In August 2026, the PPWR is responsible for establishing a harmonized framework for packaging and packaging waste in the EU and replaces the former Packaging and Packaging Waste Directive (Directive 94/62/EC).1  It applies broadly to packaging placed on the EU market, regardless of whether that packaging is used in industry, manufacturing, retail, logistics, or households.
The regulations help to set a harmonized requirement across the entire lifecycle of packaging, i.e., from design and production, through use, to collection and recycling, and it also layers new compliance duties onto the existing supply chain of manufacturers, importers, producers, suppliers, and other economic operators. Hence, such practices affect a wide range of businesses well beyond those that physically manufacture or use packaging, including consumer goods companies, retailers, logistics, and e-commerce operators as well.
Extended Producer Responsibility (“EPR”), under which producers (which may be manufacturers, but also importers or distributors) bear responsibility, including financial responsibility, for the collection, sorting and recycling of the packaging they place on the market, generally connected to the registration with, and participation in, a national or regional producer responsibility scheme.
Since its initial entry into force in February 2025, the interpretation of PPWR has indeed posed a major challenge for multiple businesses inside and outside the EU. The European Commission published a first set of Frequently Asked Questions in March 2026, followed by a Guidance Document in June 2026. The updated set of FAQs on 3 August 2026 shows that the Commission's position on many questions remained open shortly before the PPWR’s application date.
The PPWR contains core compliance duties for the “manufacturer” of packaging, including the conformity assessment and underlying technical documentation. Hence, a proper definition of manufacturer as per updated FAQs is essential, providing a broader view of who qualifies for the term, ideally for branded and unbranded packaging, than some businesses had assumed, making this classification a priority action point.
In scenarios when packaging is referred to as a name or trademark, the “manufacturer” will be interpreted as the economic operator under whose name or trademark the packaging is placed on the market. The scenario is usually observed when another operator physically manufactures or fills the packaging, but the branded operator has the decisive contractual authority to determine the packaging’s characteristics. Where packaging does not bear a name or trademark, the “manufacturer” is generally the operator that orders the packaging and determines the packaging’s design specifications. In the case of generic transport packaging, this will usually be the operator that physically produces the packaging.
The Commission, especially for contract manufacturing arrangements, takes the view that a company ordering packaging can qualify as a “manufacturer” if it simply chooses a standardized packaging option from a supplier’s catalogue, without requesting any design changes, provided that the packaging carries its branding. The Commission also clarifies its views in relation to another point of practical relevance. Simply adding a sticker to the box for shipment purposes in the context of transport packaging is not necessarily “branding” and does not re-qualify the party shipping the goods as the “manufacturer” for the PPWR.
The practicality says that businesses should assess the packaging to which they apply their name or trademark, as doing so may cause them to qualify as the manufacturer under the PPWR with the corresponding compliance responsibilities, even where a third party has a role in the design, production or filling of the packaging.
Another example explaining the concerns about flexible transport packaging, such as stretch film and pallet wrap. Before the publication of the updated FAQs, a view had gained some traction that such flexible packaging reaches its “final form” only once it is actually applied, i.e., in the case of pallet wrap once wrapped around goods, meaning the entity applying the wrap would be the manufacturer under the PPWR and not the entity manufacturing the wrap roll.
Companies that manufacture, package, import or distribute goods into the EU should use the start of the direct application of the PPWR on 12 August 2026, together with the updated FAQs of 3 August 2026, as an occasion to revisit their obligations. Significant practical questions may need a (re-)assessment and further action, in particular which economic operator qualifies as the manufacturer under the PPWR in light of branding practices and contractual arrangements.
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