PPWR: The New Role of the Producer – Practical Implementation of Compliance Obligations

With the entry into force of key requirements of the European Packaging and Packaging Waste Regulation (PPWR) on August 12, 2026, one actor’s role is moving into the spotlight: The producer. In the web seminar “The new role of the producer under the PPWR – implementing obligations in practice”, Jie Zhang from Interzero Circular Solutions Germany GmbH explained which obligations producers will face in the future and how these can be implemented in practice.

Who exactly is a producer?

A central focus of the web seminar was the differentiation of the various economic operators within the PPWR. It became clear that the role of the producer differs significantly from the previously known responsibilities under German packaging law. In the future, the decisive factor will be who develops or has packaging manufactured under their own name or brand, or who makes the significant decisions regarding its design.

Using practical examples, it was explained when packaging materials legally become packaging and what significance this has for the assignment of producer obligations. Especially in the case of complex supply chains and branded goods, new questions arise that companies should evaluate at an early stage.

Labeling obligation from August 2026

From August 12, 2026, a new labeling obligation will apply to producers. In the future, packaging must be clearly identifiable and traceable. This includes, among other things, details about the producer as well as information for identifying the packaging, for example via batch or serial numbers. Some of this information can also be provided digitally, for instance via QR codes.

Important note: This obligation is to be distinguished from the planned disposal labeling for consumers. The harmonization of disposal labeling within the EU will be implemented at a later date.

Declaration of conformity becomes a key task

Another focus was the producer’s obligation of conformity. In the future, only compliant packaging may be placed on the market. The basis for this is:

• a conformity assessment procedure,
• the technical documentation, and
• the declaration of conformity.

The technical documentation is considered the heart of the verification process. It must clearly demonstrate how compliance with the relevant PPWR requirements was tested and what evidence is available for this. The declaration of conformity itself then serves as formal proof for authorities and business partners.

The important role of suppliers was particularly highlighted. Without reliable information along the supply chain, many conformity requirements cannot be met. Companies should therefore ensure at an early stage that the necessary data and evidence are contractually regulated and available.

Article 5: Substance requirements are imminent

Since the first PPWR requirements will take effect in just a few weeks, the web seminar focused intensively on Article 5 of the regulation. This regulates the restriction of certain substances in packaging.

In addition to the already known limit values for heavy metals, PFAS (“forever chemicals”) are increasingly coming into focus. For food contact materials, companies will in future have to be able to prove that the corresponding requirements are met. Both the current recommendations of the EU Commission and practical procedures for providing evidence were presented.

Conclusion

The PPWR brings new responsibilities and extensive documentation obligations for many companies. In particular, identifying one’s own role, ensuring the necessary supplier data, and preparing the conformity documents should be addressed actively now. The web seminar made it clear: those who analyze the requirements early and implement them in a structured manner create the foundation for a smooth transition into the new PPWR world.

The three most important insights

• The new producer role is a central element of the PPWR and must be clearly distinguished from previous responsibilities.
• As of August 12, 2026, the first labeling and conformity obligations apply to producers.
• Without close cooperation with suppliers, fulfilling many PPWR requirements will hardly be possible.

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