PPWR Compliance & Supplier Information Packs | UKPS

PPWR applies from 12 August 2026

The first question is not which limit applies to you. It is who signs.

The EU Packaging and Packaging Waste Regulation — Regulation (EU) 2025/40, or PPWR — applies from 12 August 2026 and replaces the old Packaging Directive. If you place packaged goods on the EU market, whether directly, through a distributor or through an EU group company, part of it applies to you from day one.

Most of the coverage so far has focused on the numbers: substance limits, recycled content, recyclability grades. Those matter. But the question we are asked most often, and the one businesses most often have the wrong way round, is simpler than that. Who is actually responsible?

Who is the manufacturer?

Under PPWR, “manufacturer” is a legal role. It is not a description of who runs the machine.

Article 3(1)(13) defines a manufacturer as a person who manufactures packaging or a packaged product, or who has packaging or a packaged product designed or manufactured under its own name or trademark.

For most businesses buying packaging, it is the first limb that catches you. If you pack your own goods into bought-in packaging and place the packaged product on the EU market, you are the manufacturer of that packaged product. The company that sold you the box is not, and cannot sign on your behalf.

Two provisions do shift manufacturer status onto the supplier, and both are narrow. Article 3(1)(13)(b) applies where the business having the packaging made under its own name or trademark is a micro-enterprise and its supplier is located in the same Member State. Article 15(12) and Article 21 apply on a similar micro-enterprise basis where the supplier is located in the Union. A supplier established outside the EU meets neither condition.

Where your business is established still matters

It is often said that PPWR is triggered by where your product is placed on the market rather than where your business sits. That is true of scope. It is not true of role. An importer under Article 3(1)(17) must be established within the Union, so a UK business shipping into the EU can be a manufacturer under PPWR but cannot be an importer. That distinction decides who registers, who holds the technical file and whose name goes on the declaration.

What applies from day one

The Declaration of Conformity — Articles 15, 38 and 39

The manufacturer carries out a conformity assessment, draws up technical documentation to Annex VII, and issues an EU Declaration of Conformity for each packaging type. The declaration states that conformity has been demonstrated — a request sent to a supplier and still outstanding does not demonstrate anything. Records are kept for five years for single-use packaging and ten years for reusable packaging, and the declaration is to be kept up to date rather than treated as a one-off.

Substance restrictions — Article 5

The combined concentration of lead, cadmium, mercury and hexavalent chromium in packaging or its components must not exceed 100 mg/kg. That is a sum, not a limit for each metal, and it applies to all packaging including small components such as staples.

Separate PFAS limits apply to food-contact packaging only: 25 ppb for any individual substance and 250 ppb for the sum, both by targeted analysis with polymeric PFAS excluded from the count, and 50 ppm for PFAS including polymeric. A blanket request to confirm “no PFAS” across non-food-contact packaging is not this provision, and a supplier answer that does not say which basis it is measured on is not usable evidence.

Identification and traceability — Article 15(5) and (6)

Packaging must carry a type, batch or serial identifier, and the manufacturer’s name or registered trademark and postal address. This can sit on the packaging, behind a QR code or other data carrier, or in a document accompanying the packaged product. It is separate from, and earlier than, the harmonised material label that arrives in 2028.

Recyclability — Article 6(1). The one most people file under 2030

Article 6(1) says all packaging placed on the market shall be recyclable, and that paragraph carries no date of its own. The deferred dates sit in Article 6(2), which is where the grading system lives. The practical effect is that the duty is live from 12 August 2026 even though the A/B/C grades and the assessment methodology are not. Commission guidance addresses how the requirement is met in the meantime.

Where UKPS sits, and what you get from us

UKPS is a supplier of packaging. Article 16 of the Regulation puts a specific duty on suppliers: to give the manufacturer the information and documentation necessary to demonstrate conformity, including what is needed for the Annex VII technical documentation. That is our role in your compliance process, and we have built a document to discharge it.

The UKPS PPWR Supplier Information Pack

Issued per customer, on request. Each pack contains:

• Every active line we have supplied you over the last 12 months, drawn from our own system rather than from a list you have to compile.
• Material identification for each item, tested against the Article 3(1)(1) definition of packaging rather than assumed from what the item is made of.
• Component weights per unit, in the form your EPR reporting and your Article 10 minimisation assessment need.
• The substance position by material category, and the evidence each position rests on.
• The certification basis behind every category, described as what it actually is: certification verifiable on a public register, a manufacturer declaration held by UKPS, or a request made and still outstanding, with the date it was made.
• A statement of roles, so it is clear on the face of the document what we are asserting and what remains yours.

The pack is written to be passed down the chain. If you are a distributor or a merchant and the obligation actually sits with your customer, it can go to them without being rewritten.

What we do not do

We think it is worth being direct about this, because a supplier who blurs the line is not doing you a favour.

• We do not carry out your conformity assessment, and the pack does not substitute for one.
• We do not sign your Declaration of Conformity. Under Article 39 that declaration is issued under the manufacturer’s sole responsibility.
• We do not certify a recyclability grade. Article 6(3) puts that assessment on the manufacturer, and the methodology it depends on does not yet exist.
• We answer supplier questionnaires by issuing the pack rather than by completing the form. The pack covers more ground than the form asks for, and it is signed.
• We do not monitor the regulatory framework on your behalf or reissue the pack unprompted when something changes. Packs are reissued annually, or sooner on a material or regulatory change you or we identify.

Key dates

Dates marked as “at the earliest” carry an alternative trigger of a fixed period after the relevant EU acts enter into force, whichever is later. If those acts are delayed, the date moves.

Producer registration sits outside this table. It is not a documentation obligation but a condition of making packaging available at all, it applies separately in each Member State, and it follows the national registers rather than the application date. Registration under existing national EPR schemes continues in the meantime.

If you are not sure where you sit

Start with the roles question on page one, because everything else follows from it. If you buy from UKPS and do not yet have a Supplier Information Pack, speak to your account manager and we will prepare one.