PPWR and EPR are linked: the PPWR is Regulation (EU) 2025/40, which sets packaging requirements and also governs EPR. EPR, or Extended Producer Responsibility, determines who must take responsibility for packaging waste and how that responsibility is organised in each country. Having an EPR registration therefore does not show that the packaging meets all applicable requirements. If you sell packaged products in the EU, you need to check both: whether the packaging complies and which obligations your business has in each destination country.
PPWR and EPR: the difference at a glance
PPWR stands for Packaging and Packaging Waste Regulation. EPR means Extended Producer Responsibility. Here, we are discussing packaging EPR in the EU.
| Packaging requirements under the PPWR | Packaging EPR | |
|---|---|---|
| Purpose | To ensure packaging meets the applicable requirements | To make the producer responsible for managing packaging waste |
| Usual documents | Technical documentation and a declaration of conformity, according to the applicable requirements | Registration, data reports or payments, depending on the country |
| Who is responsible | The manufacturer, with obligations also applying to importers and distributors | The producer for EPR purposes, depending on the transaction and country |
| Where it applies | An EU framework | Managed nationally |
The table separates the functions to make the comparison easier, although EPR forms part of the PPWR itself.
The manufacturer is not always the business that physically makes the box: it may also be the brand that commissions the packaging or packaged product. You need to identify who holds that role in each case.
This affects you if you sell packaged products in the EU, wherever your business is established. We are not covering domestic EPR in the US or UK here, or other EPR streams such as electrical waste or batteries.
As for dates, the PPWR entered into force on 11 February 2025 and has applied generally since 12 August 2026, according to the European Commission. Some requirements have their own timetable. You can find the details in our guide to PPWR requirements and packaging documentation.
What does your EPR registration prove?
An EPR registration has a specific scope. Before relying on it, check the country, business and packaging it covers, and whether the information is up to date. For reports and payments, also check the relevant period.
The declaration of conformity is the document in which the manufacturer declares that a packaging type meets the applicable requirements.
| Document | What it allows you to check | What it does not prove on its own |
|---|---|---|
| EPR registration | That a business is registered in a particular country | That the packaging complies with the PPWR or that other countries are covered |
| Reports or payments | That data was submitted or fees were paid for a period | That the data relates to the current packaging version or that all obligations have been met |
| Packaging supplier data | The materials, weights and components the supplier declares | That the supplier takes on the manufacturer's or producer's role |
| Technical file with a declaration of conformity | The packaging type it concerns and who is responsible | That it covers other packaging or versions, or replaces EPR registration |
The declaration must identify the responsible manufacturer and the person signing on its behalf. Even if an authorised person signs for the manufacturer, the manufacturer remains responsible. Contracts or payment receipts do not, on their own, prove that every obligation has been met either.
The practical risk is assuming everything is complete when documentation is missing. Requirements may remain unaddressed and only come to light later, for example when you change supplier or sales channel. For country-specific details, see our guide to packaging EPR obligations in Europe.
Who is responsible depends on how you sell
Responsibility depends on the packaging, where the business is established, how you sell and who is involved in the supply chain. The following two examples are hypothetical and are not an assessment of a real case.
The packaging manufacturer and the producer for EPR purposes are not always the same business.
Direct sales to end users
A business established in the United States, with no EU establishment, sells directly to consumers in Germany through its website. It ships the product in a cardboard box with plastic filling. In this scenario, it is the producer for EPR purposes in Germany and must appoint an EPR representative there. It must also check who is the manufacturer under the PPWR and which packaging conformity obligations apply to it.
Sales through an EU importer or distributor
The same business sells to a company established in France, which markets the product there. In that case, the French company may be the producer for EPR purposes for that packaging. This does not remove the other obligations: packaging conformity and the identity of the manufacturer must be reviewed separately. A packaging supplier or distributor does not automatically take on every role.
It helps to distinguish three roles:
- Manufacturer's representative: acts on behalf of the manufacturer within the scope of its mandate.
- EPR representative: acts on behalf of the producer for EPR obligations in the relevant country. This role is required in the cases specified by the regulation and national rules.
- PRO (Producer Responsibility Organisation): manages EPR obligations for several producers. It can handle registration unless national rules provide otherwise.
A Responsible Person role under the GPSR, such as our EU Responsible Person service, does not automatically cover EPR. What matters is which task and country each mandate covers.
How to check what is missing
Start with these four checks:
- List your packaging and destinations: which packaging you use and the countries where you sell it.
- Map the supply chain: who manufactures, who imports, who sells to the final customer and where each business operates from.
- Match each document to its scope: country, business, packaging version and period, where relevant.
- Check what is missing: which requirements apply and what still needs to be documented or assigned.
To do this, gather your packaging types and components, materials and weights, supplier details, sales channels, destination countries and existing documents. This is a working list, not a complete legal file.
Common mistakes
- Assuming EPR registration means the packaging complies.
- Assuming one registration covers every country.
- Using data or a declaration of conformity for a different packaging version.
- Confusing the manufacturer's representative, EPR representative and PRO.
If any of these gaps affects an enforceable requirement, the prudent approach is to correct it before continuing to sell.
Not sure which packaging obligations apply to your business? Conformity Point works with businesses selling products in the EU that need clarity on their documentation and responsibilities. Explore our services
Frequently asked questions about PPWR and EPR
Does the PPWR replace national EPR registration?
No. The PPWR includes EPR rules but retains national registers. Harmonisation aims to align their rules and formats, not create one register for the whole EU. You must follow the rules of the country where you are the producer, as the European Commission explains.
Is one EPR registration valid across the EU?
No. There is no single EPR registration covering the whole EU. You must check your obligations in each country where you are the producer.
Does a packaging declaration of conformity replace EPR obligations?
No. The declaration concerns whether a packaging type meets the applicable requirements. EPR concerns who takes responsibility for its waste. Neither replaces the other.
Does the PPWR apply to US and UK businesses selling in the EU?
Yes. The PPWR applies to packaging marketed in the EU, even if the business is based in the United States or the United Kingdom. Each business's specific obligations depend on its role in the transaction.
What to check before selling in the EU
An EPR registration does not prove that your packaging complies, and a declaration of conformity does not replace registration. Check what each document covers and who is responsible for each obligation.
Have EPR registration but still need to check your packaging documentation? Tell us about your packaging types, sales channels and EU destinations. At Conformity Point, we will assess your role and identify what needs review. Have your packaging documentation and conformity reviewed
Official sources: Regulation (EU) 2025/40 · Commission Notice C/2026/3084 · European Commission: packaging waste
About the author
Written by Juan Manuel Beltrán, Founder & Product Compliance Consultant at Conformity Point. A specialist in consumer product compliance for the European market, he helps manufacturers, importers and brands sell consumer products in Europe.
Technical and regulatory review: Conformity Point. Last updated:
This article is a general guide and does not constitute legal advice. The application of the requirements described depends on the category, function, design, intended use, risks, applicable legislation and documentation of the specific product and its packaging.