

We start from your existing systems (BRCGS, IFS, FSSC 22000 or ISO 14001) and train your teams: see the environment, industrial risk and pharma domain and the training catalogue.

For a first conversation about your packaging and your shipments into the EU, describe your project.