PPWR → PPWR decision tree

PPWR decision tree: what do you have to arrange?

The PPWR has applied directly across the EU since 12 August 2026. But which obligations rest on you depends on what exactly you do: make, fill, import, supply the Union from a third country, or resell. Answer the questions below and you will see two things side by side — what you owe financially, and which declarations and documentation you must be able to produce. With the article reference for every point. One run covers one role: if you fill your own products and also resell purchased packed products, run the tool once per stream.

Unsure about a term along the way — manufacturer or producer, transport or sales packaging? The PPWR glossary of terms, roles and EPR explains each one, with the article reference.

Question 1 of 10What does your company do with packaging?

Tick everything that applies. This determines your role under the PPWR — and therefore your obligations. One run covers one role, and one answer to the question under whose name or trademark the packaging is placed on the market. Different types of packaging in that role, for instance your sales packaging and your supplier's pallets, can be included in one go. If you have a different role for other packaging, for instance you fill your own products and also resell purchased packed products, run the tool once per stream.

More than one answer possible

An aid, not advice: no rights can be derived from the outcome. You will find more with the outcome, including how to report an error or remark.

Two tracks that are easily confused

In practice I see companies treat the PPWR as a single block, while it really contains two very different tracks — with different counterparts and different risks.

  • Contributions (EPR).Whoever is first to place packaging on a country’s market registers there and contributes to collection and treatment. This runs through the national producer register and a producer responsibility organisation — in the Netherlands, Verpact. Tariffs are national and will increasingly depend on how recyclable your packaging is.
  • Declarations (product conformity). This is separate. The manufacturer carries out the conformity assessment, compiles technical documentation and signs the EU declaration of conformity. No notified body is involved: you declare it yourself, and the authorities check on a risk basis.

The classic pitfall sits between the two: anyone having packaging made under their own name or trademark is the manufacturer under the PPWR — even when the printer or packaging supplier does the actual work. The documentation duty moves across with it.

What this tool is based on

On the text of Regulation (EU) 2025/40 itself. Every outcome carries its article, so you can look it up and substantiate it internally.

Where the tool is deliberately cautious

  • The level of the contribution is set nationally and differs per member state — the tool does not quote it.
  • Several requirements only take their final shape in delegated and implementing acts; where that is the case, it is stated.
  • The Dutch 50,000 kg threshold is national implementation, not a PPWR rule — and it is under pressure.

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From an overview to a file that holds up

The outcome above is a starting point. The next step is to work through your own range, set up the technical documentation and draw up the declarations of conformity — preferably inside the management system you already have. I am happy to help with that. And if you see something in the tool that you think is not right, let me know — every remark makes the tool better.

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