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    Zwyrtek
    PPWR Compliance

    Full PPWR implementation.

    We help businesses prepare their packaging, documentation, data, contracts, supply chain and organisational processes for the requirements of the PPWR (Packaging and Packaging Waste Regulation). From qualifying the company's role and auditing packaging, through declarations of conformity, EPR, the BDO register and a reporting system, to ongoing regulatory monitoring.

    PPWR is not a single obligation for the environmental department. It is a multi-year compliance programme covering product, procurement, quality, sales, logistics, finance, IT, legal and the board.

    Book a PPWR consultationSee the implementation scope

    The first conversation is used to establish the business model, packaging flows and the potential scope of obligations. It does not replace a full compliance audit.

    The PPWR Regulation generally applies from 12 August 2026, while further requirements are rolled out in stages through to 2030, 2035, 2038 and 2040.

    Regulation

    PPWR changes how packaging is designed, documented and placed on the EU market.

    Regulation (EU) 2025/40 covers the entire packaging lifecycle — from design and material composition, through placing on the market, labelling and distribution, to reuse, recycling and extended producer responsibility.

    • Packaging design and composition

      Requirements on substances, recyclability, recycled content, weight and volume minimisation, and reusable packaging.

    • Conformity assessment

      Identifying requirements, gathering evidence, technical documentation, the conformity assessment procedure and the EU declaration of conformity.

    • Roles in the supply chain

      Establishing who is the manufacturer, importer, distributor, EPR producer, supplier, end user or authorised representative.

    • Data and traceability

      Data on materials, components, weight, substances, suppliers, recycled content, recyclability, target market and reuse.

    • EPR and domestic obligations

      Registration, reporting and financing of waste management in the countries where the packaging is to become waste.

    • Organisational processes

      Responsibilities, document flow, SKU updates, supplier verification, packaging approval and monitoring of legal changes.

    Read our analysis of the PPWR Regulation (Available in Polish)
    PPWR roles

    The manufacturer and the EPR producer are not always the same entity.

    One of the most common mistakes is equating the company that physically produces the packaging with the entity responsible for all PPWR obligations.

    Manufacturer

    Under PPWR, the manufacturer is the entity that produces packaging, or commissions its design or production, and places it on the market under its own name or trademark. It is generally responsible for:

    • packaging compliance with PPWR requirements
    • carrying out the conformity assessment
    • technical documentation
    • EU declaration of conformity
    • correct labelling of the packaging
    • corrective action in the event of non-conformity

    The manufacturer may also be the brand owner or the entity commissioning the design or production of packaging under its own name or trademark. There is generally one manufacturer for a given piece of packaging across the whole EU.

    Producer for EPR purposes

    Under PPWR, the EPR producer is the entity responsible for national extended producer responsibility obligations. It is generally responsible for:

    • registration in the relevant member state
    • reporting on packaging placed on the market
    • financing the management of packaging waste
    • cooperation with the producer responsibility organisation
    • performing domestic EPR obligations

    The EPR producer is established with reference to a specific member state and the place of first supply of the packaging or the packaged product.

    One company can simultaneously be a manufacturer, an importer and an EPR producer. It can also play different roles for different packaging, markets and sales models.

    Establish your company's role under PPWR
    Who it is for

    Who needs to prepare for PPWR?

    • Manufacturers of packaged products

      Companies producing and packaging food, cosmetics, chemicals, appliances, components, consumer goods and industrial products.

    • Own-brand owners

      Companies commissioning the production of products or packaging under their own brand or trademark.

    • Packaging manufacturers and suppliers

      Producers of cartons, film, bottles, containers, labels, closures, pallets and other components.

    • Importers

      Entities bringing packaging or packaged products from outside the EU and placing them on the EU market.

    • Distributors and wholesalers

      Companies making products available on further markets and verifying suppliers' documentation.

    • Corporate groups

      Organisations with multiple companies, markets, brands, factories or distribution channels.

    • E-commerce and marketplaces

      Online shops, cross-border sellers and companies using shipping packaging.

    • Retail and FMCG

      Retail chains, own brands, and manufacturers and distributors of consumer products.

    • Food and HoReCa

      Entities using food-contact packaging, single-use packaging and formats subject to specific requirements.

    • Automotive and industry

      Companies using transport, industrial and reusable packaging and B2B flows.

    • Logistics and fulfilment

      Operators involved in packing, repacking, warehousing and distribution.

    • Non-EU companies

      Manufacturers and sellers placing products on the EU market, including through branches and representatives.

    Decisions

    What PPWR questions do businesses bring to us?

    • Is our company a manufacturer within the meaning of PPWR?

      The manufacturer is the entity that produces packaging, or commissions its design or production, and places it on the market under its own name or trademark. Physical production alone does not determine the role. The assessment requires an analysis of contracts, markings and the placing-on-the-market model — the outcome depends on the packaging, the role, the market and the distribution model.

    • Are we an EPR producer in Poland or another EU country?

      EPR producer status is established separately for each member state in which the packaging or the packaged product is first made available. The same company may be an EPR producer in several countries, or in none. The analysis covers sales channels, incoterms and the entity making the first supply.

    • Who should issue the declaration of conformity?

      The EU declaration of conformity is issued by the packaging manufacturer, not by every participant in the supply chain. If a company commissions production under its own brand, it usually assumes the manufacturer's role. Identifying the right entity and authorised person requires establishing the roles for the specific packaging and market beforehand.

    • Is a supplier's declaration sufficient?

      Not always. A supplier's declaration is supporting evidence, but it does not replace the company's own conformity assessment and technical documentation. The document must unambiguously identify the packaging, refer to specific requirements and carry a date and version. The scope of evidence required depends on the material, the packaging's function and the company's role.

    • What documentation can we require from suppliers?

      You can require material specifications, component weights, information on substances, data on recycled content and recyclability, and test reports. However, effective data collection is based on contractual provisions and a standardised form. The scope depends on the type of packaging and the requirements that will apply to it in the coming years.

    • Do we need separate documentation for every SKU?

      Not always — documentation relates to a packaging type, not automatically to every SKU. If different SKUs use identical packaging with the same composition and weight, they can be covered by a single set of documentation. However, a change of material, supplier, weight, closure or label requires a distinction.

    • Can we group similar packaging types?

      Grouping is possible if the packaging shares the same material, essential characteristics, construction, components and purpose. The group must be clearly defined and documented so the supervisory authority can link the evidence to the specific packaging. Groups defined too broadly are the most common reason documentation is challenged.

    • How do we determine which elements are packaging?

      Packaging can include not only boxes and film but also labels, closures, dividers, tape, pallets or fillers. What matters is the function: protecting, storing, transporting or presenting the product. Qualifying these elements requires reviewing product specifications and actual packing practice at the plant.

    • How do we assess multi-material packaging?

      Multi-material packaging is assessed at component level, taking into account whether components can be separated and the mass share of each material. Data must be collected from several suppliers at once. The outcome of the assessment depends on the packaging's construction and future design-for-recycling criteria.

    • How do we prepare technical documentation?

      Technical documentation describes the packaging, its components, materials, weights, the requirements and standards applied, and the evidence of conformity. It is built in stages: from an inventory, through supplier data, to test results. Its scope and level of detail depend on the packaging type and the requirements that apply to it.

    • When are laboratory tests required?

      Tests are needed when the available supplier data cannot demonstrate compliance — typically for substances, food contact or verifying composition. The scope of testing is set after analysing evidence gaps, so that unnecessary tests are not commissioned. Tests are carried out by appropriate laboratories and testing bodies.

    • How do we verify PFAS in food packaging?

      Verification involves reviewing material declarations, information on coatings and barriers and — where the data is insufficient — analytical testing. The key is establishing which components are in contact with food and who supplies the functional layers. The scope of the work depends on the material, technology and supplier.

    • How do we prepare data for recyclability requirements?

      Data is needed on materials, components, weights, dyes, adhesives, labels and closures, broken down by packaging element. Only that level of detail allows design-for-recycling to be assessed once detailed criteria come into force. The outcome depends on the packaging's construction and the implementing acts.

    • How do we determine recycled-material content?

      Recycled content is demonstrated using data and evidence from plastic or material suppliers, not a general statement. The data must be linked to a specific batch, component and technology. The practical difficulty is keeping this data current as suppliers and formulations change.

    • How does PPWR affect supplier contracts?

      Contracts should impose an obligation to provide and update data, an audit right, rules for reporting material changes, and liability for non-conformity. Without these provisions, data collection relies solely on the supplier's goodwill. The scope of the clauses depends on negotiating position and packaging type.

    • What obligations do we have in other EU member states?

      EPR obligations are national: registration, reporting and financing of systems take place in the state of first supply. This may mean registrations in several countries and the appointment of authorised representatives. The scope depends on sales channels, including cross-border sales and marketplaces.

    • How do we combine PPWR with the BDO register and environmental charges?

      PPWR concerns packaging conformity as a product, whereas the BDO register and environmental charges are domestic registration, record-keeping and financial obligations. In practice, both areas draw on the same data on weights and materials. It is worth building a single data register that feeds both documentation and reporting.

    • How do we build a central packaging database?

      The database should link supplier, component, packaging, SKU, company and market, and store evidence and verification dates. It can be built in an existing ERP, PIM or a dedicated solution. The choice of tool is secondary to the data model and the rules on responsibility for keeping it up to date.

    • Who in the organisation should be responsible for PPWR?

      A single process owner is needed, with a mandate from the board, along with assigned roles across procurement, quality, R&D, logistics, sales, IT and finance. Diffused responsibility leads to a situation where no one can demonstrate full compliance. The model depends on the scale and structure of the group.

    • How do we prepare the company for a market surveillance inspection?

      An inspection usually concerns a specific piece of packaging: its identification, technical documentation, evidence and declaration. Preparation involves organising the repository, version control and an audit trail, and assigning people responsible for responses. The scope depends on the portfolio and the markets in which the company operates.

    • How does PPWR affect e-commerce and shipping packaging?

      Shipping packaging is packaging within the meaning of the regulation, so it will be covered by design requirements and EPR obligations in the countries of delivery. There is also the issue of empty space and liability in cross-border and marketplace sales. The scope of obligations depends on the logistics model and the entity making the product available.

    • How do we prepare a packaging adaptation plan for 2030?

      The plan should identify critical packaging, alternative constructions, a change timetable, required tests, and decision points with suppliers. Changing a piece of packaging usually takes well over a year, from design to production rollout. Priorities depend on volumes, markets and the risk of non-conformity.

    Service scope

    Full PPWR services — from legal analysis to operational implementation.

    We run our PPWR Compliance & Implementation practice in the PPWR 360° model: eight modules that can be launched together or in stages, depending on the organisation's maturity and the urgency of its obligations.

    01

    PPWR Role & Scope Assessment

    • identifying group entities
    • analysing trade flows
    • qualifying the manufacturer
    • qualifying the EPR producer
    • analysing importer and distributor status
    • analysing cross-border sales
    • analysing own brands
    • role map by packaging and market
    • responsibility matrix

    Outcome: A map of PPWR roles and responsibilities for companies, products, packaging and countries.

    02

    Packaging Inventory & Gap Assessment

    • packaging inventory
    • breakdown into components
    • format classification
    • material identification
    • SKU mapping
    • supplier analysis
    • missing-data analysis
    • requirement identification
    • documentation readiness assessment
    • risk register

    Outcome: A central packaging register and a list of gaps and corrective actions.

    03

    Supplier Compliance & Documentation

    • supplier questionnaires
    • requests for information
    • supplier declaration templates
    • documentation requirements
    • response validation
    • test report analysis
    • verification of material declarations
    • gap escalation
    • contractual clauses
    • new-supplier approval procedure

    Outcome: A documented process for obtaining and verifying data across the supply chain.

    04

    Technical Documentation & EU Declaration of Conformity

    • technical documentation structure
    • identifying applicable requirements
    • packaging description
    • design documentation
    • material composition
    • component specifications
    • evidence of conformity
    • test results
    • standards analysis
    • conformity assessment procedure
    • EU declaration of conformity
    • versioning and archiving

    Outcome: Documentation and declarations based on real evidence, not solely on suppliers' statements.

    05

    EPR, National Waste Register & Environmental Taxes

    • EPR producer status analysis
    • national waste register verification
    • packaging obligations in Poland
    • record-keeping and reporting
    • product fee
    • extended producer responsibility
    • obligations in other EU countries
    • authorised representatives
    • producer responsibility organisations
    • fee eco-modulation
    • linking PPWR data with environmental settlements

    Outcome: Consistency between PPWR product requirements and EPR registration, reporting and financing.

    We run this module together with the tax team — it also covers product fee and environmental reporting settlements (Available in Polish).

    06

    Contracts, Customs & Supply Chain

    • contracts with packaging manufacturers
    • contracts with component suppliers
    • responsibility for data and conformity
    • audit rights
    • obligation to update information
    • indemnities and recourse
    • handling non-conformity
    • import from outside the EU
    • importer status
    • branches and subsidiaries
    • customs documentation
    • repacking
    • fulfilment
    • cross-border sales
    • Incoterms and the allocation of operational responsibility

    Outcome: A supply chain and contracts adapted to the new regulatory obligations.

    Contracts, customs and trade are handled within our legal advisory, compliance and international trade practice (Available in Polish).

    07

    Data, Technology & Reporting

    • PPWR data model
    • packaging database
    • SKU and component structure
    • single source of truth
    • ERP integration
    • integration with PIM, PLM, QMS or workflow
    • supplier portal or forms
    • data-completeness dashboard
    • automatic reminders
    • approval workflow
    • document repository
    • multi-entity reporting
    • audit trail
    • AI supporting document classification and review

    Outcome: A lasting PPWR data management system, not a one-off spreadsheet.

    We build the systems layer together with our technology team: data, workflow and compliance process automation (Available in Polish).

    08

    Governance, Training & Change Management

    • PPWR process owner
    • steering committee
    • RACI matrix
    • board responsibility
    • responsibility of procurement, quality, logistics, sales and IT
    • new-packaging introduction procedure
    • supplier-change procedure
    • training
    • internal communication
    • monitoring of legal changes
    • periodic compliance review
    • inspection preparedness
    • non-conformity response plan

    Outcome: A compliance system that keeps operating after the implementation project has ended.

    We run the programme to the standard of governance and transformation programme management (Available in Polish).

    Methodology

    From diagnosis to a working compliance system.

    1. 01Discovery

      We get to know the group's structure, products, markets, sales models, packaging and current processes.

    2. 02Role mapping

      We establish entities' roles for each piece of packaging and country.

    3. 03Packaging mapping

      We build a register of packaging, components, SKUs, suppliers and materials.

    4. 04Gap assessment

      We compare the available data and documentation against the requirements for specific packaging.

    5. 05Remediation plan

      We set priorities, responsibilities, deadlines and corrective actions.

    6. 06Supplier engagement

      We obtain the missing information and roll out a standard for supplier cooperation.

    7. 07Documentation

      We prepare technical documentation, procedures and declarations of conformity.

    8. 08Data and workflow

      We launch the register, data flow, completeness controls and reporting.

    9. 09Governance and training

      We assign roles and train the people involved in the process.

    10. 10Monitoring

      We update the system as packaging, suppliers and implementing acts change.

    Cooperation models

    A scope of cooperation matched to the organisation's maturity.

    PPWR Initial Assessment

    For companies that do not know whether, or to what extent, PPWR applies to them.

    • workshop
    • initial role qualification
    • analysis of selected flows
    • identification of main obligations
    • risk map
    • recommendation of next steps

    PPWR Readiness Audit

    For companies with many packaging types, brands or suppliers.

    • role map
    • inventory of a sample or the whole portfolio
    • document analysis
    • gap assessment
    • list of gaps
    • implementation roadmap
    • priorities by risk

    PPWR Full Implementation

    For organisations requiring a comprehensive implementation.

    • full audit
    • supplier process
    • documentation
    • declarations
    • contracts
    • EPR
    • data
    • workflow
    • governance
    • training
    • inspection preparedness

    PPWR Managed Compliance

    Ongoing support after implementation.

    • helpdesk
    • verification of new packaging
    • documentation review
    • requirement updates
    • monitoring of implementing acts
    • support for new markets
    • supplier reviews
    • periodic reporting to the board
    Choose an implementation model
    Data governance

    PPWR is also a data project.

    In a large organisation, packaging data is scattered across procurement, quality, production, logistics, marketing, finance, suppliers and IT systems. Without a shared data model, it is impossible to efficiently maintain documentation, reporting and compliance.

    The PPWR data chain — a single source of truth

    1. 01Supplier
    2. 02Component
    3. 03Packaging
    4. 04SKU
    5. 05Company
    6. 06Market
    7. 07PPWR role
    8. 08Requirements
    9. 09Evidence
    10. 10Declaration
    11. 11EPR and reporting

    Data describing every piece of packaging

    • packaging identifier
    • type and function
    • components
    • material
    • weight
    • supplier
    • country of origin
    • brand
    • product and SKU
    • target market
    • manufacturer status
    • EPR producer status
    • substances
    • PFAS
    • recycled content
    • recyclability
    • reuse
    • source documents
    • verification date
    • responsible person
    • packaging version

    The biggest risk is not the lack of a single document, but the lack of control over whether the data is complete, up to date and assigned to the correct packaging.

    Documentation

    The declaration of conformity is the end of the process, not its starting point.

    The EU declaration of conformity confirms that a proper assessment has been carried out for a given packaging type and that documentation justifying conformity has been gathered. A declaration on its own, without evidence, packaging identification and technical documentation, does not create conformity.

    Before the declaration

    • packaging qualification
    • identifying the manufacturer
    • identifying requirements
    • material data
    • supplier information
    • tests and analyses

    Technical documentation

    • packaging description
    • design and application
    • components and materials
    • legal requirements
    • standards applied
    • evidence of conformity
    • test reports
    • risk assessment

    Declaration

    • identification of the manufacturer
    • identification of the packaging
    • statement of conformity
    • references to requirements
    • authorised person
    • date and signature
    • version control

    We do not prepare declarations "blind". We first establish the entity's role and the scope of evidence required for the given packaging.

    Supply chain

    Packaging conformity depends on data quality across the supply chain.

    What most often blocks documentation?

    • the supplier sends back a general statement without reference to requirements
    • the document does not identify a specific piece of packaging
    • the declaration does not refer to specific requirements
    • component data is missing
    • weights and material composition are missing
    • the test report concerns a different material
    • the document does not show a date or version
    • the supplier does not confirm changes to the formulation or construction
    • the declaration is issued by the wrong entity
    • data is inconsistent between procurement and quality

    Scope of our support

    We prepare a standard for supplier requests, a matrix of required documents, validation criteria, an escalation mechanism and appropriate contractual provisions.

    EPR and settlements

    PPWR, the BDO register and environmental charges must form one system.

    PPWR regulates packaging conformity as a product, together with the obligations linked to placing it on the market and managing it as waste. In Poland, some record-keeping and registration obligations are linked to the BDO (waste database) register, while financial liability may include product fees, financing EPR systems and other environmental settlements.

    1. 01Packaging data
    2. 02Conformity assessment
    3. 03EPR producer role
    4. 04Registration
    5. 05Record-keeping
    6. 06Reporting
    7. 07Fees
    8. 08Board report

    We run the settlements layer together with our tax team — eco-taxes, environmental charges and EPR settlements (Available in Polish) use the same data on weights and materials as the PPWR documentation.

    Having a BDO number does not in itself confirm that the packaging conforms to PPWR requirements. Conversely, a PPWR declaration of conformity does not replace EPR obligations, record-keeping or reporting.

    Sectors

    PPWR across different business models.

    • Manufacturing

      Product, group and transport packaging, component suppliers and plant responsibility.

    • FMCG and retail

      Large SKU counts, own brands, supplier requirements, consumer packaging and EPR systems.

    • Food and beverages

      PFAS, food contact, single-use formats, beverage packaging, recycled content and reuse.

    • Cosmetics and chemicals

      Multi-component packaging, closures, dispensers, labels and material evidence.

    • Automotive

      Transport and industrial packaging, closed loops, reusable packaging and inter-plant flows.

    • E-commerce

      Shipping packaging, empty space, cross-border sales, marketplaces and EPR in multiple countries.

    • HoReCa

      Service packaging, single-use formats, food packaging and reuse systems.

    • Pharma and medical devices

      Specific exemptions and interplay with product, safety and labelling regulations.

    • Logistics and fulfilment

      Repacking, packaging ownership, end user, transport and the operator's role.

    • Import and distribution

      Importer liability, non-EU documentation, foreign suppliers and market availability.

    Example projects

    Typical implementation projects.

    • Manufacturer with several hundred SKUs

      Packaging and component map, role classification, supplier questionnaires, document register and a standard declaration of conformity.

    • Corporate group operating in multiple countries

      EPR producer analysis by market, company and sales channel, and a central governance model.

    • Own-brand owner

      Establishing manufacturer status, splitting responsibility with the contract manufacturer and organising documentation.

    • Importer of non-EU products

      Assessment of importer status, completeness of supplier evidence, packaging conformity and EU market obligations.

    • Retail chain

      A PPWR requirements standard for suppliers, document validation and a non-conformity escalation system.

    • Food manufacturer

      Analysis of food-contact packaging, PFAS, material data and technical documentation.

    • E-commerce company

      Shipping packaging, multi-market EPR, weight data and preparation for empty-space requirements.

    • Industrial manufacturer

      Transport and reusable packaging, inter-plant flows and analysis of reuse models.

    • Company implementing a PPWR system

      Data model, functional requirements, supplier workflow, document repository and a management dashboard.

    • Organisation preparing for a client audit

      Rapid assessment of documentation completeness, supplier gaps, responsibilities and a corrective action plan.

    Timeline

    PPWR is a multi-year timetable, not a single date.

    1. 11 February 2025

      The PPWR Regulation entered into force.

    2. 12 August 2026

      General date of application of PPWR and the start of application of selected requirements, including certain substance restrictions.

    3. 2027–2028

      Further implementing acts, delegated acts, methodologies, standards and requirements concerning, among other things, labelling, minimisation and empty space.

    4. 2028–2029

      Phased entry into force of part of the harmonised labelling requirements.

    5. 2030

      Key requirements on design for recycling, recycled content, minimisation, empty space, format restrictions and reuse — subject to detailed rules and implementing acts.

    6. 2035

      Further requirements on large-scale recycling and further implementation levels.

    7. 2038

      Further tightening of the recyclability classification.

    8. 2040

      Higher targets for recycled-material content and reuse.

    The exact deadline depends on the specific obligation, the type of packaging and the dates on which implementing and delegated acts enter into force. The timetable should be updated as the regulation develops further.

    Checklist

    Is your company ready for PPWR?

    1. 01Are all packaging types identified?
    2. 02Is packaging assigned to products and SKUs?
    3. 03Do we know all components and materials?
    4. 04Do we know the weight of every component?
    5. 05Have we established the manufacturer for every packaging type?
    6. 06Have we established the EPR producer for every market?
    7. 07Do we have data from all suppliers?
    8. 08Do documents unambiguously identify the packaging?
    9. 09Can we demonstrate compliance with substance requirements?
    10. 10Do we have a PFAS verification process?
    11. 11Do we have technical documentation?
    12. 12Do we know who can sign the declaration of conformity?
    13. 13Do contracts require suppliers to update data?
    14. 14Do we have a single source of packaging data?
    15. 15Does the board receive a report on risks and implementation progress?

    If the answer to several questions is "no", "partly" or "we don't know", the company probably needs a structured PPWR programme, not just the preparation of a single document.

    Order a PPWR Readiness Assessment
    Project team

    PPWR requires the cooperation of many functions.

    • board
    • legal department
    • compliance
    • ESG and environment
    • procurement
    • quality
    • R&D
    • product design
    • production
    • logistics
    • sales
    • e-commerce
    • customs
    • finance
    • tax
    • accounting
    • IT and master data

    The lack of a single process owner and a clear division of responsibility leads to a situation where every department holds part of the data, but no one can demonstrate full compliance.

    A 360° approach

    PPWR requires more than an interpretation of the law.

    • Legal & Compliance

      Interpretation of roles, obligations, documentation, contracts and liability.

    • Tax, EPR & Environmental Charges

      National waste register, settlements, environmental charges, reporting and producer responsibility.

    • Customs & International Trade

      Import, cross-border sales, non-EU suppliers and international flows.

    • Data & Technology

      Packaging registers, systems, workflow, integrations, dashboards and automation.

    • Business Transformation

      Governance, allocation of responsibility, PMO, training, implementation and change management.

    We do not limit ourselves to preparing an opinion. We help translate regulatory requirements into specific processes, data, documents, responsibilities and tools for the organisation.

    Team

    A cross-disciplinary project.

    Depending on its scope, a PPWR project can involve different competencies within Zwyrtek Group and external partners. We define the team composition after diagnosing the scope — not every project requires all roles.

    • lawyers
    • tax advisors
    • environmental charges experts
    • customs specialists
    • supply chain experts
    • process consultants
    • data and technology specialists
    • change management experts
    • laboratories and technical partners

    The project team is led by partners responsible for the legal-compliance area and for implementation, data, processes, customs and tax. We indicate the partner line-up for a specific project at the proposal stage. Meet the Zwyrtek Group team.

    Service boundaries

    What should not be confused with a full PPWR implementation?

    • registering with the national waste register does not mean the packaging conforms to PPWR
    • a supplier's declaration does not always replace technical documentation
    • a single test does not confirm all PPWR requirements
    • buying an IT system does not solve the problem of incomplete data
    • a generic declaration template does not establish who should sign it
    • a material certificate does not always relate to the finished packaging
    • outsourcing reporting does not automatically transfer legal liability
    • a training presentation does not replace a compliance process

    Laboratory tests and specialist technical assessments may be carried out by appropriate laboratories, testing bodies or technical partners. Zwyrtek Group can coordinate their involvement in the project.

    First step

    What does a first PPWR consultation look like?

    1. 01Business model

      We establish what the company produces, imports, packages, sells and in which markets.

    2. 02Packaging flows

      We analyse the main packaging types, suppliers, brands and distribution channels.

    3. 03Potential roles

      We identify the most likely roles and the areas requiring detailed analysis.

    4. 04Project scope

      We recommend an audit, full implementation, a documentation project or ongoing support.

    During the first consultation we do not confirm the conformity of the entire portfolio, nor do we issue a declaration without reviewing the documentation.

    FAQ

    Frequently asked questions about PPWR.

    These answers are general in nature. The scope of obligations always depends on the entity's role, the type of packaging, the market and the distribution model.

    PPWR is Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste. It regulates the entire lifecycle of packaging: design and material composition, substance restrictions, recyclability, recycled-material content, weight and volume minimisation, labelling, reuse and extended producer responsibility. As a regulation it applies directly in all member states, although some obligations — particularly registration and reporting — remain governed nationally. For a business this means it must demonstrate the conformity of specific packaging with evidence, not a general statement. The scope of obligations depends on the entity's role, the type of packaging, the market and the distribution model, so an assessment always requires individual analysis.

    The regulation entered into force on 11 February 2025 and generally applies from 12 August 2026. However, this date does not cover all obligations. Some requirements — concerning, among other things, design for recycling, recycled content, minimisation, empty space, format restrictions, reuse and labelling — come into force in stages over the following years, in particular around 2030, 2035, 2038 and 2040, subject to detailed rules and implementing and delegated acts. The practical timetable for a specific company must be derived from its packaging portfolio and markets, and then updated as further acts and Commission guidance are published.

    PPWR applies to entities that place packaging or packaged products on the market or make them available on the EU market — a much wider group than just packaging manufacturers. The scope of obligations, however, varies. The manufacturer is responsible for packaging conformity and documentation, the importer for verifying evidence and the conformity of the imported goods, the distributor for checking the required documents, and the EPR producer for registration, reporting and financing the system in a given country. A company that only consumes packaging in an internal process may have narrower obligations. The assessment depends on the role, the packaging, the market and the distribution model.

    Under PPWR, the manufacturer is the entity that produces packaging, or commissions its design or production, and places it on the market under its own name or trademark. This means the manufacturer need not be the factory physically producing the packaging — it can be the brand owner. There is generally one manufacturer across the whole EU for a given piece of packaging, and it is responsible for the conformity assessment, technical documentation, the EU declaration of conformity, labelling and corrective action in the event of non-conformity. Establishing this role requires analysing contracts, commercial markings and actual influence over the packaging design.

    The EPR producer is the entity responsible for national extended producer responsibility obligations in the state where the packaging or the packaged product is first made available on the market. It is responsible for registration, reporting, financing the management of packaging waste and cooperation with the producer responsibility organisation. The role is established separately for each member state, so one group may have different EPR producers in different countries, and cross-border sales may require the appointment of an authorised representative. The outcome of the analysis depends on sales channels, delivery terms and the structure of entities within the group.

    The manufacturer is responsible for product conformity of the packaging: the conformity assessment, technical documentation, the EU declaration of conformity and labelling. The EPR producer is responsible for financial and reporting obligations in a specific country: registration, record-keeping, reports and financing collection and waste management. These are two separate layers of responsibility that may — but need not — rest with the same entity. A company can be the manufacturer of one piece of packaging, the importer of another, and the EPR producer in several countries at the same time. Conflating the two roles is the most common source of errors when planning implementation and allocating responsibility within a corporate group.

    Usually yes, if it commissions the design or production of packaging and places it on the market under its own name or trademark. The contract manufacturer then remains a supplier, and responsibility for documentation and the declaration of conformity passes to the brand owner. In practice this means obtaining data on materials, components, weights and substances from the manufacturer and securing these obligations in the contract. The outcome depends on the contract's terms, the packaging's markings and who actually places the product on the market, and therefore requires analysis of the specific commercial arrangement rather than a general assumption.

    An importer placing packaging or packaged products on the EU market has its own verification obligations: it must ensure that a proper conformity assessment has been carried out, that documentation and a declaration exist, and that the packaging is correctly labelled. If the importer places the goods on the market under its own brand or modifies the packaging, it may take on the manufacturer's obligations in full. In addition, it usually becomes the EPR producer in the state of first supply. The scope of liability depends on who is the importing entity, how the supply chain is organised and the commercial terms applied.

    Yes, if their packaging or packaged products reach the EU market. A non-EU company is not always the direct addressee of the obligations, however — the formal burden often rests with the EU importer or an authorised representative. In practice, a non-EU supplier must provide the data and evidence needed to demonstrate conformity, since without them the European partner cannot build the technical documentation. Companies selling directly to EU consumers, including through their own online shops and marketplaces, must additionally settle EPR obligations in the countries of delivery. The solution depends on the market-entry model.

    It can, if it is the entity that actually places the goods on the EU market and acts as the importing party. The mere presence of a branch does not determine the role, however — what matters is who enters into the transaction, who is the declarant in the customs procedure, and who first makes the product available on the market of a given country. Branch structures can also be relevant for EPR obligations and national registrations. The analysis therefore covers customs documentation, invoicing flows, Incoterms and the actual course of deliveries. The outcome depends on the specific operating model and may differ between markets.

    The EU declaration of conformity is drawn up by the packaging manufacturer, who is responsible for its content. It is signed by an authorised person within that entity. The declaration relates to a specific packaging type, indicates the requirements applied and is based on the technical documentation and the evidence gathered. It is not a document that can be issued solely on the basis of a supplier's statement or a template downloaded from the internet. Zwyrtek Group is not a certification body and does not issue "PPWR certificates" — we help establish the entity's role, gather evidence, build the documentation and prepare the wording of the declaration for signature by the appropriate person.

    Not always. If the supplier is the manufacturer placing the packaging on the market under its own name, the declaration is its responsibility. However, if the packaging is produced to order and under the recipient's brand, the recipient usually becomes the manufacturer, and the supplier provides the data, specifications and evidence needed for the conformity assessment. The supplier's declaration can be a useful input document in this situation, but it does not replace the company's own technical documentation. A practical solution is to standardise the supplier form and record the information obligations in the contract. The final split depends on the commercial arrangement and the packaging's markings.

    It can, if it covers a clearly defined group of packaging sharing the same essential characteristics: material, construction, components and purpose. Grouping is a way to reduce the number of documents for a large SKU portfolio, but it requires a precise description of scope and a link to the technical documentation. Groups defined too broadly are risky: during an inspection it is hard to show that the evidence relates to a specific piece of packaging. A change of supplier, formulation, weight, closure or label usually requires a new entry to be separated out. Grouping rules are best set at the start of the project and applied consistently in the packaging register.

    PPWR technical documentation is a set of documents demonstrating that a given piece of packaging meets the applicable requirements. It usually includes a description of the packaging and its purpose, drawings or design specifications, a list of components, materials and weights, an indication of the requirements and standards applied, evidence of conformity — including supplier data and test reports — and a risk assessment with conclusions. It should be versioned and linked to a specific packaging type. The level of detail depends on the material, the packaging's function and which requirements already apply and which will take effect in later years.

    Documentation and the declaration must be kept for the period set out in the regulations, counted from the placing of the packaging on the market, and made available to market surveillance authorities on request. In practice, what matters is not only the retention period itself but also the ability to quickly reconstruct which version of the packaging was valid during a given period and what evidence supported it. We therefore recommend a repository with version control, verification dates and assigned responsible people. The specific period and method of disclosure must be confirmed for the given packaging type and market, also taking national record-keeping obligations into account.

    Not always, but often. Tests are needed when the available supplier data cannot demonstrate compliance — typically for substance restrictions, food contact, verifying coatings and barriers, or inconsistent material declarations. A sensible sequence is to first analyse the evidence gaps and only then commission tests, so as not to test everything unnecessarily. Tests are carried out by appropriate laboratories and testing bodies; Zwyrtek Group can coordinate their involvement in the project, select the scope of testing and incorporate the results into the documentation. The scope depends on the material, technology and purpose of the packaging.

    PPWR introduces restrictions on certain substances in packaging, including provisions on PFAS in food-contact packaging, linked to thresholds and rules set out in the regulation and implementing acts. In practice this means establishing which components and functional layers are in contact with food, who supplies them, and whether the available material declarations actually relate to the finished packaging. Where the data is insufficient, analytical testing may be needed. The detailed scope of the obligation and how it is demonstrated depend on the material, the packaging's construction and the implementing acts in force at a given time.

    Design-for-recycling requirements are being rolled out in stages — the key threshold falls around 2030, with further tightening of classification expected in later years, in particular around 2035 and 2038. The detailed assessment criteria and performance classes will be clarified in implementing and delegated acts. For a company this means design decisions taken today should take future criteria into account, since changing a packaging design and rolling it out into production usually takes well over a year. Priorities are best set according to volumes, markets and the risk of losing the ability to sell a given format.

    Minimum levels of recycled-material content in plastic packaging are planned in stages, with a key threshold around 2030 and higher targets around 2040, while detailed calculation rules and exemptions will follow from implementing acts. Demonstrating recycled content requires data and evidence from material suppliers linked to a specific component and technology, not a general marketing statement. The biggest operational challenge is keeping this data up to date as suppliers and formulations change, so it is worth capturing it in the packaging register and in contractual provisions.

    Transport and grouped packaging is also packaging within the meaning of the regulation, so it is covered by requirements on minimisation, labelling, data and — to the appropriate extent — reuse and closed loops. In B2B and inter-plant flows, it is important to establish who is the manufacturer of reusable packaging, who manages its circulation and who is responsible for EPR obligations in a given country. Industrial and automotive companies often need to analyse reuse models, pallets, dividers and returnable packaging. The scope of obligations depends on the packaging's construction, the owner of the pool and the direction of flows.

    In e-commerce, shipping packaging is what matters most: its weight, construction, fillers and — once the relevant requirements take effect — restrictions on empty space. The second area is EPR: cross-border sales usually give rise to registration and reporting obligations in the countries of delivery, and marketplace sales require establishing who is the responsible entity. On top of that comes handling returns and repacking in fulfilment warehouses. In practice this means a need for reliable data on packaging weights broken down by market. The scope of obligations depends on the logistics model and sales structure.

    No. PPWR regulates packaging conformity as a product and the framework of extended producer responsibility, whereas the BDO register is a national register and record-keeping and reporting system operating under Polish law. Both areas are linked through data — weights, materials and volumes of packaging placed on the market — but they perform different functions. Product conformity does not exempt a company from registration and reporting obligations, and registration does not confirm that packaging meets design and documentation requirements. A well-designed compliance system feeds both areas from a single packaging data register, limiting the risk of discrepancies.

    No. Having a BDO registration number confirms entry in the national register and enables record-keeping and reporting obligations to be met, but on its own it does not prove that the packaging meets PPWR requirements. Product conformity is demonstrated through technical documentation, evidence relating to materials and substances, and an EU declaration of conformity issued by the appropriate entity. The reverse also applies: a PPWR declaration of conformity does not replace registration, record-keeping, reporting or fees. Companies that treat the BDO register as covering all packaging obligations usually discover the gaps only during a client audit or an inspection.

    EPR registration is required in the states where the company is a producer for EPR purposes, that is, where it first makes packaging or a packaged product available. This does not automatically mean registering in every EU country — what matters is the actual sales channel and the entity making the supply. Cross-border sales or a lack of establishment in a given country may require the appointment of an authorised representative. The analysis covers company structure, delivery terms, the role of sales platforms and volumes. The outcome differs between markets and requires periodic review as the sales model changes.

    An effective process starts with a standard: a single request form, a matrix of required documents, criteria for validating responses and an escalation path when data does not come in. In parallel, it is worth updating contracts — to require providing and updating data, reporting material changes, an audit right, and liability for non-conformity. Suppliers usually respond faster when the request is precise and states which packaging and requirement it relates to. A third element is a new-supplier approval procedure so gaps do not recur. The scope of activity depends on the number of suppliers and the company's negotiating position.

    The database should mirror the chain: supplier — component — packaging — SKU — company — market — role — requirements — evidence — declaration. Each record should be assigned material, weight, substances, recycled-content data, source documents, verification date, responsible person and packaging version. Technically it can be built in an ERP, PIM, QMS or a dedicated solution with a supplier workflow. What matters, however, is the data model and update rules, not the choice of tool. The biggest risk is not the lack of a single document, but the lack of control over whether the data is complete, up to date and assigned to the correct packaging.

    A single process owner is needed, with a mandate from the board, along with a clear division of tasks across legal, compliance, ESG, procurement, quality, R&D, production, logistics, sales, customs, finance and IT. Without this, every department holds part of the data, but no one can demonstrate full compliance. In larger organisations a model with a steering committee, a RACI matrix and periodic board reporting on progress and risks works well. In smaller ones, a designated person with a clearly described procedure for introducing new packaging and changing suppliers is enough. The model is adapted to the scale, the group's structure and the number of markets.

    Yes — under the PPWR Managed Compliance model we provide ongoing support once implementation is complete: a helpdesk for teams, verification of packaging entering the portfolio, review of documentation and declarations, monitoring of implementing and delegated acts, support when entering new markets, periodic supplier reviews and regular reporting to the board. We do not, however, take on the entity's legal liability for packaging conformity — that remains with the manufacturer and the EPR producer — nor do we issue certificates. We tailor the scope and frequency of support to the number of packaging types, markets and the pace of change in the portfolio.
    Related questions

    Related questions from boards, compliance and supply chain teams.

    • How do we establish the company's role under PPWR?
    • Who is responsible for the declaration of conformity?
    • How do we carry out a packaging audit?
    • How do we collect data from suppliers?
    • What do we do if a supplier refuses to provide data?
    • How do we group similar packaging?
    • How do we assess multi-material packaging?
    • How do we prepare a packaging approval procedure?
    • How do we implement PPWR across a corporate group?
    • How do we manage PPWR across multiple countries?
    • How do we link PPWR data with our ERP?
    • How do we combine PPWR with the BDO register?
    • How do we prepare for an inspection?
    • How do we limit board liability?
    • How do we change contracts with suppliers?
    • How do we prepare a roadmap to 2030?
    • How do we assess PFAS risk?
    • How do we manage declarations of conformity?
    • How do we control packaging versions?
    • How do we choose a system for PPWR data?
    • Can AI help analyse documentation?
    • How do we prepare a PPWR dashboard for the board?
    Related areas

    What do we combine PPWR implementation with?

    A PPWR programme is rarely run in isolation from other areas. It is most often combined with work on contracts and the movement of goods — legal advisory, compliance and international trade (Available in Polish) — and with settlements: tax advisory on eco-taxes and environmental charges (Available in Polish). The systems layer is built by the team responsible for data, workflow and compliance process automation (Available in Polish), and we run the whole to the standard of governance and transformation programme management (Available in Polish). Foreign companies usually start with the topic of obligations for foreign entrepreneurs in Poland (Available in Polish), while organisations automating document analysis start with the principles of the safe use of AI in compliance processes (Available in Polish). We describe the regulatory context in the article: a detailed analysis of the PPWR Regulation (Available in Polish).

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