PPWR
PPWR is here: ensure your supply chain is compliant or risk immediate penalties.
Failing to properly label packaging now puts businesses at immediate risk of penalties and held shipments, after a new EU regulation came into force on 12 August 2026.
With the TESISQUARE Platform, you can gather, validate and centralise compliance data from your suppliers with speed and accuracy.
Packaging is no longer a purely logistical matter, since the EU’s Packaging and Packaging Waste Regulation (2024/2745) came into force on 12 August 2026. It’s now a mandatory legal priority.
All packaging (primary, secondary, tertiary and transport packaging) must be accompanied by an EU declaration of conformity and a detailed technical dossier. Processing such a volume of supplier data manually or using spreadsheets is risky – and unsustainable.
The time to structure your supply chain data is now.
The Challenge
What do I risk if I’m not PPWR compliant in time?
The new PPWR requires businesses to gather, validate and manage a sizeable volume of data. Continuing to manage compliance through disjointed systems, spreadsheets, and manual processes brings serious operational and financial risks to your organisation:
Penalties and held shipments
Failure to supply an EU declaration of conformity (Annex VII) and the required technical documentation can lead to your goods being blocked at customs or within the distribution channel.
Reputational damage and greenwashing accusations
Insufficient data traceability exposes your brand to penalties for misleading environmental claims.
Spiralling operational costs
Chasing down technical documentation at the last minute and continuously re-entering supplier data into ERPs breeds inefficiency and unsustainable costs.
What PPWR deadlines do you need to meet?
Who does the PPWR apply to?
The PPWR does not only affect packaging manufacturers; in fact, no industry sector is exempt. If your company produces, imports, distributes, or sells products that are packaged in the European Union, then you must comply with the new requirements.
Materials within the regulation’s scope
The PPWR covers all the main materials used in packaging:
Glass and metal
Paper and paperboard (cardboard)
Plastic
Wood
Textiles
Ceramics/Porcelain
Supply chain roles
PPWR impacts individuals and businesses throughout the supply chain.
Manufacturers
Design, technical documentation and EU declaration of conformity.
Producer (brand owner)
Registration of Extended Producer Responsibility (EPR) and annual reports.
Importers and distributors
Verification of technical documentation and compliance before placing packaging on the market.
The TESISQUARE platform: one platform, end-to-end PPWR compliance
Don’t get caught up in micro-solutions and silos that create endless touchpoints handled in isolation. With TESISQUARE’s One-Stop Platform you can compile comprehensive data on each and every product, sync them with your ERP, and achieve full compliance with all present and future environmental – from the PPWR and EUDR, to the ESPR, CBAM and CS3D.
Why choose TESISQUARE for your PPWR compliance?
Centralised item management
Get direct access to the compliance data for each item by retrieving it from your ERP or supply chain systems. There’s no need to re-enter anything that has already been digitised.
Supplier network and the “do it once, do it well” principle
Suppliers only need to add the details of their packaging into the network once. It is then shared with clients, permitting maximum collaboration throughout the supply change, with zero duplication.
Native EUDR - PPWR synergy
Any paper or carboard packaging data already collected for EUDR compliance is automatically re-used for PPWR – no time is wasted on duplicate entries.
Dynamic data gathering and digital passport
The system only asks suppliers for missing details and lays the foundations for future labelling and for managing the packaging’s full lifecycle.
Watch our webinar on PPWR
View a real-life demo of how you can digitalise your PPWR compliance, manage due diligence, and collaborate with suppliers and partners, all within a single platform.
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Companies who have trusted us with their compliance
Time has run out: ensure your supply chain is PPWR compliant
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Q&A: New rules under PPWR
Frequently Asked Questions, Answered by the Experts
Scope of Application, Exemptions, and Penalties
What is the PPWR and what hard deadlines does it set forth?
EU Regulation 2025/40 (packaging and packaging waste regulation or PPWR) governs the entire lifecycle of packaging items, from design to the end of their useful life. It is directly applicable in all EU Member States. The first legal obligations for all companies begin on 12 August 2026, after which non-compliant packaging can no longer be placed on the market. However, any packaging that had already been placed on the market prior to 12 August 2026 in compliance with the rules in force at the time (e.g. stock in distributor warehouses or on retailer shelves) may continue be sold until that stock has been used up. Subsequent stages, from 12 August 2028, will introduce new labelling requirements. Strict targets on the recyclable content of packaging and empty space ratios will come into force from 1 January 2030.
Source: Regulation (EU) 2025/40 (PPWR), Articles 1, 7, 12, 24 and 71, with acknowledgement of 14; European Commission (DG ENV FAQ, March 2026): Section XV, Question 9
Are SMEs and micro-enterprises exempt from the requirements of the PPWR?
There are no general exemptions for SMEs or micro-enterprises. However, the Regulation provides important derogations and simplifications to lighten the administrative burden on smaller companies:
– Re-use targets: micro-enterprises (companies with fewer than 10 employees and a turnover or balance sheet below €2 million) are exempt from the mandatory re-use targets under article 29, provided they place less than 1,000 kg of packaging on the market per year.
– Refilling and takeaway: micro-enterprises are exempt from the HoReCa sector requirement to provide re-usable takeaway containers.
– Extended Producer Responsibility (EPR) transfer: if a micro-enterprise commissions the design or manufacture of packaging featuring its own brand, but the supplier resides in the same Member State, the legal responsibility of “manufacturer” (and all related compliance and EPR) are legally transferred upon that supplier.
– Simplified accounting: companies that place less than 10 tonnes of packaging on the market per year can report simplified data.
Conversely, no exemptions are in place concerning limits on empty space (maximum 50%) in grouped and transport packaging, including e-commerce packaging. Neither are there exemptions from the general requirement to minimise packaging.
All companies – micro-enterprises and SMEs included – must also guarantee that their packaging respects limits on chemicals. For example, the regulation prohibits the use of PFAS in food-contact packaging (in force from 12 August 2026) and limits the use of heavy metals (the total combined weight of all lead, cadmium, mercury and hexavalent chromium must not exceed 100 mg/kg) [8]; technical documentation to support this must be supplied for the full length of the supply chain.
Source: Regulation (EU) 2025/40 (PPWR), Articles 3, 5, 10, 24, 29, 33 and 44; European Commission Guidelines (DG ENV FAQ, March 2026): Section II (Question 5), Section XVII (Question 1).
What risks does a company run if it is not compliant by the 2026 deadline?
From 12 August 2026 (when the regulation’s general requirements come into force), any company that places non-compliant packaging on the market opens itself up to serious operational, customs and legal consequences:
– Withdrawal, recall or held shipments: the market surveillance authorities can require immediate corrective actions from the economic operator, prohibit a packaging from being placed on the market, demand its withdrawal from the market or recall all batches already distributed across the EU.
– Shipments held at EU customs borders: with regard to packaging or packaged products imported from third countries, national customs authorities can directly intervene at the border to identify, reject or block shipments without compliant technical documentation or that breach sustainability requirements.
– Administrative and financial penalties: each Member State must set out specific penalties by 12 February 2027. The PPWR states that such penalties must be effective, proportionate and dissuasive.
– Exclusion from Green Public Procurement (GPP) tenders: any non-compliant packaging precludes the option to participate in public administration tenders, whose minimum mandatory criteria (in force from 2030) require suppliers to respect the PPWR’s eco-compatibility laws.
– Greenwashing penalties: any misleading environmental claims (on recyclability, the percentage of recyclable materials or re-usability) that do not meet the minimum legal requirements or are not backed by technical documentation are deemed unfair commercial practice and will be subject to severe penalties.
Source: Regulation (EU) 2025/40 (PPWR), Articles 14, 58, 61, 62, 63, and 68, with acknowledgement of 182; European Commission Guidelines (DG ENV FAQ, March 2026): Section XV (Questions 13 and 14 – market surveillance and national penalties).
Roles and Responsibilities in the Supply Chain
What roles and responsibilities fall to manufacturers, suppliers, importers and distributors under the PPWR?
The PPWR sets out precise legal responsibilities, with no exceptions, for every supply chain role:
– Manufacturer (brand owner): the company that has packaging (or a packaged product) designed or manufactured and places it on the market under its own name or trademark. Accountability for regulatory compliance falls entirely to this entity: assessing compliance, filling out the technical dossier and signing the EU declaration of conformity. (One favourable point to note for micro-enterprises: as mentioned, if the brand owner is a micro-enterprise and purchases the packaging from a supplier within the same Member State, the responsibilities of manufacturer fall to that supplier.)
– Supplier: the entity that produces the packaging or supplies the materials to the manufacturer. It is legally required to provide all the information and data regarding the materials and laboratory tests necessary to enable the completion and compliance of the required technical documentation.
– Importer: the entity that places packaging from an EU third country on the EU market. It must ensure that the third-country producer has followed the correct compliance procedures and affix its contact details to the packaging. This entity is required to keep a copy of the EU declaration of conformity for 5 years (for single-use) or 10 years (for re-usable packaging).
– Distributor: the entity that makes packaging available on the market. It must carry out the required due diligence, checking that the label and all manufacturer/importer data can be found on the packaging. It must also ensure that the producer has carried out their Extended Producer Responsibility (EPR) registration in the Member State which is the package’s destination.
Source: Regulation (EU) 2025/40 (PPWR), Articles 3, 15, 16, 18 and 19; European Commission Guidelines (DG ENV FAQ, March 2026): Section II (Question 5 – exceptions for micro-enterprises); Section X (Questions 1 and 4 – manufacturer and supplier responsibilities).
Which compliance documents must be ready by 12 August 2026?
From 12 August 2026, manufacturers and importers of packaging must fill out and keep ready for inspection the following compliance documentation:
– Technical Dossier, drawn up in line with the provisions of Module A, Annex VII of the Regulation.
– The EU declaration of conformity, structured in line with the official form in Annex VIII.
What must these documents show in 2026? The entry into force of the regulation’s various requirements is staggered. From 12 August 2026, these documents must demonstrate compliance with the limits on chemical substances (ex art. 5). Specifically, they must certify that the:
- limits on the concentration of heavy metals have not been exceeded (the total combined concentration of lead, cadmium, mercury and hexavalent chromium must not exceed 100 mg/kg)
- limits restricting the PFAS content in packaging intended for direct contact with food stuffs have not been exceeded.
The documentation must also ensure full traceability of the packaging, by including all required identification details (type, batch or series number) and the manufacturer’s or importer’s details on the packaging.
These documents do not need to physically accompany the goods in transit. They must be held by the manufacturer or importer for 5 years (for single-use) or 10 years (for re-usable packaging) from the date on which it was placed on the market, ready to be issued in electronic format to the market surveillance authorities within 10 days of a reasoned request from said authorities.
Source: Regulation (EU) 2025/40 (PPWR), Articles 5, 15, and 18, and Annexes VII and VIII; European Commission Guidelines (DG ENV FAQ, March 2026): Section X, Question 2 (Manufacturer obligations); Section XV, Question 1 (Compliance procedures start date).
Technical Data, Empty Space, PFAS and Recycled Content
What limits are there on PFAS and heavy metals in packaging?
From 12 August 2026, to be placed on the EU market, all packaging must comply with strict limits on the safe use of chemicals:
– Heavy metals: the total combined concentration of lead, cadmium, mercury and hexavalent chromium must not exceed 100 mg/kg (100 parts per million (ppm)).
– PFAS (per- and polyfluoroalkyl substances): food-contact packaging is prohibited from placement on the market if the following concentrations are exceeded:
– 25 ppb (parts per billion) for any PFAS as measured with targeted PFAS analysis
– 250 ppb for the sum of PFAS measured (including the prior degradation of precursors)
– 50 ppm for total fluorine concentration.
These limits apply to the entire packaging item, including any inks, varnishes, lacquers, glues and adhesives.
Source: Regulation (EU) 2025/40 (PPWR), Article 5 and Annexes VII and VIII; European Commission Guidelines (DG ENV FAQ, March 2026): Section III (Substances of concern), Questions 6, 10, 14, 15, 16 and 17.
What is the Empty Space Ratio?
From 1 January 2030, the PPWR will introduce very strict rules to combat excessive packaging, through two complementary obligations:
- General minimisation (weight and volume): all packaging placed on the market will have to be designed in a way that keeps its weight and volume as low as possible, restricted to what is strictly necessary to ensure functionality, security, safety and hygiene. No packaging with features designed specifically to increase the perceived volume of the product – such as double walling or false bottoms – will be permitted.
- A 50% limit will be placed on empty space: economic operators filling grouped packaging, transport packaging or e-commerce packaging will be required to guarantee the percentage of empty space does not exceed 50% of the total volume of the packaging. When calculating empty space, protective or filling materials (such as bubble wraps, air cushions, polystyrene chips or paper cuttings) are legally considered “empty space”.
Who is exempt from the 50% limit? Economic operators who use re-usable packaging within a re-use system are exempt from meeting the 50% limit. Those who use sales packaging directly as the packaging for e-commerce shipments are also exempt from the 50% limit (although this does not remove the requirement for general minimisation of weight and volume).
Source: Regulation (EU) 2025/40 (PPWR), Articles 10, 24 and Annex IV; European Commission Guidelines (DG ENV FAQ, March 2026): Section VII (Packaging minimisation); Section XI, Questions 1, 2 and 3 (Methodology for calculating empty space).
Digital Management, Multi-Regulation Compatibility and the TESISQUARE Platform
How can I gather compliance data from suppliers efficiently while avoiding human error?
The PPWR transforms supply chain data collection from good business practice into a rigorous and detailed legal obligation. Under Article 16, suppliers are legally required to provide manufacturers with all the data and documentation necessary for the manufacturer to demonstrate that the packaging is compliant, including test reports and the technical data for the materials. Under Article 15, manufacturers are also legally required to fill out and keep a copy of the technical dossier and the corresponding EU declaration of conformity for 5 years (for single-use) or 10 years (for re-usable packaging) from the date on which the packaging was placed on the market, thus ensuring it can be electronically issued to the market surveillance authorities within 10 days of an inspection.
To avoid manual errors or penalties, businesses need to manage an enormous and complex volume of certificates (such as lab tests verifying safe levels of heavy metals and PFAS, as required from 12 August 2026). To do this, they must leave behind fragmented management systems like e-mail or spreadsheets that function in isolation.
The ideal solution is to adopt a collaborative and comprehensive platform like the TESISQUARE SRM suite, which fully integrates with your company’s ERP. Suppliers need only add their technical specifications and lab tests once. The shared network then automatically associates it with the validated identification documentation for that item. Companies who use it can then be sure the documents are compliant, secure, and immediately retrievable at any time.
If I already manage EUDR compliance for paper and wood, can I re-use that data for PPWR?
Yes, but with some crucial legal and regulatory differences that businesses must know and understand to avoid communication errors and penalties. The EUDR (the anti-deforestation regulation (EU) 2023/1115) and the PPWR (Regulation (EU) 2025/40) overlap significantly with regard to paper, paper/cardboard and wood, but the scope of their application and exemptions differ profoundly:
- The crucial packaging exemption under the EUDR:
- Under the EUDR, paper, paperboard and wooden packaging are subject to traceability requirements and due diligence only if they are placed on the market as standalone packaging, applicable for example to a producer selling empty paperboard or cardboard boxes (HS 48) or empty wooden pallets (HS 4415).
- Conversely, any packaging used exclusively as supporting material, protective material or to transport another product (e.g. a box containing a domestic appliance or a filled pallet) falls ENTIRELY outside the scope of the EUDR.
- Universal application under the PPWR:
- There are no such exemptions under the PPWR: any paper, paper/cardboard, or wood packaging (whether standalone or for use in transporting other goods) is subject, in all circumstances, to the rules of the PPWR (recyclability, minimisation, labelling).
- Exemptions for recycled paper/card:
- the EUDR fully exempts paper and paperboard made 100% from recycled materials (as they have already completed their lifecycle and would otherwise be considered waste) [84]. If the paper contains virgin fibres, the EUDR requires traceability and geolocation for the land of origin only for the part of the product that contains virgin fibres [84].
- Conversely, the PPWR applies irrespective of the presence of recycled or virgin materials, so that the entire item’s final recyclability is certifiable [6(1), Annex II].
Inter-compatibility and the value of the TESISQUARE Platform: TESISQUARE provides an extraordinary advantage for handling packaging waste streams that fall under both regulations (e.g. standalone packaging or packaging made of virgin fibres): any fibre composition data, timber supplier identification data, and supply chain certifications (FSC/PEFC) that were gathered and processed for EUDR are automatically populated in the materials section of the PPWR technical dossier (Annex VII). This avoids duplication of work and reduces time spent completing admin while ensuring all reported data is consistent for any future audits by the relevant authorities.
Source: Regulation (EU) 2025/40 (PPWR), Article 6 and Annex VII (Module A – Internal production control); European Commission Guidelines (DG ENV FAQ, March 2026): Section IV (Recyclability); Regulation (EU) 2023/1115 (EUDR) Article 3 (Compliance requirements) and Annex I (Goods nomenclature); European Commission Guidelines (DG ENV FAQ, April 2026): Section 2.5, Question 2.5 (Application of the regulation to wood and paper used for packaging); Section 2.8, Question 2.8 (Recycled paper/paperboard); Section 3.4 (Downstream obligations and traceability).
How does the TESISQUARE platform integrate with ERPs like SAP or Oracle?
Real-time integration with a company’s ERP is not just an efficiency measure; it is the primary defence against operational risks under the PPWR. Placing non-compliant packaging on the market can result in a company needing to take immediate corrective actions, such as withdrawing or recalling products from the market (ex art. 58), or customs holding shipments at the EU border (ex art. 61).
The Tesi Extended Integration module allows the platform to connect directly to your ERP, through APIs and automated data flows. The software reads any product master data and purchase orders in your management system and adds suppliers to the Tesi SRM to collect the missing data and documents. It then provides the ERP with an up-to-date compliance status. Under this system, only batches confirmed as compliant get the green light to proceed, eliminating the risk of penalties or customs disputes right at the start.