PPWR: what obligations do distributors and importers have?
The manufacturer (called the “producer” in the PPWR) issues the EU declaration of conformity and keeps the technical documentation. Importers ensure before placing on the market that this has been done. Distributors act with due care. Anyone who places packaging on the market under their own name or brand counts as the manufacturer themselves. Private individuals have no obligations.
As of: 17.10.2026 · Reviewed by: Editorial team Elke Plastic GmbH · Information provided without guarantee, not legal advice.
Who has which role?
| Role | Core obligation | Evidenced in |
|---|---|---|
| Manufacturer (producer of the packaging) | Carry out the conformity assessment, issue the EU declaration of conformity, keep the technical documentation; keep both for 5 years for single-use packaging and 10 years for reusable packaging; provide documents to the authorities within 10 days (Art. 15) | Declaration of conformity |
| Importer | Before placing on the market, ensure that the manufacturer has assessed conformity and drawn up the technical documentation; keep a copy of the declaration of conformity available for 5 or 10 years (Art. 18) | Checklist |
| Distributor | Act with due care regarding the requirements, including checking that the manufacturer is entered in the producer register; hand over documents to the authorities on request (Art. 19) | Checklist |
| Distributors with their own brand | Anyone who places packaging on the market under their own name or brand, or modifies it, counts as the manufacturer and has its obligations (Art. 21) | Declaration of conformity template |
| Producer within the meaning of producer responsibility (EPR) | Registration in the national producer register, financial contributions for collection and recycling (Art. 44, 45) | PPWR overview |
| Private individual | No obligations under the PPWR | — |
What you should do now as a distributor or importer
- Request declarations of conformity from all suppliers and file them by packaging type.
- Check whether the manufacturer's name and address and the unique identification of the packaging are included.
- Request evidence on heavy metals; for food contact, also on PFAS.
- Keep the technical documentation available on request.
- Plan a material audit: what is mono-material and what is composite (relevant from 2030 at the earliest)?
- Your own brand? Then you issue the declaration of conformity yourself: view the template.
The supplier checklist to tick off: PPWR checklist.
Deadlines at a glance
| Stage | Date | Applies to you |
|---|---|---|
| Evidence and substance limits | 12.08.2026 | Declaration of conformity, heavy metals, PFAS for food contact |
| Harmonised labelling | at the earliest 12.08.2028 | Information on material and disposal |
| Recyclability, recycled content, empty space | at the earliest 2030 | Material audit, switch to mono-material where applicable |
The full timeline to 2040: PPWR timeline.
The PPWR and the Packaging Act: what remains?
The PPWR applies directly in all EU Member States and applies alongside the German Packaging Act (VerpackG) and the LUCID registration requirement. As far as we know, it does not yet replace these national rules; the German legislature is adapting them, and you can find the current status at the Zentrale Stelle Verpackungsregister.
Frequently asked questions
As an online seller, do I have to issue a declaration of conformity?
The declaration is issued by the manufacturer of the packaging. If you place packaging on the market under your own name or brand, or modify it in a way that may affect conformity, you count as the manufacturer yourself and issue the declaration (Art. 21). Otherwise, as a distributor, you take due care to ensure that your supplier meets its obligations.
Does the PPWR also apply to shipping packaging?
Yes, it applies to packaging of every kind placed on the market in the EU, including shipping packaging. Requirements on empty space will apply to it later (from 01.01.2030 at the earliest).
As a private individual, do I have obligations under the PPWR?
No. Obligations fall on manufacturers, distributors and importers.
Where do I find the evidence for Elke Plastic items?
In the data sheet archive, sorted by product. The declarations of conformity are available there as downloads.