PPWR: Navigating EU Regulation 2025/40 with Trusty

Packaging data, connected documents and updatable information to manage compliance

Regulation (EU) 2025/40, known as the PPWR – Packaging and Packaging Waste Regulation, introduces new rules for the management of packaging and packaging waste in Europe. Its general application is scheduled for 12 August 2026.

The PPWR replaces Directive 94/62/EC and, as a regulation, will be directly applicable in all Member States. It covers all packaging placed on the European market, regardless of material, and addresses the entire packaging life cycle: from design to end-of-life management.

Its objective is to make packaging more sustainable and circular by reducing waste, limiting unnecessary packaging, and promoting reuse, refill, recyclability and the use of recycled material. The change is not only technical: companies will need to manage data, responsibilities and documents related to packaging compliance more effectively.

A note on the PPWR

Before looking at the operational aspects, it is useful to start with an important clarification. There is a lot of inaccurate, incomplete or incorrect information circulating about the PPWR. This is not just a perception: during the “PPWR e Green Claims” webinar organized by CONAI on 23 April, 2026, explicit reference was made to actual “fake news” about the regulation, which has contributed to confusion among companies.

This has very practical consequences: relying on incorrect information can lead companies to build inadequate processes, incur unnecessary costs or, conversely, underestimate real obligations. For this reason, it is essential to rely on verified sources and maintain a cautious approach, especially in a regulatory framework that is still evolving in some areas.

The brand owner becomes responsible for packaging

One of the most significant changes concerns the role of the manufacturer. Under the PPWR, this definition does not only include the company that physically produces the packaging. It also includes the company that has packaging, or a packaged product, designed or manufactured and places it on the EU market under its own name or trademark.

This means that the brand owner cannot treat packaging compliance as the sole responsibility of the external supplier. Even when the packaging is produced by a third party, the company that markets the product under its own brand must be able to demonstrate the packaging’s compliance.

This role should be distinguished from the producer EPR, which is linked to registration, contribution and reporting obligations in the countries where the product is sold. The manufacturer, on the other hand, signs the Declaration of Conformity, keeps the technical file and may be subject to audits. The two roles may coincide, but they are not automatically the same thing.

What companies need to do under the PPWR

One of the most significant changes concerns the role of the manufacturer. Under the PPWR, this definition does not only include the company that physically produces the packaging. It also includes the company that has packaging, or a packaged product, designed or manufactured and places it on the EU market under its own name or trademark.

This means that the brand owner cannot treat packaging compliance as the sole responsibility of the external supplier. Even when the packaging is produced by a third party, the company that markets the product under its own brand must be able to demonstrate the packaging’s compliance.

This role should be distinguished from the producer EPR, which is linked to registration, contribution and reporting obligations in the countries where the product is sold. The manufacturer, on the other hand, signs the Declaration of Conformity, keeps the technical file and may be subject to audits. The two roles may coincide, but they are not automatically the same thing.

Declaration of Conformity: content in progress

The PPWR Declaration of Conformity is one of the key tools introduced by the new regulatory framework and was also discussed during the webinar organized by CONAI on 23 April. One point that clearly emerged is that the content of the DoC is expected to evolve in line with the deadlines set by the regulation.

Another aspect clarified during the webinar concerns the supporting documentation for the DoC: it must be kept by the manufacturer, but it does not need to be passed down the supply chain. Its purpose is to demonstrate, in the event of a check by the competent authorities, how the company reached its conclusion on the packaging’s compliance. It is therefore not a document to be shared with customers or distributors, but an internal file to be made available in case of inspection.

It is also worth noting that the MOCA Declaration of Conformity, required for materials and articles intended to come into contact with food, does not replace the PPWR Declaration of Conformity. They are two distinct declarations, although they may be combined when both apply.

From regulatory requirement to operational challenge

For many companies, the difficulty will not only be interpreting the regulation, but translating it into a manageable internal process.

The first concrete step, which can already be taken today, is to map the packaging materials used, regardless of the aspects of the regulation that are still evolving. Before defining how to manage the Declarations of Conformity, companies need to understand their starting point: which packaging components they use, what materials they are made of, which suppliers they come from, and which information is already available or still missing.

This mapping makes it possible to identify where action is needed, which suppliers should be involved, and which data must be collected. Only by starting from an organized information base will companies be able to build the next steps required by the regulation on solid ground.

Trusty, from fragmentation to clarity

The PPWR is a process, not a one-off event. It requires preparation, continuous updates and the ability to translate regulatory obligations into concrete business processes.

Trusty closely monitors the evolution of the regulation and is structured to support companies throughout this journey, with an approach that takes into account both the complexity of the regulatory framework and the operational needs of those who manage packaging every day.

In a framework that is still evolving, starting early is the best way to reduce uncertainty and reach the next deadlines with stronger, more complete and usable information. Companies that want to start navigating the PPWR can do so with us today.

Communicating updatable packaging information

The quality of internal data also affects external communication. Misalignment between technical documents, digital materials and commercial requests can create inefficiencies and inconsistencies.

With Trusty, the information base built for internal management can also be enhanced through QR codes, making updatable information on products and packaging available while maintaining consistency between what is managed internally and what is communicated externally.

An additional resource for navigating the PPWR

To explore prevention measures, design criteria and deadlines in more detail, companies may find it useful to consult the CONAI Vademecum on prevention measures under Regulation 2025/40 on packaging and packaging waste, updated on 27 March 2026.

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