Roles & Responsibilities. Who needs to do what in your company & supply chain.

✓ Your obligations since 12 August 2026

• Only place compliant packaging on the market – including substance limits (heavy metals, PFAS in food-contact packaging, Art. 5) and minimisation (Art. 10).
• Carry out the conformity assessment and draw up the technical documentation in accordance with Annex VII (Art. 15(2)).
• Draw up the EU declaration of conformity in accordance with Annex VIII and keep it up to date (Art. 39).
• Keep the documentation for 5 years (single-use) or 10 years (reusable) and provide it within 10 days upon request (Art. 15(3), (10)).
• Indicate the type, batch or serial number as well as your name and postal address on the packaging, via QR code or in an accompanying document (Art. 15(5), (6)).

⏱ What comes later

Harmonised labelling (from 12 August 2028 at the earliest), recyclability from 2030, recycled content targets for plastic from 2030, and from 2038 only recyclability performance grades A/B.

📋 What you need from your suppliers

• Material composition per component
• Evidence on heavy metals and substances of concern, for food contact PFAS and the documentation required under food contact legislation (Art. 16(2))
• Test reports and specifications for the technical documentation

✓ Your obligations since 12 August 2026

• Provide the manufacturer with all information and documentation needed to demonstrate conformity – including the content for the technical documentation in accordance with Annex VII (Art. 16(1)).
• For food contact, also supply the documentation required under food contact legislation (Art. 16(2)).
• In a language the manufacturer can easily understand, on paper or electronically.
• Be able to identify, upon request of the authority, to whom you have supplied – for 5 or 10 years respectively (Art. 22).

⏱ What comes later

With the recyclability performance grades (from 2030) and recycled content targets, your customers will request additional information on recyclability and recycled content.

📋 What you need yourself

• Material composition of your product, where applicable from your upstream suppliers
• Test reports on heavy metals and PFAS
• Food contact declaration of conformity, where relevant

✓ Your obligations since 12 August 2026

• Only place compliant packaging on the market (Art. 18(1)).
• Ensure beforehand that the manufacturer has carried out the conformity assessment and drawn up the technical documentation, and that the goods are accompanied by the required documents (Art. 18(2)).
• Indicate your own name and postal address on the packaging, via a data carrier or in an accompanying document (Art. 18(3)).
• Keep a copy of the EU declaration of conformity for 5 or 10 years respectively and make the technical documentation available within 10 days upon request (Art. 18(7), (8)).
• If in doubt, do not place on the market; in case of non-conformity, take corrective action, withdraw or recall, and notify the authority (Art. 18(6)).

⏱ What comes later

Once the labelling obligation under Art. 12 applies (from 12 August 2028 at the earliest), you will also check the labelling. As a rule, you are also a producer within the meaning of EPR (see role section Producer).

📋 What you need from your manufacturer in the third country

• EU declaration of conformity in accordance with Annex VIII
• Access to the technical documentation in accordance with Annex VII (materials, test reports, assessments of recyclability, minimisation, reuse)
• Substance evidence, for food incl. PFAS and food contact legislation
• Type, batch or serial number and manufacturer details on the packaging or accompanying document

✓ Your obligations since 12 August 2026

• Act with due care (Art. 19(1)).
• Check before selling: Is the producer subject to EPR registered? Are the manufacturer and importer details provided? (Art. 19(2))
• If in doubt about conformity, do not sell until conformity has been established (Art. 19(3)).
• Storage and transport must not jeopardise conformity.
• In case of non-conformity, ensure corrective action, withdrawal or recall, inform the authority and, upon request, provide it with all available documentation (Art. 19(5), (6)).

⏱ What comes later

With the labelling obligation (from 12 August 2028 at the earliest), you will additionally check the labelling. Once the national PPWR producer registers are in place (Art. 44), the registration check will take place there.

📋 What you need from your suppliers

• The producer's registration number in the national packaging register
• Manufacturer or importer details and type, batch or serial number
• optionally: a copy of the EU declaration of conformity as evidence of your due care

✓ Your obligations since 12 August 2026 – under the mandate, at least (Art. 17(2))

• Keep the EU declaration of conformity and the technical documentation at the disposal of the authorities for 5 or 10 years respectively
• upon request, provide all documentation in a language that can be easily understood, within 10 days
• cooperate with the authorities in case of non-conformity
• terminate the mandate if the manufacturer acts contrary to the PPWR
• Not transferable: Conformity itself (Art. 15(1)) and drawing up the technical documentation remain with the manufacturer.

⏱ What comes later

The scope grows with every new requirement (labelling, recyclability performance grades, recycled content), because you keep the respective current documentation available.

📋 What you need from your principal

• current EU declaration of conformity per packaging type
• complete technical documentation in accordance with Annex VII
• notification of any change to packaging or material

✓ Your obligations

• Registration in the producer register of every Member State in which you first make products available – no registration, no sales there (Art. 44(2), (4)).
• Fulfilment of extended producer responsibility (Art. 45), individually or via a producer responsibility organisation – in Germany, a dual system (Art. 46).
• If you sell directly to end users in another Member State, you must appoint an authorised representative for EPR there by written mandate (Art. 45(3)). For producers from third countries, Member States may require this in general.
• Provide online platforms and fulfilment service providers with your registration number and a self-declaration (Art. 45(4), (7)).
• Important regarding timing: The national PPWR registers will only be set up 18 months after the first implementing act (Art. 44(1)). Until then, national rules continue to apply – in Germany, the Packaging Act (VerpackG) and LUCID.

📋 What you need

• Quantities per packaging material and Member State
• Material details from your suppliers (for quantity reporting)
• Contract with a system or a producer responsibility organisation

✓ Your obligations since 12 August 2026

• Storage, handling, packaging and dispatch must not jeopardise the conformity of the packaging (Art. 20).
• Obtain registration number and EPR self-declaration from customers selling to consumers upon concluding the contract (Art. 45(7)).
• Check with reasonable effort whether the details are correct; in case of false or missing information, demand correction and, if necessary, suspend service (Art. 45(8)).
• If you repackage goods yourself or use your own shipping packaging, you may be deemed to be the manufacturer or producer for that packaging.

⏱ What comes later

Requirements for e-commerce packaging, including empty-space ratio limits (Art. 24), with later deadlines (12 February 2028 / 1 January 2030).

📋 What you need from your customers

• Registration number in the producer register per destination country
• EPR self-declaration
• for own shipping packaging: documentation from your packaging suppliers

ℹ Your role under PPWR

• “Exporter” is not a role under PPWR. Only an entity established in the EU can be an importer – that is your EU customer.
• If you fill or package yourself, you are the manufacturer – even if located outside the EU. The declaration of conformity and technical documentation are then your task (Art. 15). Your importer may only accept the goods if this has been done (Art. 18(2)).
• If you are only a broker/trader, you pass the manufacturer's documentation on to your customer.
• If you sell directly to end users in the EU, you are additionally a producer and may need an authorised representative for EPR (Art. 45(3)).

⏱ What comes later

Labelling, recyclability grades and recycled content targets also apply to your packaging as soon as it enters the EU market.

📋 What you should keep ready

• EU declaration of conformity in accordance with Annex VIII per packaging type
• technical documentation in accordance with Annex VII
• Substance evidence, for food incl. PFAS and food contact legislation
• Your manufacturer details and type, batch or serial number on the packaging or accompanying document