PPWR and Small Businesses: What the Commission’s New Guide Clarifies

On 19 October 2026, the European Commission published a short guide for small businesses on the Packaging and Packaging Waste Regulation (PPWR). The PPWR has applied since 12 August 2026, but most of its requirements will be phased in over the coming years. The guide sets out which obligations apply to smaller companies today, how to tell whether a business counts as a manufacturer, importer or producer, and which exemptions are available to micro-enterprises.

 

What Applies Now

The guide serves as a useful reminder that, for now, businesses qualifying as manufacturers, importers or producers only need to comply with a limited set of rules.

1. Declaration of Conformity. Manufacturers and importers must draw up a declaration of conformity for their packaging. For now, it only needs to cover the substances of concern under Article 5 of the PPWR: the limits for lead, cadmium, mercury and hexavalent chromium and the PFAS limits for food-contact packaging. The heavy metal limits already existed under the previous Packaging and Packaging Waste Directive, so the Commission identifies the PFAS restriction as the main new element. Where a business is legally the manufacturer but does not produce the packaging itself, Article 16 of the PPWR requires the physical supplier to provide the data and technical documentation needed for the declaration.

2. Traceability Marking. Packaging must carry a type, batch or serial number, or another identifier, together with the manufacturer’s contact details, so that it can be linked to its manufacturer and its declaration of conformity. The guide clarifies that packaging already produced without these markings does not need to be repackaged or destroyed. The information can be provided through accompanying documents, such as invoices or by digital means, as long as the link to the manufacturer and the declaration is clear.

3. Authorized Representative. Producers must appoint an authorized representative for extended producer responsibility (EPR) purposes in certain cases. The guide notes that the Commission has proposed suspending this requirement and that negotiations are ongoing, following calls from SMEs that we covered in our article on the request to suspend the PPWR authorized representative requirement. A day after the guide was published, on 20 October, the European Parliament voted to limit the suspension to EU-based small and micro-enterprises until 2035 and on October 21 the Council adopted its negotiating position, proposing an exemption for producers placing less than 1 tonne of packaging per year in another Member State, until 2032. Until the two institutions reach an agreement, the requirement still applies.

 

Manufacturer, Importer or Producer?

The guide also revisits the three roles defined in the PPWR, since each one carries different obligations.

• Manufacturer: The basic rule is the one discussed in our article on private label packaging under the PPWR: the business whose name or trademark appears on the packaging is its manufacturer, wherever the packaging was produced. The guide adds two useful clarifications. Placing a logo sticker on generic packaging is enough to make a company the manufacturer, while a label added only for shipping is not. And when a business uses plain transport packaging from a supplier, such as boxes or pallets without its brand, the manufacturer role stays with that supplier.

• Importer: A business that places packaging or packaged products from a non-EU country on the EU market is an importer. Its obligations are the same as those of a manufacturer.

• Producer: A business is the producer when it makes packaging or packaged products available for the first time in the Member State where it is located, or sells directly to consumers in another Member State. The two roles serve different purposes. The manufacturer is responsible for the packaging’s compliance with the PPWR, while the producer is responsible for financing the collection and recovery of packaging in the Member State where it becomes waste.

 

 

Exemptions for Micro-Enterprises

Micro-enterprises, meaning businesses with fewer than 10 employees and an annual turnover below €2 million, can benefit from two exemptions under certain conditions:

• Manufacturer Obligations:  If a micro-enterprise sells packaging under its own brand and the physical supplier is located in the EU, the supplier becomes the manufacturer. The supplier then draws up the declaration of conformity and ensures traceability marking.
• EPR Obligations: If a micro-enterprise is also the producer, it is exempt from EPR requirements when the supplier of the packaging materials is established in the same Member State.

 

What Comes Next

Most PPWR requirements will apply later, many from 2030 onwards. They include recyclability, minimum recycled content in plastic packaging, packaging minimization, labelling, bans on certain single-use plastic formats, reuse targets and refill and reuse obligations for the take-away sector.

Some of these come with lighter rules for smaller companies. Micro-enterprises are exempt from the reuse targets of Article 29 and from the obligation under Article 33 to offer reusable packaging in the take-away sector. Businesses that place less than 1,000 kg of packaging on the market per year will have simpler EPR reporting requirements.

Many of these rules still depend on implementing acts and guidelines that the Commission is preparing. The guide encourages small businesses to take part in the consultations published on the Commission’s Have Your Say portal and the Commission maintains a dedicated PPWR implementation page.

 

Conclusion

For most small businesses, the immediate obligations under the PPWR are limited: a declaration of conformity covering heavy metals and PFAS, traceability marking and, until an agreement on its suspension is reached, the authorized representative requirement. The key step is identifying the correct role for each product line, since a brand label alone can turn a buyer of packaging into its manufacturer. Micro-enterprises working with EU-based suppliers can pass several of these obligations on to the supplier.

Pack-Lab supports businesses with heavy metal and PFAS testing for the PPWR, as well as regulatory consulting on operator roles and technical documentation. Contact us to discuss your packaging.