Commission publishes factsheet on PPWR requirements for small businesses
MORE INFORMATION
The factsheet reiterates that, although the PPWR has applied since 12 August 2026, many requirements will only apply gradually over the coming years.
For now, the main points highlighted for smaller businesses are:
- Declaration of Conformity: manufacturers and importers must currently demonstrate compliance mainly with substance-related requirements, including heavy metal limits and PFAS restrictions for food-contact packaging;
- Traceability: packaging must be linked to its manufacturer and DoC, but packaging already produced without the required markings does not need to be repackaged or destroyed; the information may instead be provided through accompanying documentation or digital means;
- Authorised representatives: EPR-related authorised representative requirements remain applicable for now, although the Commission proposal to suspend them is still under negotiation;
- SME exemptions: micro-enterprises may benefit from specific exemptions, while businesses placing less than 1,000 kg of packaging on the market per year may benefit from lighter EPR reporting requirements.
The factsheet also provides practical examples clarifying when a company is considered a manufacturer, importer or producer under the PPWR.
NEXT STEPS
The Commission is continuing to prepare the supporting measures and guidance needed for the progressive implementation of the PPWR, including on recyclability, recycled content, minimisation, labelling, reuse and refill obligations.
