The packaging regulation, also known as PPWR (Packaging and Packaging Waste Regulation), concerns packaging placed on the European market: from the box around a product to the pallet on which goods are transported. Whether the regulation applies to your company depends on one simple question: do you yourself place packaged products on the market, or do you supply packaging material to others? Those who do fall within the scope in principle, regardless of company size.
The regulation distinguishes between types of packaging. There is sales packaging, which is the packaging the end user receives. There is grouped packaging, which packages multiple products together for the shop. And there is transport packaging, intended to transport goods between companies without damage. Each type has its own requirements regarding material use, recyclability and labelling. An installation company that sends components to customers in its own packaging can thus just as well fall under the regulation as a manufacturer that packages consumer products.
Who exactly falls under the regulation
The regulation targets anyone who places packaging or packaged products on the European market for the first time. This can be the manufacturer, but also the importer who sources products from outside the EU and packages them or has them packaged themselves. A wholesaler who only resells existing, already packaged products, generally has a different position than the party that chose or had the packaging made. Where exactly the line lies between these roles is not always unambiguously established in every case; the regulation itself provides the definitions, and the supervisor explains how these are applied in practice.
For companies placing products on the market in multiple countries, it is relevant that packaging rules have traditionally differed per Member State, for example in collection and reporting obligations. The regulation harmonises some of this at European level, but not everything. Those who operate internationally are well advised to check per country what additional requirements apply. examined per subject what applies to your situation provides a first direction for this.
Difference from the digital product passport
It is important not to confuse packaging and product passport. The digital product passport concerns the product itself: what materials it is made of, how it can be repaired, what its environmental impact is. The packaging regulation concerns the wrapping around it. For some product groups, both regulations come together, for example when packaging information is also included in the passport. Whether this applies in your case depends on the product group in which you operate and the state of affairs in the underlying legislation for that group.
The difference is also visible in the administration. A product passport is linked to one product and remains attached to it, whereas packaging obligations are often kept per quantity sold or per market season. Companies that already collect data for a product passport often recognise part of the questions that the packaging regulation also asks, such as material composition and recyclability, but the two processes run separately.
What you can check before taking action
A good first step is to determine the role your company plays in placing packaging on the market: as a manufacturer, importer or distributor. After that, it is useful to look at what type of packaging is involved and whether there are already existing obligations, for example through a national collection organization. If you are uncertain whether a particular packaging falls within the scope, it is best to submit this to the competent supervisory authority or a lawyer who works with the current text; that text is published on EUR-Lex and is the only source you can rely on for exact deadlines and definitions.
Entrepreneurs who are unsure of their exact position often benefit from a brief overview to determine whether further investigation is needed. get a first indication in a few questions provides a starting point for this, without you having to investigate everything yourself right away. The question of how information is created and where it comes from is also relevant for many companies before they make a choice; see where the information on this platform comes from explains that.
Finally
Whether the packaging regulation applies to your company depends on your role in the supply chain and the type of packaging you use. Only a lawyer or the competent supervisory authority can make a statement about your specific situation. If you would like to get an initial picture of where you stand, take the free quick-scan or browse through the topics in the knowledge base.