In principle, yes: if you place a packaged product on the market under your brand (or a private label), you are the PPWR declarant for that packaging, even if you buy it from a supplier. You must check that the purchased packaging complies with the Regulation (recyclability, PCR content and permitted format). Your suppliers will have to provide certifications, but you retain legal responsibility to the authorities. This makes PPWR clauses in purchasing contracts essential. There is an exception for micro-enterprises: if you are below the thresholds (fewer than 10 employees and turnover below €2 million under Recommendation 2003/361/EC), Articles 3 and 15(12) transfer conformity obligations to your packaging supplier, provided it is established in the EU. See our dedicated article: PPWR for micro-enterprises and business creators.
Read the source article: PPWR packaging regulation: EU 2025/40 changes in 2026