--- title: "PPWR compliance: who can help?\nConsultancy, software or producer responsibility organisation?" description: "PPWR compliance support compared: consultancies, software, producer responsibility organisations and lawyers, with prices and what each leaves to you." canonical: https://projetcelsius.com/en/blog/ppwr-compliance-support/ author: "Sébastien Pierfederici" datePublished: 2026-11-06 dateModified: 2026-11-06 language: en translationOf: https://projetcelsius.com/blog/conformite-ppwr-comment-se-faire-accompagner/ --- # PPWR compliance: who can help? Consultancy, software or producer responsibility organisation? **Author**: Sébastien Pierfederici **Published**: 2026-11-06 **Section**: Practical guide **Canonical URL**: https://projetcelsius.com/en/blog/ppwr-compliance-support/ **French original**: https://projetcelsius.com/blog/conformite-ppwr-comment-se-faire-accompagner/ **Source**: Projet Celsius (https://projetcelsius.com/en/), a climate strategy consultancy of engineers and PhDs based in Paris and Marseille. > To bring its packaging into line with the PPWR, mandatory since **12 August 2026**, a company can rely on its producer responsibility organisation, a software tool, a technical consultancy, a large audit firm or a lawyer. The manufacturer of each packaging type must draw up its technical documentation and its **EU declaration of conformity**. At Projet Celsius, a simple compliance project costs **around €5,000 excl. VAT** for an SME, and **€10,000 to €15,000 excl. VAT** with extended producer responsibility (EPR), the files and follow-up. ## Key takeaways - The manufacturer **signs the declaration alone**: a service provider prepares it but does not take responsibility for it. - A company with up-to-date data can carry out **its packaging inventory and its EPR membership** on its own. - Software produces the documents, but **does not tell you which packaging** your company is the manufacturer of. - For an SME, we recommend **a technical consultancy for the first inventory**. *Projet Celsius, which wrote this article, is one of the providers compared. Each provider is described from its public pages as at 6 November 2026, and none has paid to appear here.* If you do not yet know whether your packaging is affected, start with our test [PPWR: who is affected?](https://projetcelsius.com/en/blog/ppwr-who-is-affected/). ## What does the PPWR require of a company? [Regulation (EU) 2025/40](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R0040) on packaging, known as the **PPWR** (Packaging and Packaging Waste Regulation), has applied **since 12 August 2026** (Article 71). It attaches its obligations to **roles**: manufacturer, importer, distributor. The **manufacturer** carries most of them. It places on the market only packaging that complies, assesses that conformity itself or through a third party acting on its behalf, **without a notified body**, then draws up **the technical documentation** and **the EU declaration of conformity** (Article 15), as summarised in [our PPWR guide](https://projetcelsius.com/en/blog/ppwr-packaging-regulation-guide/). ### One manufacturer per packaging item The manufacturer is not necessarily the company that produces the packaging. The [Commission guidance document](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:C_202603084) of 10 June 2026 states that **there is only one manufacturer** in a supply chain. For sales packaging, it is in principle **the company that fills it**, often the brand owner. For transport packaging, such as a shipping box or pallet wrap, it is in principle the company that makes it, unless it bears the name or trade mark of its user. An importer or distributor that sells under its own brand **becomes a manufacturer** in turn (Article 21). ### The 6 steps to PPWR compliance Compliance takes **6 steps**, in-house or with a service provider: - List the packaging placed on the market, type by type, from the body to the label, down to the transport box and film. - State, for each packaging type, who is the manufacturer, importer or distributor, and who is the producer liable under extended producer responsibility (EPR). - Gather the evidence from suppliers, who must provide the manufacturer with **all the information and documentation needed** (Article 16). - Draw up the technical documentation (Annex VII) and the EU declaration of conformity (Annex VIII) for the types of which the company is the manufacturer. - Keep these documents for **5 years**, or 10 years for reusable packaging, and hand them over **within 10 days** of a reasoned request from an authority. - Join a producer responsibility organisation (PRO, éco-organisme in French) of the [French EPR scheme for professional (B2B) packaging](https://projetcelsius.com/en/blog/france-epr-professional-packaging-2027/) **before 31 December 2026**, if the company is its producer. The documents themselves follow a model set by the Regulation: our article on [the PPWR declaration of conformity](https://projetcelsius.com/en/blog/ppwr-eu-declaration-of-conformity/) goes through it heading by heading, and the one on [the technical documentation](https://projetcelsius.com/en/blog/ppwr-technical-documentation-supplier-evidence/) sets out what evidence to request from suppliers. The 2030 recyclability criteria **are still awaiting** Commission acts, as [the PPWR timeline](https://projetcelsius.com/en/blog/ppwr-timeline-deadlines/) shows, whereas the [PFAS limits for food-contact packaging](https://projetcelsius.com/en/blog/pfas-food-packaging-ppwr-limits/) already apply. > Whoever drafts the declaration of conformity, the manufacturer remains solely responsible for it. ## How much of the work can you do in-house? ### The inventory and the EPR membership Part of the work requires **no outside expertise**, provided your data is up to date: - The list of packaging, if the ERP or a spreadsheet already tracks the items sold, their components and their suppliers. - Membership of a PRO of the French EPR scheme for professional packaging, done online on its portal, as described in [our comparison of Citeo and Léko (in French)](https://projetcelsius.com/blog/citeo-ou-leko-choisir-eco-organisme/). - A first inventory using the free guides and templates that the PROs make available to their members. - The request for evidence from suppliers, with a standard letter that covers each component, its production site and the period covered. ### The cases that call for a written opinion The work becomes harder when the answer depends on **a contract, a brand or a flow of goods**: - The PPWR manufacturer and the EPR producer **are not always the same company**, especially for a [seller established outside France](https://projetcelsius.com/en/blog/french-epr-authorised-representative/). - An importer or distributor that sells under its own brand, or modifies packaging, takes on the manufacturer's obligations without always knowing it. - A supplier replies with **a general certificate** that names neither the component, nor the site, nor the period, and therefore proves nothing. - Within a group, the same packaging can have a different role depending on the subsidiary that buys it, fills it or resells it. - A [micro-enterprise](https://projetcelsius.com/en/blog/ppwr-small-businesses-obligations/) may see the manufacturer's obligations pass to its supplier, subject to conditions. These cases call for **a written opinion**, based on an article of the Regulation or of the Commission guidance. ## What are the risks without a declaration of conformity? ### Distributors that stop selling The first risk comes from customers. Before selling, the distributor checks the labelling, the identification of the manufacturer and the producer's registration in the register (Article 19). If it has reason to believe the packaging does not comply, it **refrains from selling it** until it has been brought into conformity. In practice, a supplier that cannot show its documents to the customer who asks for them **risks being delisted**. ### Withdrawal from the market A missing or incorrectly drawn up declaration, or incomplete technical documentation, is a **formal non-compliance**: the Member State requires it to be brought to an end and may, if it persists, **restrict the sale** of the packaging or **have it withdrawn** (Article 62). A manufacturer that discovers a non-compliance must itself correct, withdraw or recall the packaging, and inform the authorities (Article 15). ### Penalties still to be set The Regulation leaves it to Member States to set their penalties **by 12 February 2027 at the latest** (Article 68). As at 6 November 2026, **no French penalty specific to the PPWR has been passed**: the [bill adapting French law to EU law](https://www.assemblee-nationale.fr/dyn/17/dossiers/DLR5L17N53140), adopted by the French Senate on 18 February 2026, is still awaiting the National Assembly. Our article on [PPWR penalties](https://projetcelsius.com/en/blog/ppwr-penalties-non-compliance/) details what already applies and what is still at the draft stage. EPR already has its own. The French Environmental Code ([Article L. 541-9-5](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000041583338)) provides for an administrative fine of up to **€7,500 per unit or per tonne** of product for a legal entity that fails to meet its EPR obligations, such as membership, and a periodic penalty payment of up to €20,000 per day; the [unique identifier (identifiant unique, or IDU), the EPR registration number](https://projetcelsius.com/en/blog/french-epr-unique-identification-number/), must also appear on its documents. The [amendment adopted by the Senate](https://www.senat.fr/enseance/2025-2026/348/Amdt_513.html) would raise this ceiling to **1% of worldwide turnover**. These are **EPR penalties**, not PPWR penalties. ## Which providers offer PPWR compliance support? 7 types of provider help companies with the PPWR, from large audit firms, which serve groups, to producer responsibility organisations, free of charge for their members. ### Large audit firms and inspection bodies They are aimed first at **groups operating in several countries**. [EY](https://www.ey.com/fr_fr/insights/climate-change-sustainability-services/ppwr-pourquoi-les-entreprises-doivent-agir-des-maintenant-sur-leurs-emballages) advertises role qualification and a roadmap in France; [Deloitte](https://www.deloitte.com/cz-sk/en/services/consulting/services/ppwr.html) and [KPMG](https://kpmg.com/pl/pl/uslugi/esg-environmental-social-and-governance/ppwr-pack-kompleksowe-wsparcie-w-spelnieniu-wymogow-regulacyjnych.html) publish PPWR offers outside France. Inspection bodies add laboratory testing: [Bureau Veritas](https://www.cps.bureauveritas.com/ppwr/EU-PPWR-compliance-solution) maps roles along the supply chain and reviews the declaration, [SGS](https://www.sgs.com/en/services/eu-ppwr-compliance-packaging-testing-recyclability-and-documentation) offers testing and gap analysis. All work **on quotation**. None publishes prices. They cover **several sales countries** and integration into reporting, which serves groups first. ### Technical consultancies, including Projet Celsius They target **SMEs and mid-cap companies (ETI in French)** that want to delegate the work, then take it back. Projet Celsius carries out the 6 steps described above for the company and hands over **the packaging table**, an example of which, built for this article, is shown here, together with the organisation that will keep it up to date. Projet Celsius is **Qualiopi-certified** (the French quality certification for training providers) for its training activities ([certificate](https://projetcelsius.com/qualiopi/certificat-qualiopi-projet-celsius-2026-2029.pdf)), and its consultants teach for the Institut de Formation Carbone. The firm **does not provide legal advice** and does not cover EPR registers on every continent. Other French consultancies work in this segment: [RecycleMe](https://recycleme.fr/expertises-eco-conception/audit-ppwr/) sells a PPWR checklist **from €995 excl. VAT**, and from €3,250 excl. VAT with training; [EcoMundo](https://ecomundo.eu/blog/ppwr-reglement-emballages-obligations-entreprises) offers to map packaging and roles, on quotation. ### Tool-based consultancies and lawyers Some EPR compliance operators sell advice backed by a tool. The Landbell group offers a [role analysis at €1,800](https://click-and-comply.com/ppwr-services/ppwr-economic-operator-assessment-prdIE-HHXX-0025-ctgppwr) and **[workshops from €1,999 to €4,999 excl. VAT](https://erp-recycling.org/wp-content/uploads/2026/09/H2C_ProductSheet_PPWR-2026_EN.pdf)**, covering 2 or 3 packaging items for the first 2 packages. The Dutch firm [RegSurance](https://regsurance.com/) combines advice with its PaxHub platform, on quotation. Lawyers, such as [Heuking](https://www.heuking.de/en/consulting-focuses/packaging-and-packaging-waste-regulation-ppwr.html) in Germany, handle **a disputed role, a contract or litigation**. Their page describes **legal qualification**, contracts and registrations. A technical consultancy brings them in when a role is disputed. ### Software, producer responsibility organisations and training **PPWR software** produces the documents from what the company enters, including its role for each packaging item. Generators charge for the declaration **from €49** ([PPWR-DOC](https://ppwr-doc.com/)), platforms [€29 to €299 a month](https://ppwrconnect.com/pricing) at PPWR Connect, and up to [€799 a month](https://h2compliance.com/ppwr-declaration-of-conformity-software/) for 10,000 declarations at SimpliDoC. Some carbon accounting platforms add a PPWR module: [Greenly](https://greenly.earth/produits/conformite-ppwr) advertises importing bills of materials from the ERP, chasing suppliers and exporting declarations, with no published price. The software publisher Polygon One [says so itself](https://polygon-one.com/en/ppwr-manufacturer-vs-producer): assigning roles remains the customer's decision, which the tool maps **without qualifying it legally**. The **PROs** approved in France on 3 June 2026 for professional packaging help their members free of charge. [Citeo Pro](https://www.citeopro.com/cap-emballages-pro/) offers its Cap Emballages Pro kit, [Léko Pro](https://lekopro-organisme.fr/nos-missions-et-accompagnement/) its MyLéko space, and [Twiice](https://www.twiice.org/outils/) an online diagnostic and EPR declaration templates. Their tools serve **the EPR declaration**. That leaves **training**, so that the purchasing and quality team can do the work itself, as set out in [our PPWR training programme](https://projetcelsius.com/en/blog/ppwr-training-for-teams/). ## How much does PPWR compliance cost? **No public price list** covers a full compliance project. At Projet Celsius, for an SME, it costs **around €5,000 excl. VAT** for the inventory and the roles. With EPR, the technical files for the types of which the company is the manufacturer and follow-up, allow **€10,000 to €15,000 excl. VAT**, depending on the number of product references. Each engagement is priced on quotation, as are the life cycle assessment (LCA) of a packaging item or the pathway towards the 2030 targets when the company asks for them. The price depends on the number of product references, and above all on **the number of packaging types** they share: - The number of distinct packaging types: 30 product references sharing 3 formats are dealt with faster than 10 references with 10 formats. - The number of suppliers to chase, and the quality of the evidence they have already sent. - The number of companies and sales countries, which multiplies the cases to examine and the EPR declarations. - The share of borderline cases: group brand, modified packaging, purchases from outside the Union, flows between subsidiaries. The headline prices on the market rarely cover the same scope: a generator charges for the document, a workshop covers 2 or 3 packaging items, a subscription gives access to the tool without the qualification work. A comparison only makes sense **for the same inventory and the same deliverable**. Handling compliance and EPR **on the same inventory** avoids paying 2 times for the same data collection. ## Where to start, depending on company size For us at Projet Celsius, a PPWR provider should be judged on 2 points: it tells you, for each packaging item, whether you are its manufacturer, and it leaves you a file your team knows how to update. The criteria for choosing between 2 consultancies are in our article on [choosing a PPWR consultancy](https://projetcelsius.com/en/blog/ppwr-compliance-audit/). > **Our recommendation** Have **the first inventory done by a technical consultancy**, then handle the updates in-house. > - For an SME or a mid-cap, we recommend **a technical consultancy for the first inventory**, and that is the work we do: the inventory and the roles, the supplier evidence, the EPR declaration, then training for the team that will handle the updates. > - A micro-enterprise **should first check** whether its supplier is the manufacturer in its place. The PRO's guides and a generator are often enough. > - A group operating on several continents will be better served by **a large audit firm** or a multi-country EPR operator. > - A legal question, a disputed role or a supplier contract is a matter for **a lawyer**: we do not provide legal advice. Software comes **afterwards**, once the inventory is done: it **keeps the declarations up to date**. To train the team that will take over, our [PPWR training programme](https://projetcelsius.com/en/blog/ppwr-training-for-teams/) details the modules. ## Key takeaways - Since 12 August 2026, every packaging type must have its technical documentation and its EU declaration of conformity, drawn up by its manufacturer. - A company with up-to-date data can handle the inventory, EPR membership and evidence requests on its own. Working out which packaging it is the manufacturer of more often requires help. - The immediate risk is commercial, because a distributor that doubts the conformity of a packaging item must refrain from selling it. - 7 types of provider offer help, from the large audit firm to the producer responsibility organisation. The right choice depends on the size of the company and the number of packaging types. - At Projet Celsius, allow around €5,000 excl. VAT for an SME in the simple version, and €10,000 to €15,000 excl. VAT with EPR, the files and follow-up. To compare 2 consultancies, our article on [the PPWR compliance audit](https://projetcelsius.com/en/blog/ppwr-compliance-audit/) gives the questions to ask and the deliverable to require. ## Frequently asked questions ## Frequently asked questions ### Who signs the PPWR declaration of conformity? The manufacturer of the packaging. The Commission guidance document of 10 June 2026 states that the declaration is drawn up by the manufacturer or by an authorised representative appointed in writing, and that the manufacturer remains solely responsible for conformity. For sales packaging, the manufacturer is in principle the company that fills it, often the brand owner. A distributor that sells under its own brand becomes a manufacturer. ### Is PPWR software enough to be compliant? Software produces the declarations and keeps them up to date, once the company has entered its packaging, its suppliers and its role for each item. It does not decide that role for the company, nor borderline cases such as a group brand or modified packaging. It is enough when the company already knows which packaging it is the manufacturer of. ### Do I need a lawyer for PPWR compliance? Not for most packaging: establishing who the manufacturer of each packaging item is, gathering the evidence and drafting the documents is technical work. A lawyer becomes useful for a role disputed with a supplier, a contract clause or an inspection that turns into litigation. A technical consultancy will tell you when to bring one in. ### Will my producer responsibility organisation help me with the PPWR? Partly. In France, Citeo Pro, Léko Pro and Twiice provide their members with free guides, templates and inventory tools. They help declare EPR tonnages. They do not analyse each packaging item to say who its manufacturer is and what evidence to gather: that work remains with the company or its service provider. ### What should I do if a supplier does not send its evidence? The Regulation requires suppliers of packaging and materials to provide the manufacturer with all the information and documentation needed (Article 16). A written request that covers the component, the site and the period, with a reply date, is the first step. If there is no reply, the company documents its reminders and considers another supplier. ### When should I start? Now, if you have not already. The Regulation has applied since 12 August 2026: packaging placed on the market since that date must already have its declaration and its technical documentation. Membership of a PRO of the French EPR scheme for professional packaging must be completed before 31 December 2026, and France must set its penalties by 12 February 2027 at the latest (Article 68). ## Sources - European Parliament and Council, [Regulation (EU) 2025/40 of 19 December 2024 on packaging and packaging waste](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R0040), Articles 3, 15, 16, 19, 21, 39, 62, 68 and 71, Annexes VII and VIII. - European Commission, [guidance document on Regulation (EU) 2025/40 (C/2026/3084)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:C_202603084), 10 June 2026, section 2 on the definition of the packaging manufacturer. - European Commission, DG Environment, [FAQ on Packaging and Packaging Waste Regulation](https://environment.ec.europa.eu/publications/faq-packaging-and-packaging-waste-regulation-ppwr_en), 3 August 2026. - French Senate, [amendment No. 513 rect. to the bill adapting French law to European Union law](https://www.senat.fr/enseance/2025-2026/348/Amdt_513.html) (in French), adopted on 16 February 2026; National Assembly, [legislative file](https://www.assemblee-nationale.fr/dyn/17/dossiers/DLR5L17N53140) (in French), consulted on 6 November 2026. - Légifrance, [French Environmental Code, Article L. 541-9-5](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000041583338), version in force since 25 August 2021 (extended producer responsibility penalties), consulted on 6 November 2026. The Légifrance pages are in French.