PPWR is now in effect across the European Union. Just days before its August 12 general application date, the European Commission published new guidance addressing several topics like EPR, PCR & more with direct implications for packaging users.
As your industrial packaging partner, Greif is closely monitoring PPWR developments to understand their impact on our industry and customers. To help you navigate these evolving requirements, here are four key developments to be aware of and actions you can take now:
1. Active Priority: Your Declaration of Conformity (DoC) File
Packaging placed on or imported into the EU market must be backed by a valid Declaration of Conformity (DoC). A DoC is not a simple self-certification checkbox; it relies on underlying technical documentation from the supplier related to the packaging/packaging material.
The Shared Supply Chain Duty: While packaging suppliers of empty sales packaging like Greif issue technical documentation and material declarations for such packaging., your company – usually in the role of the manufacturer for PPWR purposes – is responsible for compiling and maintaining the complete DoC file for the final packaged product placed on the market. The PPWR DOC and underlying technical documentation must be retained for 5 years (single-use packaging) or 10 years (reusable systems) after placing on the market.
2. Extended Producer Responsibility (EPR):Understanding Who Holds Responsibility
The latest guidance provides additional information on how EPR responsibilities may be determined, including the role of the party that designs packaging or places it on the market.
However, determining who qualifies as the responsible “producer” can depend on the specific packaging arrangement, contractual relationships and national implementation of EPR requirements. This means the answer is not necessarily the same across every packaging scenario or EU Member State. Our current understanding is that the company using the sales packaging – packer, filler or brand owner – will be considered, in the vast majority of cases, the producer.
3. Hazardous-Rated Containers (UN-Approved) Aren’t Automatically Exempt
The latest guidance highlights the importance of considering the actual use and application of the packaging, rather than relying solely on its UN certification. UN-rated packaging is exempt only when actively carrying dangerous goods.
If you use UN-certified steel/plastic drums or IBCs to ship non-hazardous products, those containers will not qualify for exemptions.
4. Plastic Recycled Content (PCR) Is Calculated Per Manufacturing Plant
PPWR introduces minimum recycled-content requirements for certain plastic packaging, with requirements phasing-in over time.
The latest guidance mentions that the 35% PCR target for non-contact-sensitive plastic packaging, phasing in from 2030, is calculated by packaging type and format as an annual average at manufacturing-facility level. This can provide flexibility to balance higher-PCR content packaging with virgin-resin only containers where technical requirements or limitations apply.
A Quick DoC Readiness Checklist for Your Operations
To help ensure your supply chain remains compliant with the requirements now in effect, we suggest using the following questions as a starting point:
- Do we know which PPWR requirements apply to each specific packaging format in our portfolio?
- Have we established who is legally responsible for drawing up and signing the DoC for our packaged products?
- Do we have the underlying technical documentation (such as material specifications, supplier declarations and, if and where needed, test reports) required to back up our conformity claims?
- Do we have a standardized process for collecting supplier data and keeping this compliance information up to date?
How Greif Supports Your Compliance Journey
Preparing a Declaration of Conformity relies on seamless data sharing across the supply chain. Greif provides full technical statements, component material specifications, and product statements to support your DoC documentation process.
Want a practical walkthrough of how packaging supplier data directly feeds into your DoC workflow? Watch Greif’s webinar: “PPWR in Practice: From Greif Technical Statements to Your DoC” to see real-world examples and get answers to common regulatory questions.