PPWR: which companies are affected and in what role?

There is no list of companies affected by the Packaging and Packaging Waste Regulation (PPWR) to look up. There are 2 criteria, neither of which concerns your size: you place a packaged product on the EU market and you are its first link established in the Union. If you meet the 2 criteria, you are in scope. The tool below identifies your position in a few clicks, giving you a verdict, the urgency and the first action to take.

The following sections explain what a producer is, who signs what, the 2 decisive criteria, the timeline and the most exposed business profiles. The complete PPWR guide covers the regulation as a whole.

1If you place a packaged product on the EU market, you are affected

As soon as you place a packaged product on the EU market, you fall within the scope of the PPWR, whether or not you manufacture your packaging and whatever your size. Neither your sector nor your turnover matters: the regulation looks at who makes the product available and under whose name.

Why your role matters more than whether you are affected

The PPWR assigns obligations by role rather than company size. You come within scope as soon as your name appears on a packaged product sold in the Union. The answer to whether you are affected is almost always yes; what remains to establish is your role and how urgently you need to act: the brand signing the declaration of conformity or the importer and distributor checking someone else's.

What if I do not manufacture my packaging?

You are still affected. The PPWR uses a broad definition of manufacturer: the party manufacturing the packaging or packaged product, but also the party that has it manufactured and sells it under its own name or trademark. Buying ready-made boxes does not take anyone out of scope. The packaging supplier provides technical evidence; it does not relieve you of responsibility: if the packaged product is sold under your brand, the declaration of conformity remains yours and the technical documentation must be available on request. This resembles the approach in Empowering Consumers for the Green Transition (EmpCo), where responsibility follows the party addressing the market rather than the subcontractor. There is an important exception for makers and craftspeople: if you are a micro-enterprise under Recommendation 2003/361/EC (fewer than 10 employees and turnover or a balance sheet total below €2 million), Article 15(12) of the regulation transfers conformity obligations to your packaging supplier if it is established in the EU. The general definition of manufacturer in Article 3 goes further when that supplier is in the same Member State as you: the supplier is then recognised as the packaging manufacturer under the regulation's general definition. For a French micro-enterprise, the clearest route is therefore a French supplier. See our dedicated article: PPWR: what obligations apply to a micro-enterprise or independent maker?.

2How the PPWR defines a producer

The producer is the company that makes a packaged product available on the EU market for the first time. The regulation then assigns the roles. The manufacturer in the broad sense, meaning the brand under which the packaged product is sold, including private labels, signs the declaration of conformity. This is a legally enforceable document retained for 5 years for single-use packaging and 10 years for reusable packaging. The importer checks the declaration and keeps a copy.

The roles of the brand, importer and distributor

3 types of business often become directly responsible despite never operating a packaging machine:

• The brand whose name appears on the product signs the declaration of conformity, even if the packaging is outsourced.
• The importer bringing a finished packaged product into the EU is the first link established in the Union: it must check that the manufacturer has assessed conformity and keep a copy of the manufacturer's declaration. It signs the declaration itself only if it sells under its own brand.
• The distributor selling under its own name (private label) is treated as the packaged product's manufacturer: it signs the declaration.

Transport packaging counts too

The regulation covers more than sales packaging. Shipping parcels, void fill and grouped overpackaging also fall within scope: e-commerce businesses are responsible for their transport packaging, with an empty space ratio capped at 50% from 1 January 2030 at the earliest and reuse targets that exclude cardboard boxes. This is what an inspector sees when the product arrives by parcel.

3The 2 criteria that determine whether you are in scope

The 2 criteria must both be met:

• you put a packaged product into circulation in the EU, whether a product on a shelf, a shipped parcel or transport packaging;
• you are its first link established in the Union: the brand, importer or distributor selling under its own name.

If either criterion is missing, you are outside the direct scope. If you meet both, you are in scope, whatever your size.

The trigger: placing products on the EU market

The PPWR is a product regulation: making products available on the Union market triggers the obligation, just as a product safety requirement or CE marking does. A website delivering to France is enough to fall within scope for the relevant part of its business. Where the packaging is manufactured makes no difference: the regulation looks at where the packaged product is sold.

Why your size does not matter

There is no employee or turnover threshold for the qualitative obligations: recyclability, recycled content and labelling. A sole trader under France's auto-entrepreneur scheme is treated in the same way as a listed group. This is a clear difference from the Corporate Sustainability Reporting Directive (CSRD), which the Omnibus Directive (EU) 2026/470 limits to companies with more than 1,000 employees and €450 million in turnover, once transposed in France (by 19 March 2027 at the latest). There are only targeted derogations, particularly from reuse targets for micro-enterprises. The regulation also includes a transfer clause specifically for micro-enterprises. Articles 3 and 15(12) transfer conformity obligations to the packaging supplier if it is established in the EU (paragraph 12) and go as far as reclassifying it as the manufacturer under the general definition if the parties are in the same Member State (Article 3). For a maker buying boxes in France, the PPWR mainly concerns their supplier: the real issue becomes joining the French extended producer responsibility (EPR) system through an EPR scheme (Citeo or Léko) and registering on the national packaging registers in the EU countries where they sell. Full details: PPWR for a micro-enterprise or independent maker.

4When the rules apply and who is most exposed

The regulation applies in several waves and some business profiles are more exposed than others.

The timeline in 3 dates

• 12 August 2026: full application. Every packaging type must be covered by a signed declaration of conformity and up-to-date technical documentation, and food packaging must meet the per- and polyfluoroalkyl substances (PFAS) thresholds in Article 5.
• 12 August 2028: harmonised sorting labels shared by the 27 Member States.
• 1 January 2030: the turning point. Banned formats (Annex V) and the first reuse targets begin to apply; recyclability of all packaging and recycled plastic content requirements follow from this date at the earliest, or later if the Commission's acts are delayed. The full sequence is in the deadline timeline.

The most exposed business profiles

Everyone placing a packaged product on the EU market is in scope, but 4 business profiles face the greatest exposure because their packaging combines plastics, sensitive formats and volume:

• Importers, the first link established in the EU, must check the manufacturer's declaration of conformity and keep a copy. They sign it themselves if selling under their own brand.
• E-commerce is subject to a maximum empty space ratio of 50% from 2030 at the earliest and reuse targets of 40% in 2030 for reusable transport packaging (crates, boxes and pallets), with cardboard boxes excluded.
• Private labels and retail businesses sign as manufacturers and face the banned formats in Annex V.
• In hotels and food service, miniature toiletries and disposable plastic packaging for consumption on the premises leave the market on 1 January 2030.

5Our view at Projet Celsius

From our perspective as practitioners, the PPWR has 3 effects:

• It extends the obligation to small businesses, whereas the CSRD stops at large organisations.
• It ultimately affects everyone, as the declaration of conformity reaches back along the chain, including packaging suppliers.
• The practical question becomes which of my catalogue items meet the 2030 threshold.

Everything depends on the data. The first deliverable is an inventory of packaging by catalogue item, before any legal memorandum: material, weight, recyclability, recycled content and format. For a mid-cap company (ETI in French) with several hundred catalogue items, allow €15,000 to €30,000 over around 3 months; a small or medium-sized enterprise (SME) with a short catalogue can do it in-house in a few weeks. This is the only no-regret investment in the project: it separates what is already compliant from what is not and avoids redesigning everything. Packaging redesign takes 6 to 18 months. The next stage, measuring and choosing between options, is described in our packaging eco-design method. To scope this work, the Celsius PPWR diagnostic maps your packaging families to the requirements to examine and the available evidence.

6Key takeaways

• There is no size threshold: a sole trader under France's auto-entrepreneur scheme is affected just like a listed group as soon as a packaged product is sold in the EU. However, a micro-enterprise sourcing packaging from a supplier established in the EU transfers conformity obligations to that supplier (Article 15(12)).
• The PPWR uses a broad definition of manufacturer, meaning the brand under which the packaged product is sold, including private labels: it signs the declaration of conformity, which the importer checks and retains.
• The timeline has 3 waves: documentation and PFAS thresholds since 12 August 2026, labelling in 2028, banned formats from 1 January 2030 and recyclability and recycled content from that date at the earliest.
• Penalties will be national, but risks already exist: withdrawal from the market, EPR penalties and exclusion from tenders.
• If you ship to other EU countries, each country has required registration on its producer register (Article 44, through the existing national registers until PPWR registers are available) and, outside your country of establishment, a local EPR authorised representative (Article 45), since 12 August 2026. Details for a maker selling remotely. In France, the rule has been in force since 10 July 2026: every producer not established in France must appoint an EPR authorised representative there (Article L. 541-10-9-1 of the French Environmental Code), for all EPR schemes. The full mechanism is explained here.
• If you are unsure about exports, check your situation with 3 questions.

The PPWR has applied since 12 August 2026: the first practical step is to identify which catalogue items are at risk now. Start the inventory, address Annex V formats and multi-material plastics first and keep the deadline timeline to hand for what follows.

Further resources

Frequently asked questions

1Is a container that forms part of the product, such as a candle jar, packaging?

Not always; this is the first question to resolve. The regulation defines packaging by its function: containing, protecting, handling, delivering or presenting a product (Article 3). An item needed to contain or preserve the product throughout its life is not packaging when it is an integral part of the product. Annex I gives an indicative list: items that are not packaging include graveyard lights (containers for candles), toolboxes, printer cartridges and flowerpots intended to be sold with the plant. In our reading, a jar designed to hold a candle throughout its use follows the same logic. Beware of misleading comparisons: a sweets box is still packaging, and a tea bag or coffee capsule is packaging under the regulation. When your container is not packaging, it requires neither a declaration of conformity nor a packaging EPR fee (éco-contribution): your obligations concern the shipping box and void fill. There are two qualifications: describing such an object as reusable is an environmental claim (in French) that must remain accurate, and what happens to it at the end of its life must be described accurately.

2Can I rely on my supplier's statement that the packaging is compliant?

No. Your supplier may provide technical evidence about the packaging it manufactures, but if the packaged product is sold under your name or trademark, you sign the declaration of conformity and answer to the enforcement authority. The supplier contract sets out your remedies; it never transfers regulatory responsibility.

3Does the PPWR apply to small businesses?

Yes, in principle: the PPWR provides no general size exemption from qualitative obligations (recyclability, recycled content and labelling). However, if you are a micro-enterprise (fewer than 10 employees and turnover below €2 million under Recommendation 2003/361/EC) and buy packaging from a supplier established in the EU, Article 15(12) transfers conformity obligations to that supplier; Article 3 even reclassifies it as the manufacturer if the parties are in the same Member State. Your real issue then becomes joining the French EPR scheme (Citeo or Léko, with a flat fee for small volumes) and registering on the national packaging registers in the EU countries where you sell. See our dedicated article: PPWR: what obligations apply to a micro-enterprise or independent maker?.

4Does the PPWR apply if I mainly sell outside the EU?

Yes, for the share of your packaged products made available on the EU market. An accessible website delivering to Europe is enough. Presence on the European market matters, rather than the share of your business it represents.

5Does the PPWR apply in France without a French law?

Yes. It is a European regulation: it applies directly and identically in the 27 Member States on the dates specified in the text, without transposition. Only the penalty regime is set nationally, and it is being developed in France.

6Where should I start in practice?

Start with an inventory of your packaging by catalogue item (material, recyclability, recycled content and format), identifying catalogue items at risk before 2030. Then prioritise Annex V formats and multi-material plastics.

7Is my packaging compliant if it is French and recyclable?

Not automatically, because 2 independent issues overlap here. Packaging quality, whether recyclable, kraft, French or biodegradable, concerns product conformity. For a micro-enterprise, this largely falls to the supplier if it is established in the Union. Sales formalities remain your responsibility, whatever the quality of your packaging: membership of a producer responsibility organisation (PRO, éco-organisme in French) and a unique identifier (identifiant unique, or IDU) to sell in France, then registration on a national register and appointment of an authorised representative in each Union country to which you ship without being established there. Even exemplary packaging does not exempt you from these steps. The authorised representative mechanism is explained here, and three questions identify your situation.

8Does an e-commerce shipping parcel count as packaging under the regulation?

Yes. The regulation covers sales packaging, grouped packaging and transport packaging: the parcel, void fill and overpackaging therefore fall within scope just like the packaging visible on a shelf. The e-commerce business is responsible for its transport packaging, with an empty space ratio capped at 50% from 1 January 2030 at the earliest and reuse targets that exclude cardboard boxes. Your inventory must therefore include shipping boxes and void fill materials, as well as the product carton: this is what an inspector sees when they receive your product by parcel.

9Which PPWR deadlines apply to a company selling only in France?

The same as everywhere in the Union, because a regulation applies directly in the 27 Member States without transposition. Since 12 August 2026, every packaging type must be covered by a declaration of conformity and technical documentation. Harmonised sorting labels arrive on 12 August 2028. Banned Annex V formats and the first reuse targets apply from 1 January 2030; recyclability of all packaging and recycled plastic content requirements apply from this date at the earliest. French extended producer responsibility obligations continue to apply alongside them.

10Does the PPWR replace membership of a French producer responsibility organisation?

No, these are 2 separate systems. Membership of a producer responsibility organisation (Citeo or Léko for packaging) falls under French extended producer responsibility and finances collection and sorting. The PPWR sets requirements for the packaging itself: recyclability, recycled content, labelling and the declaration of conformity. A company up to date with its EPR fee may therefore fail to meet the product requirements, and the reverse is also possible. The regulation adds registration on the national producer register of each country where you sell (Article 44) and, outside your country of establishment, appointment of an EPR authorised representative (Article 45).

11What penalties apply in France if my packaging is non-compliant?

The PPWR leaves each Member State to set its penalties (Article 68 of Regulation (EU) 2025/40), and France has not yet set a schedule of fines: the implementing arrangements are being developed (DGPR, ADEME, DGCCRF). However, 3 mechanisms already have an effect: withdrawal of a non-compliant catalogue item from the market, additional EPR fee modulation for packaging that disrupts sorting (a 50 to 100% penalty at Citeo) and exclusion from tenders whose criteria include packaging compliance. These effects arise through buyers and producer responsibility organisations without waiting for an inspection.

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