The most frequently asked questions about the PPWR, answered briefly. Is your question not among them? The PPWR Check gives a personal answer based on your role, market and material.
What does PPWR mean?+
PPWR stands for Packaging and Packaging Waste Regulation, formally Regulation (EU) 2025/40. It is the European packaging regulation that replaces the packaging directive of 1994. Because it is a regulation and not a directive, it applies directly in all 27 member states, without a national transposition law.
When does the PPWR take effect?+
The regulation entered into force on 11 February 2025. Most of the obligations have been enforceable since 12 August 2026. Additional requirements then follow in 2027, 2028, 2029, 2030, 2035, 2038 and 2040.
Does the PPWR also apply to small businesses?+
Yes. There is no general exemption for SMEs. The substance restrictions, the traceability obligation and the declaration of conformity apply regardless of company size. Micro-enterprises that make no more than 1,000 kg of packaging available in a member state per year are, however, exempt from the reuse targets, and in certain cases from the manufacturer obligations.
We order custom-made packaging — does that make us the manufacturer?+
Yes. For packaging bearing no name or trademark, the decisive criterion is who places the order and decides the design specifications. If you have custom packaging made for your product, you are the manufacturer and your supplier is not — even though you make nothing yourself. If the packaging does carry a trademark, the brand owner is the manufacturer. If you buy standard unbranded packaging off the shelf, the producing company is the manufacturer; adding a shipping sticker does not count as branding. Under Article 16 your supplier must provide you with the technical documentation you need.
What is the difference between manufacturer and producer?+
The manufacturer designs or has the packaging made under its own name or brand — there is one in the entire EU. The producer is the first to place the packaging on the market in a specific member state and bears the EPR obligation there. One company can have both roles, and be a producer in several member states.
Who enforces the PPWR in the Netherlands?+
The Human Environment and Transport Inspectorate (ILT). Non-compliant packaging may not be placed on the market. During a check you can be asked for the declaration of conformity. In August 2026 the European Commission clarified that enforcement is stepwise: the authority must first require you to end the non-compliance and give a reasonable window to put it right. Only if that does not happen do heavier measures follow, such as prohibition, recall or withdrawal from the market.
Will products be barred from the market from 12 August 2026?+
No. The European Commission states explicitly that enforcement of the obligations applying from 12 August 2026 must not disrupt trade flows, supply chains or consumer access to goods. Market surveillance authorities are asked to be supportive — awareness-raising, requests for information and requests for corrective action with a realistic timeline — rather than sanction-oriented.
Is there a transition arrangement for existing stock?+
Packaging already placed on the market before 12 August 2026 may stay on the market — even if it does not comply with the PPWR. Stock produced before that date but not yet placed on the market does not have to be destroyed, remanufactured or re-labelled: the identifier and manufacturer details (Art. 15(5) and 15(6)) may then be supplied via an accompanying document. For packaging manufactured after that date, the accompanying document is only allowed where the information genuinely does not fit on the packaging.
My supplier no longer exists — how do I demonstrate conformity?+
For packaging manufactured before 12 August 2026 a best-efforts obligation applies: you do everything you can to obtain the information after all — by contacting the former supplier, approaching the legal successor after a takeover or merger, or making your own substantiated assessment. Record what you tried. Existing suppliers are, incidentally, obliged under Article 16 to provide the documentation you request; they may not refuse.
Do coffee pads and tea bags fall under the PPWR?+
Yes. The packaging definition has been broadened. Coffee pads and tea bags are subject to a reporting obligation from 12 August 2026; coffee capsules from 1 January 2027. For many companies this means reporting on a stream they have never declared before.
Does my name have to be on the packaging?+
Yes. From 12 August 2026 the name, postal address and an electronic means of contact of the manufacturer appear on the packaging or behind a QR code, plus a type, batch or serial number. Importers add their own details.
May I still use the Green Dot?+
From 12 February 2027 the Green Dot symbol may no longer appear on the packaging, unless it is made accessible via a QR code.
Which packaging will be banned in 2030?+
Six categories: shrink wrap around multipacks, single-use plastic around fresh fruit and vegetables under 1.5 kg, single-use tableware for on-site consumption in hospitality, sachets for sauces and sugar, miniature packaging for cosmetics in hotels, and plastic carrier bags thinner than 15 microns.
Do pallet wrappings and straps have to become reusable?+
Not 100%. From 2030, transport packaging must be fully reusable for transport within your own company (including between linked or partner enterprises in the EU) and for transport to another company in the same member state. That requirement does not apply to pallet wrappings, such as stretch film and pallet hoods, or to straps used to stabilise and protect products on pallets: Commission Delegated Decision (EU) 2026/429, in force since 26 May 2026, exempts them. They still count towards the overall 40% reuse target for transport packaging, in which formats with a low and a high reuse rate can be offset against each other.
How much recycled material will my packaging need to contain?+
From 2030, for packaging that is at least 5% plastic: 30% in PET with food contact, 10% in non-PET with food contact, 30% in single-use beverage bottles and 35% in other plastic. In 2040 these percentages rise to 50, 25, 65 and 65 percent respectively.
Does production waste count as recycled material?+
No. It concerns exclusively post-consumer recyclate, measured on average per plant per year. Post-industrial material does not count.
Is the PPWR Check legal advice?+
No. It is an informative self-check based on the published regulation text and public guidance. Parts of the regulation are still being filled in via delegated and implementing acts, and member states may impose additional requirements.