What is the PPWR?
The PPWR is the EU Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40). It aims at reducing packaging waste and harmonizing packaging rules within the EU Single Market. This new regulation applies to all packaging and packaged products placed on the EU market.
The PPWR officially entered into force on 11 February 2025 and became applicable as from 12 August 2026 throughout the European Union – although certain provisions are subject to a different implementation timeline and shall apply only further down the line.
What does it change for your e-labels?
Some of the provisions introduced by the PPWR imply new labelling requirements. It requires for example that the company responsible for a packaged product (i.e. the “manufacturer”) be clearly identified, either on the label itself or through digital means, by stating its name, postal address and electronic contact details (Art. 15).
To help you comply with this new obligation, all our e-label templates now feature a new “Packaging information” section, in which you can add the relevant information about the manufacturer.
Preceded by the phrase “Manufactured by”, this field allows you to enter:
- The manufacturer’s name and postal address (i.e. a single point at which the manufacturer can be contacted)
- The manufacturer’s electronic contact details (email address or phone number)
But… who is the manufacturer?
Under the PPWR, the manufacturer is the natural or legal person who manufactures packaging or packaged products or has them designed or manufactured under its own name or trademark. It is not necessarily the natural or legal person that physically produces the packaging. In other terms, the manufacturer is the economic operator that orders the packaging and determines the characteristics and design of the packaging.
For packaged products that bear a company name or trademark, the “manufacturer” is generally the owner of that name or trademark, insofar as they are the ones determining the packaging specifications.
Please note that micro-enterprises (i.e. employing fewer than 10 people and with an annual turnover below 2 million €) are exempted from “manufacturer” status. The manufacturer status then passes on to the packaging supplier, provided that the latter is based in the same EU country as the micro-enterprise itself.
More information on the concept of “manufacturer” can be found:
- Under Questions 2 and 3 of the EU Commission’s Guidance document for PPWR (available in all EU languages)
- Under Section II, Questions 5, 6 and 7 of the EU Commission’s Frequently Asked Questions on PPWR document (available in EN only)
Comments