PPWR training: which programme should you choose for your teams?
Who to train, and on what?

The packaging regulation, known as the PPWR (Packaging and Packaging Waste Regulation), has applied since 12 August 2026, and none of its 71 articles mentions training. It does, however, require the manufacturer to prove, package by package, that each requirement is met. That evidence originates in several departments: purchasing obtains it from suppliers, R&D produces it when designing, quality assembles it and marketing prints it on the label.

A useful programme therefore depends on 2 things: the role the regulation gives the company, which determines what it must prove or check, and the packaging it places on the market, which determines which requirements apply to it. Format, duration and funding are decided afterwards. If the question is still whether the company is affected at all, the test PPWR: am I affected? comes first.

1Who needs PPWR training, and on what?

The regulation places each company in one or more roles, each with its own obligations. A serious programme therefore starts from what the company does with its packaging, not from the table of contents of the text.

Manufacturer, importer, distributor or supplier

Our guide to the regulation sets out these 4 roles, which can be summarised as follows:

• The manufacturer has the packaging designed or made under its own name or brand, even if it produces nothing itself. It draws up the technical documentation and signs the EU declaration of conformity (Articles 3 and 15).
• The importer places on the market packaging that comes from a third country. It checks that the manufacturer has done this work, keeps a copy of the EU declaration of conformity available to the authorities and makes sure it can supply them with the technical documentation, for 5 or 10 years (Article 18).
• The distributor checks, before selling, the labelling of the packaging and the producer's entry in the producer register (Article 19).
• The packaging or materials supplier gives the manufacturer all the information and documentation it needs to demonstrate conformity (Article 16).

A single company often holds 2 roles at once. An importer or distributor that sells under its own brand, or that modifies the packaging to the point where its conformity may be compromised, becomes a manufacturer and takes on its obligations (Article 21). Micro-enterprises have a separate regime: when their supplier is established in the Union, the supplier bears the manufacturer's obligations under Article 15 (paragraph 12). A seller established outside France often goes through an authorised representative.

One part of the evidence per team

The tool above sets out, role by role, what each team must be able to do. At a manufacturer, quality and purchasing come first: the technical documentation must exist before the packaging is placed on the market (Article 15), and it depends on the documents that suppliers are required to provide (Article 16). R&D follows, because its requirements mostly arrive in 2030 (Articles 6, 7 and 10), then marketing for the label and claims (Articles 12 and 14), and logistics for empty space and the reuse of transport packaging (Articles 24 and 29).

These teams do not need the same amount of training time. A short common core, which sets out the logic of the regulation and the evidence chain, followed by modules for each function, covers the need better than an identical day for everyone. Legal follows the core and reviews supplier contracts, through which the documents arrive.

2Is PPWR training mandatory?

No. The regulation requires no training and provides for no certification of individuals. It requires a result: packaging that complies with Articles 5 to 12, demonstrated by technical documentation and an EU declaration of conformity, as our article on the declaration of conformity explains.

What the regulation requires instead

Conformity is demonstrated through internal production control, module A of Annex VII: the manufacturer ensures and declares, under its sole responsibility, that the packaging meets the requirements, with no third-party body. It takes account of design changes and standards, and repeats the assessment when conformity may be compromised (Article 15(4)). This step requires teams that recognise what changes conformity: a new ink, a replacement supplier, a seal in a different material.

What argues for training now

The pressure comes first from downstream. Before selling, the distributor must check the labelling and the producer's entry in the register (Article 19). Questions therefore travel back up to brands and their suppliers, and a team that cannot answer them with dated documents holds up a listing.

It then comes from the authorities. Technical documentation that is missing, incomplete or erroneous is a formal non-compliance, which the Member State requires to be corrected (Article 62). Each Member State must set its penalties by 12 February 2027 at the latest (Article 68), and the manufacturer hands over its documentation within 10 days of a reasoned request (Article 15(10)).

3What should a good training programme contain?

A programme is judged by what trainees can do when they leave, on their own packaging. 3 elements separate useful training from a presentation of the regulation.

The company's packaging as raw material

The training starts from an inventory: formats, materials, suppliers, countries of sale, and sales, grouped and transport packaging. A food tray, a cosmetics carton and a stretch-wrapped pallet do not fall under the same articles, and the packaging formats banned in 2030 cover only certain formats. A serious provider asks for this inventory before the session and builds its exercises on it.

The first exercise fits on a table: a real package, on which each department identifies the markings that concern it, then the evidence that would have to be shown for each.

Supplier documents, read in the session

The most useful exercise is to read together, as a group, real documents received: a food contact declaration of compliance, a recycled content certificate, a technical data sheet. Trainees learn to say what the document proves, what it does not prove and what to ask for again. The gaps found most often are a document that covers another component, another site or a past period, as the review of supplier evidence shows.

Dated course materials, article by article

Every date given in training must come with its article and, where applicable, the act that conditions it. The harmonised label is the typical example: the Commission was to adopt its implementing act by 12 August 2026 at the latest (Article 12(6)). The obligation applies on the later of these 2 dates: 12 August 2028 or 24 months after that act. Course materials that announce "mandatory labelling in 2028" without this reservation age badly.

The other requirements also arrive in stages, which the PPWR timeline sets out one by one:

• Since 12 August 2026, packaging in contact with food can no longer exceed the PFAS (per- and polyfluoroalkyl substances) thresholds set by Article 5(5).
• From 2030, the new recyclability criteria, the minimum recycled content of plastic parts and the minimisation of weight and volume apply, with some dates depending on acts still awaited.
• In 2035, packaging will in addition have to be recycled at scale, using a method that the Commission has yet to set (Article 6).

Warning signs

A training offer deserves to be set aside when one of these signs appears:

• The programme is identical for all teams and all sectors, with no prior question about the company's packaging.
• The course materials still present the 1994 directive as the text in force, although it has been repealed since 12 August 2026, apart from a few transitional provisions (Article 70).
• The offer promises a "PPWR certification" of people or packaging, which the regulation nowhere provides for.
• The trainer talks about the text without ever talking about evidence, with no exercise on a supplier document and no technical documentation shown.
• Nothing assesses what has been learned, and the session ends with a simple attendance certificate.

The third sign is the most misleading. A company can have its file reviewed by a third party, but no text issues a PPWR certificate: conformity remains the manufacturer's responsibility. Only the recycled content of plastic packaging could require a third-party audit, if the act due by 31 December 2026 at the latest provides for it (Article 7). For marketing, the same caution applies to the claims "recyclable" or "eco-designed", governed by Article 14 and by the law on environmental claims, which a claims audit can review before a reprint.

4In-house, open-enrolment or online: which format to choose?

The format depends on the number of people to be trained and on the need to work on the company's own documents. The 3 formats can be combined: an online module can prepare a classroom session.

In-house, to work on your own documents

In-house training (intra-company) brings together the teams of a single company. It is the only format in which the exercises use its own packaging and supplier documents, under a confidentiality agreement if needed, and it is justified as soon as several departments are affected. The example below, built for this article, shows how such a day would be organised for a food brand that has its trays and films made under its own name.

This breakdown is not a standard: it shows where the time goes. The core takes 1 hour 30 minutes, marketing and logistics leave before noon, and the afternoon brings together purchasing and quality to turn the gaps into requests to suppliers.

Open-enrolment, for one person on their own

Open-enrolment (inter-company) training brings together trainees from several companies around a common programme. It suits one person on their own, a quality manager for example, who needs to understand the regulation before organising what follows in their own company. Its exercises remain generic, since nobody brings their confidential documents.

The online module, for the common core

The online module passes on the logic of the regulation to many people and can be updated faster than printed materials, but it does not replace the exercise on documents. For R&D, it can be complemented by work on packaging eco-design, and the same reasoning applies to other subjects, such as choosing LCA training.

Questions to ask the provider

Whatever the format, 5 questions are enough to compare 2 proposals:

• Which of the company's packaging and supplier documents will be used for the exercises, and by what date do they have to be sent?
• Which modules are aimed at which teams, and how many hours does each of them last?
• How do the course materials cite the articles and the acts still awaited, and who updates them when they are published?
• What experience does the trainer have of conformity files and of reviewing supplier documents?
• How is learning assessed, and under which activity declaration number (the French training provider registration number) is the provider registered?

5How much does PPWR training cost, and who funds it in France?

No public price list sets the price of PPWR training. It depends mainly on the preparation time on the company's own documents, the number of groups and modules, and the format. Funding, by contrast, follows public rules, which can be checked before signing.

Qualiopi, the condition for funding

A training provider funded by an OPCO (a French sector-based skills operator), the State, a region, the Caisse des dépôts (a French public financial institution) or France Travail (the French public employment service) must be certified against criteria set by decree (Article L. 6316-1 of the Labour Code). This is the certification known under the brand Qualiopi. According to the Ministry of Labour, it attests to the quality of the training process, not to the trainer's mastery of the PPWR: the questions in the previous section remain necessary.

The OPCO for companies with fewer than 50 employees

For companies with fewer than 50 employees, the OPCO funds the actions of the skills development plan, the pay of the employee in training and ancillary costs (Article L. 6332-17). The terms and priorities of funding are set by the board of directors of each OPCO: the request is prepared before the session, with the programme and the quote. From 50 employees, this article does not apply, and the industry branch's OPCO states what it covers.

The CPF, rarely

For this type of training, the personal training account (CPF) funds only actions that lead to a certification registered in one of the national registers of certifications (Article L. 6323-6). A short PPWR course does not qualify, unless the provider has had it registered: its course sheet then quotes the registration number.

For us at Projet Celsius, successful PPWR training is measured the following week: the buyer knows which document to ask for again, quality knows where to file it, marketing knows what it may write. We build it in-house, from the company's own packaging and supplier documents, with course materials in which every date cites its article. Projet Celsius is Qualiopi-certified for its training activities, and our PPWR support service takes over when the file itself has to be put together.

6Key takeaways

• The PPWR requires no training, but its technical documentation involves purchasing, R&D, quality, marketing and logistics.
• The company's role, manufacturer, importer, distributor or supplier, decides what each team must be able to do.
• A good programme works on the company's own packaging and supplier documents, with dates tied to their article.
• No "PPWR certification" exists: an offer that promises one should raise a flag.
• In France, Qualiopi conditions public and pooled funding, and the OPCO funds companies with fewer than 50 employees.

To prepare the review of documents received, see how to have your suppliers' evidence checked; for transport packaging, see the reuse targets.

Further resources

Frequently asked questions

1Is PPWR training mandatory?

No. Regulation (EU) 2025/40 requires no training and provides for no certification of individuals. It requires the packaging to comply and the manufacturer to demonstrate it through technical documentation and an EU declaration of conformity. Training the teams that produce this evidence is one way of achieving that, not an obligation of the text.

2Who should be trained first on the PPWR?

It depends on the company's role. At a manufacturer, quality or the regulatory department, which assembles the technical documentation, and purchasing, which obtains the supplier documents, come first. At a distributor, it is the teams that list products and check the labelling and the producer's entry in the register.

3Is there a PPWR certification?

No. The regulation provides neither for certification of individuals nor for a certificate issued by a third party for packaging. Conformity is demonstrated through internal production control, carried out by the manufacturer under its sole responsibility. Only recycled content could require a third-party audit, if the act expected at the end of 2026 provides for it. A training course issues an attestation, never a PPWR certification.

4How long does PPWR training last?

No text sets a duration. A short common core on the logic of the regulation, followed by modules for each function, makes it possible to train each team in its share of the evidence without tying everyone up. The time that matters most is the time spent on exercises on the company's own packaging and documents.

5Can a French OPCO fund PPWR training?

Yes, for a company with fewer than 50 employees, if the provider is Qualiopi-certified. The OPCO then funds the training costs, the employee's pay and ancillary costs, on terms set by its board of directors. The request is prepared before the session.

6Do you have to repeat the training when the Commission's acts are published?

It needs at least updating. The harmonised label, recyclability and recycled content depend on delegated or implementing acts that set the methods and sometimes the dates. Course materials that cite their articles can be updated in a few pages, without redoing the whole session.

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