How to prepare your business for PPWR compliance

If PPWR hasn’t been high on your company’s agenda until now, where is the best place to start? Alex Hawley, head of sustainability legal at PwC UK, outlines the important steps companies should take now to ensure they are compliant with the new requirements.

PPWR is complex, and there has been extensive commentary on its detailed requirements. However, it can be more difficult to cut through the noise and understand where to focus efforts, especially as businesses face the first wave of compliance following 12 August 2026.

Some key themes have emerged from practical experience in supporting clients to design and implement PPWR compliance programs.

For businesses beginning to address compliance, here are some practical steps to consider.

Understand your role

Map the key ways the business interacts with packaging reaching the EU. For which packaging units is your organisation the Manufacturer, Importer, or a Distributor under PPWR? Are you the EPR Producer of the packaging in one or more EU Member States?

Once you have a clear picture of the role(s) you play, this will determine the compliance obligations that follow. Compliance will look very different for a business which is predominantly a Manufacturer, with primary responsibility for compiling and keeping the technical documentation and signing the Declaration of Conformity (DoC), and a business with obligations more concentrated downstream.

Think inside the box

Packaging which exceeds the heavy metals or PFAS limits will not be compliant unless a specific derogation applies, whereas packaging which adheres to the limits can meet the 12 August requirements with the right documentation. Focus first on proving packaging complies with the technical limits and discovering as soon as possible if any units need to be held back.

Technical testing can also have one of the longest lead-times of the current PPWR compliance actions, so start the process while working on the other pieces of the puzzle. High-risk items include packaging with bright inks, black plastic, and food contact packaging with waterproof or greaseproof coatings like takeaway containers.

Where possible, obtain test results from suppliers- where these are not provided, the recent European Commission FAQs indicate that Manufacturers will be expected to make “best efforts” including conducting their own tests.

Prioritise key batches

PPWR obligations first crystallise at the point packaging is placed on the EU market. Although not a resilient long-term system, in the short term, it is possible to prioritise compliance for the next batches of product reaching the EU market and address the required actions in tranches, even week by week if volumes allow.

However, be aware of the nuance if taking this approach, as the point at which packaging is “placed on the market” can vary between sales, transport or service packaging, and depend on whether it is imported from outside the EU.

While building the right system, use the “right now” system

The Commission FAQs reinforce that the purpose of the traceability number is to ensure the packaging can be linked back to its DoC and technical documentation. Long-term, businesses will need a structured system and to give thought to how packaging or batches are grouped.

However, for those under pressure to comply in the short term, use what works for now – this can be an existing or temporary numbering system, as long as it reliably links the packaging to the relevant information. Similarly, FAQs confirm that for existing stock placed on the market after 12 August, administrative workarounds are possible, such as providing manufacturer information in a separate document rather than on the packaging itself.

Align on communications

Gather key colleagues who will be receiving PPWR queries from supply chain partners; this could include stakeholders from procurement, legal, compliance and supply chain teams. Align on an approach to queries that works for the business, considering response times, agreed wording, and how questions will be triaged. What is the commercial position on what can be shared, and what must remain confidential?

Be ready to respond

Expect an influx of queries from supply chain partners, and potentially regulators. Ensure that the touchpoints which are most likely to receive those enquiries are aware of the agreed approaches, understand the significance if a regulator requests information, and are ready to escalate quickly.

Manufacturers have 10 days to produce technical documentation and the DoC if contacted by authorities, so training and escalation protocols for those monitoring central mailboxes and customer service lines should avoid delays. In particular, where you have placed electronic contact details on packaging as a Manufacturer or Importer, ensure that those mailboxes are monitored.

In summary, if the business has:

Clarity on the PPWR roles it plays, and the compliance actions resulting
A clear view of how its EPR “Producer” footprint may have changed, including making any new registrations
Systems in place to meet PPWR requirements for the next batches of packaging placed on the EU market (including, for Manufacturers, technical documentation and DoC)
An approach to applying Manufacturer and Importer information to packaging, which can use a workaround for existing stock
A system for traceability, even if this is temporary; and
Internal processes to respond to commercial and regulator queries

Then the key bases should be covered under the 12 August requirements.

However, as further provisions of PPWR phase in over the years to come, the businesses which are likely to cope best will be those that have set a strong foundation now. It will be increasingly important to be able to assess the impact on the business in good time, and connect legal interpretation, product data and supplier engagement.

So, as well as looking to the immediate requirements, remember to keep an eye on what comes next.

Disclaimer: This article is for informational purposes only and does not constitute legal advice.

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