PPWR for an Olive Oil Exporter: A Moroccan Case Study

What was the mill’s starting point?

A well-organised exporter on food safety, which had never looked at its packaging as a regulated product. This is a composite case study: it brings together situations our teams meet at Moroccan food exporters, without describing a client.

The mill, in the Fès-Meknès region, produces and packs extra virgin olive oil. It is certified to IFS Food Version 8. Its flows into the EU:

• its own brand in 50 cl and 75 cl tinted glass bottles, with aluminium caps fitted with a seal and a plastic pourer, and paper labels, sold to an importer-distributor established in France;
• a private label in 1-litre PET bottles for a European retailer;
• 5-litre metal tins under its own brand;
• year-end gift boxes, two 50 cl bottles in a carton sleeve with inserts;
• shipping cartons of six or twelve bottles, printed with the mill’s logo, on stretch-wrapped pallets.

In September 2026, the retailer sends a PPWR questionnaire: are you the manufacturer of the packaging? Provide the EU declaration of conformity, the PFAS results, the recycled content of the PET, your recyclability data and your labelling plan. The quality department, which has answered food safety questionnaires for years, does not know where to start.

Who was the manufacturer of which packaging?

Not the same company for every range. That was the first piece of work, reference by reference, using the Commission’s criteria: the brand normally designates the manufacturer, there is only one per packaging item, and the producer, which finances end of life, is the first operator that makes the packaging available in the Member State where it will become waste.

Two decisions followed. First, the mill wrote down this matrix and had it approved by the importer and the retailer, before answering any questionnaire. Second, for its own brand, it agreed the split of tasks with the importer, established in France with a registered address: the mill draws up the EU declaration of conformity and the technical documentation, the importer answers for placing on the EU market. Article 18 of the Regulation gives the importer its own obligations: check, before placing on the market, that the manufacturer has carried out the conformity assessment and drawn up the technical documentation, that the packaging is labelled and accompanied by the required documents, and that the manufacturer’s identification and contact details appear on it; indicate its own name and address; keep a copy of the EU declaration of conformity and be able to provide the technical documentation to the authorities for five years (ten for reusable packaging); take corrective action and inform the authorities if it doubts compliance; provide the documents proving compliance within ten days when an authority asks. It therefore needs the mill’s declaration, and quick access to its technical documentation, from the first shipment.

Which PFAS and food contact evidence was gathered?

Evidence targeted at what touches the oil. Since 12 August 2026, food-contact packaging may not be placed on the EU market above the PFAS limits in Article 5; labels, sleeves and cartons, which do not touch the oil, are outside that scope.

The plan followed the stepwise approach the Commission recommends for enforcement: total fluorine first, with a 50 mg/kg threshold below which the sample could be considered compliant; above it, a check on the nature of the fluorine, then total oxidisable precursor analysis. Each report was filed with the reference and the component batch tested. For bisphenols, Regulation (EU) 2024/3190, in force since 20 January 2025 and corrected by Regulation (EU) 2026/250, prohibits the use of BPA in food-contact varnishes and coatings. Its transitional provisions allowed single-use packaging made with BPA and compliant with the previous rules to be first placed on the market until 20 July 2026; it may still be filled and sealed during the following 12 months, and the food packed in it may be sold until stocks run out. The deadline moves to 20 January 2028 for packaging used to preserve fruit, vegetables or fishery products, and for packaging where the BPA varnish is only on the exterior metal surface. The oil tins fall under the general rule: the can maker’s declaration of compliance must now refer to this Regulation and state whether BPA or another bisphenol was used.

One point surprised management: stock. Bottles filled in July 2026 were waiting to be shipped in September. For an imported product, the Commission takes release for free circulation in the EU as the moment of placing on the market, and it states that there is no transitional period for the exhaustion of stocks as regards PFAS. Those batches therefore fell under the limits: the cap and tin batches used were traced through the IFS traceability system and linked to the test results.

What did the PET private label change?

The role, and therefore the nature of the work. For the PET bottles, the retailer is the manufacturer; it will draw up its EU declaration of conformity, based on the information its suppliers provide. The mill, as supplier, had to deliver accurate data, not a signature.

With its preform maker, it therefore consolidated:

• the composition of the bottle, cap and label, with the weight of each part;
• the recycled content of the PET and its batch traceability;
• the origin and recycling process of the recycled PET, in light of Regulation (EU) 2022/1616;
• the total fluorine results.

For recycled content in plastics, the Commission states that two exemptions apply directly, with no authorisation needed, including one for plastic parts representing less than 5% of the total weight of the packaging unit. The pourer on the glass bottles could qualify: the mill weighed each part and recorded the calculation in its technical documentation, as the Commission requires for any exemption invoked. As olive oil is not a beverage, the PET bottle falls, in our reading, under Article 7’s contact-sensitive packaging with PET as the major component: at least 30% post-consumer recycled plastic from 1 January 2030, or three years after the implementing act on the calculation method if that is later, then 50% from 1 January 2040, as an average per manufacturing plant and year. The retailer, as manufacturer of that bottle, carries this requirement; the mill passes on the blow-moulder’s data.

On recyclability, nothing was redesigned. Until the harmonised design-for-recycling criteria, expected through delegated acts by 1 January 2028 and applying from 1 January 2030 at the earliest, the Commission indicates that the manufacturer applies the requirements of the former Directive and its standards, such as EN 13430:2004. The mill documented the glass, cap, seal and label combination so as to be ready when the criteria are published.

How were labelling and gift boxes planned?

Through an artwork schedule, not an immediate redesign. Harmonised labelling of material composition will apply from 12 August 2028, or 24 months after the entry into force of its implementing act, whichever is the latest; in November 2026, the Commission’s implementation page still showed that act as in preparation.

The plan adopted:

• own brand: an inventory of every label and its variants, with its planned renewal date; the redesign will be done at the first renewal after the act is published;
• Decision 97/129/EC abbreviations: identified on the artwork, to be removed before 12 August 2028, after which they will no longer be allowed;
• private label: the retailer will decide; the mill has asked for its timeline;
• shipping cartons: transport packaging, except e-commerce packaging, is excluded from the sorting label.

For the gift boxes, the issue was minimisation. From 1 January 2030, the manufacturer will have to reduce the packaging’s weight and volume to the minimum necessary for its functionality. The Commission recalls that marketing and consumer acceptance no longer justify extra packaging on their own, while functionality takes account of sales for gift purposes or on the occasion of seasonal events (Annex IV). The mill measured the weight and volume of each gift box, noted the elements with no protective or presentation function, and is waiting for the harmonised standards the Commission must request by 12 February 2027.

Finally, the importer asked the mill about its pallets. According to the Commission, the transport packaging reuse targets, from 1 January 2030, only apply within the EU, from the first warehouse, and fall on the operator that places the product on the EU market in that packaging. The two parties agreed to revisit the question once the expected calculation method is available.

What lessons for other food exporters?

The main one: a PPWR questionnaire is handled by packaging item and by role, with the existing quality system. A fish cannery in Safi or a dried fruit exporter in Agadir will find the same logic, with other components at risk.

• Write down, for each range, who is the manufacturer and who is the producer, and have it approved by the customer.
  
• Separate the components in contact with food from those that are not.
  
• Obtain a total fluorine test from suppliers for each component in contact with food.
  
• Link, through traceability, component batches to the batches shipped after 12 August 2026.
  
• Weigh small plastic parts and document the recycled-content exemptions.
  
• List the artworks and abbreviations to review by 2028.
  
• Measure the weight and volume of gift boxes and over-packaging.
  
• Appoint someone to track Commission acts.
  

The full method is in our PPWR compliance checklist for exporters and the regulatory framework in our PPWR guide for non-EU exporters. Sector-specific requirements are on our food and beverage sector page.