Who is a manufacturer under PPWR? Key obligations explained

What is the PPWR and why is it important for packaging compliance

The Packaging and Packaging Waste Regulation (PPWR) came into force on 11 February 2025 and will apply from 12 August 2026, replacing the existing directive.

Its aim is to harmonise packaging waste management across the EU through:

• EU-wide labelling requirements
• Recyclability criteria
• Standardised data reporting
• Stricter rules on packaging design and materials

Unlike traditional Extended Producer Responsibility (EPR), the PPWR introduces detailed obligations across the full packaging lifecycle.

For more information on the official framework, see the European Commission.

Who is a Manufacturer under PPWR?

The PPWR manufacturer definition represents a significant shift. A manufacturer is no longer simply the company that physically produces packaging. Instead, it is the organisation with the most influence over packaging design.

This includes businesses that:

• Apply their own brand or trademark to packaging
• Specify packaging materials or design
• Sell products under their own label in the EU or Northern Ireland

Put simply: if your name is on the packaging, you may now be the manufacturer under PPWR.

PPWR Manufacturer definition: are you now responsible?

Many businesses will be surprised to find they now fall under this definition. Retailers, importers, brand owners, and e-commerce sellers are particularly affected. Even where packaging is produced by a third party, responsibility may sit with the business placing it on the market.

Understand your PPWR compliance obligations by completing our free PPWR Obligation Quiz.

Examples: Who is a Manufacturer under PPWR?

To make this clearer, here are some common scenarios:

• A retailer selling private label products
• An e-commerce brand shipping goods into the EU
• A company rebranding imported products
• A business specifying packaging design for its products

In each case, the company may be considered the manufacturer under PPWR due to its control over packaging.

PPWR compliance obligations for Manufacturers

If you are deemed a manufacturer under PPWR, several key requirements apply from 12 August 2026.

1. Packaging labelling requirements

Manufacturers must display:

• A unique packaging identifier
• Company name and postal address

Where this is not possible, a QR code or other digital carrier may be used.

2. Conformity assessment and documentation

Manufacturers must carry out a conformity assessment for each packaging unit, including:

• Technical documentation
• An EU Declaration of Conformity

Further environmental and compliance guidance is available from the European Environment Agency.

3. Ongoing PPWR packaging requirements

Manufacturers are responsible for ensuring packaging complies with:

• Design requirements
• Material restrictions
• Labelling standards
• Data reporting formats

Does PPWR apply to UK companies?

Yes. The PPWR applies to any company placing packaging on the market in the EU or Northern Ireland. This means UK businesses exporting goods or operating in these markets must comply with PPWR requirements.

Don’t wait until August. Get ahead of PPWR compliance

The changes introduced by PPWR are significant, and early preparation is essential. At Valpak, we support businesses in navigating PPWR compliance obligations with:

PPWR Advisory Service

• Understand your role under PPWR
• Identify compliance gaps
• Build a clear action plan

Enquire about our PPWR Advisory Service

PPWR Conformity Data & Documentation Service

• Support with Declarations of Conformity
• Technical documentation management
• Data readiness for compliance

Explore our PPWR Data Service

PPWR Obligation Quiz

Not sure where you stand? Take our PPWR Obligation Quiz to quickly assess your responsibilities.

Or contact our team by calling 03450 682 572 to discuss your obligations.