PPWR in Practice Webinar Materials
On this page you will find webinar materials and answers to questions asked during the webinar.
The interpretations and guidelines that were still pending at the time of the webinar were updated in the materials on 26 August 2026. The updated sections are clearly marked with a green background.
Webinar presentation materials
Download webinar presentation materials and supplementary PPWR materials
Questions and Answers by Topic
Operator roles and producer responsibility
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If the brand owner is not part of the packaging supply chain, is the Producer then the packaging manufacturer/importer?
Based on our interpretation, the licence holder is considered both the Manufacturer and the company subject to producer responsibility.
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What is our role if we purchase sales packaging, such as canisters, drums and IBC containers, from Finland, fill them and place the products on the market? We add our product information to the packaging, but the packaging itself is not customized for us.
For canisters, you are considered the Manufacturer of the packaged product and are responsible for both producer responsibility obligations and, for example, the Declaration of Conformity for the packaging. The Finnish Supervisory Agency (LVV) has interpreted the metal cage and pallet of an IBC container as transport packaging. According to PPWR, transport packaging is generally not intended for the end user. However, in cases where packaging can be considered both sales and transport packaging, it is considered sales packaging.
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Are foldable packaging items (such as pastry boxes and pizza boxes) considered to be in their "final form" when supplied as blanks by the manufacturer, or only once assembled by the user?In the case of paperboard and cardboard packaging, the manufacturer of the blank is considered the Manufacturer. For service packaging, the intention has generally been that individual pizzerias would not be subject to producer responsibility. Based on this, the interpretation appears to lean towards the manufacturer of the blank. However, if the packaging is branded, responsibility lies with the brand owner.
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If transport packaging is unbranded but a logo tape is later added in the warehouse of the commissioner of the packaging, which party is subject to producer responsibility: the physical manufacturer or the commissioner of the packaging?
Further guidance from Finnish Supervisory Agency is still awaited.
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If we manufacture private-label products but source all materials ourselves, is the brand owner or the manufacturer responsible for the packaging?
From 12 August 2026 onwards, producer responsibility for branded packaging, including private-label products, will rest with the brand owner. For transport packaging, producer responsibility will generally rest with the packaging manufacturer. For products placed on the market before 11 August 2026, responsibilities are determined according to the previous legislation.
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We commission a custom-made wooden packaging for our equipment. The wooden package bears only the manufacturer's Finnish Food Authority (Evira) stamp and no other logos, as it is intended solely for transport. Is the manufacturer of the transport packaging responsible for reporting? Most of the packaging is exported from Finland outside the EU, while some is supplied to B2B customers in Finland.
According to the European Commission’s latest PPWR guidance, for custom-made packaging, the company ordering the packaging may be considered the manufacturer and therefore subject to producer responsibility, even if the packaging does not bear the customer’s name or trademark.
Only transport packaging that remains in Finland is reported in Finland.
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We purchase unprinted flat-packed brown cardboard boxes from a supplier and, as a contract packer, pack our customers’ products into them. Each box contains hundreds of units of the same product. Is this transport packaging? Must we report the bulk boxes delivered flat-packed when we add a label containing the product number, product name, serial number, date and our company name? Would removing our company name from the label change the situation?
A generic flat-packed cardboard box is considered transport packaging as such, meaning that the manufacturer of the blank is considered the Manufacturer. In this case, your company is not subject to producer responsibility for the packaging. Producer responsibility lies either with the box manufacturer or with the company having the product packed.
If the packaging carries an SSCC label or an address label, it is not considered branded packaging, so this does not change the situation in this case.
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Clarification regarding licensing: if our company holds a licence to use a Finnish trademark, does this change the allocation of responsibilities? The packaging may contain nothing more than the trademark logo.
A trademark makes the packaging branded packaging. Producer responsibility therefore lies with the trademark owner, which in this case is the company holding the right to use the trademark.
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We purchase paper from Sweden. The paper is wrapped in protective paper and contains a cardboard core inside the roll. Neither is branded, and both form part of the supplier’s standard packaging. Once the paper has been used, the wrapping paper and cardboard core are collected with our cardboard packaging waste. Who is responsible for reporting the wrapping paper and cardboard core? Should the packaging be reported in Finland or Sweden?
Packaging data must always be reported in the Member State where the packaging or packaged products are placed on the market and become waste. In this case, the packaging must therefore be reported in Finland. According to the Finnish Supervisory Agency (LVV), the end label and wrapping of paper rolls are considered sales packaging. Therefore, the Swedish distance seller has producer responsibility for them in Finland. Your company is considered the end user of this sales packaging.
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If a retailer orders products packed with its own logos, is the retailer subject to producer responsibility for the packaging?
Yes. The brand owner is subject to producer responsibility for the packaging of these products.
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Our product is packed in plastic packaging and is shipped to the customer in a cardboard box. How does PPWR affect this?
You are subject to producer responsibility for the plastic product packaging. This will not change. This will not change. The actual manufacturer of the generic cardboard box (transport packaging) is responsible. If the cardboard box is branded, the brand owner is responsible.
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How can a manufacturer of stretch films know how the film will be used? Similarly, how can a manufacturer of transport packaging know whether the packaging will remain in Finland and enter the Finnish waste management system?
Finnish Supervisory Agency has suggested that manufacturers of materials used as transport packaging could use two separate product codes. One product code would indicate “recycling fee paid”, meaning the packaging remains in Finland and is used as transport packaging. The other product code would indicate “recycling fee not included”, meaning the packaging is either used as product or transport packaging but is supplied to another country, in which case the recycling fee must be paid in that country. Stretch film is considered packaging while still on the roll, so the film manufacturer is responsible.
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Why is the distinction between packaging material and packaging important when assessing compliance, for example in relation to recycled content in materials purchased and stored before the new requirements enter into force?
Producer responsibility reporting covers packaging that has been placed on the market, and the packaging must comply with the applicable requirements at the time it is placed on the market. For example, if packaging material has been purchased and stored before 12 August 2026 but is later used to manufacture sales or grouped packaging on or after that date, the Manufacturer of the packaging or packaged product must prepare an EU Declaration of Conformity and report the packaging under producer responsibility obligations.
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A company imports products bearing its own trademark into one EU Member State. The products are then sold to wholesalers, who distribute them from a central warehouse to several countries. The EU importer and brand owner may not know all the countries in which the products ultimately end up. Is the brand owner or the wholesaler subject to producer responsibility for these products? Products may be supplied to the same country both directly by the brand owner and through wholesalers.
In this case, producer responsibility lies with the brand owner established in the relevant country or with the importer (distributor) established in that country. The relevant country is the country where the products ultimately end up.
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If a company imports packaging into Finland from a third country but delivers a large share of it to other EU countries, how should reporting be handled? Should all imported packaging be reported, or only the packaging sold in Finland?
Only packaging that remains in Finland is reported under Finnish producer responsibility obligations. Packaging supplied to other countries must be reported to the producer responsibility system of the country concerned. For sales packaging, producer responsibility lies with the Manufacturer of the packaged product or the Importer. If you import transport packaging, you are subject to producer responsibility in Finland only for the transport packaging that remains in Finland.
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If the only branded packaging material is tape and all other materials (such as packaging films, cardboard, pallets, stretch film and strapping) are standard products from a packaging supplier’s catalogue, is the manufacturer of those packaging materials responsible? Or are we responsible as the packer? Is there a difference between transport packaging and product packaging?
Most of the packaging materials mentioned are transport packaging.
Transport packaging can consist of several separate, ready-made packages (e.g. a pallet, box and wrapping). Using them together does not make the user/assembler their manufacturer. However, if packaging is created from components that do not yet perform the function of packaging on their own, this constitutes the actual assembly or manufacture of the packaging. In this case, the assembler may be considered the Manufacturer and the first potential producer.
Who is the Manufacturer of transport packaging?
- If the packaging bears a name or trademark, the producer is the company that had the packaging manufactured.
- If the packaging is generic, the producer is generally the actual manufacturer (supplier) of the packaging.
- The importer also has producer responsibility for transport packaging if it comes from outside Finland.
Packaging
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Is a large container or a drum considered transport packaging?
The Finnish Supervisory Agency (LVV) has interpreted the metal cage and pallet of an IBC container as transport packaging. According to PPWR, transport packaging is generally not intended for the end user. However, in cases where packaging can be both sales and transport packaging, it is considered sales packaging.
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If a brown cardboard box carries a black-and-white label containing a product code, product name (which may include a brand name), GTIN code, commissioning company details and similar information, is the packaging considered branded?
In this case, the packaging is not considered branded. If the packaging carries an SSCC label or an address label, it is not considered branded packaging.
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Is home compostability considered recyclability?
No further information is currently available on this topic. Guidance from the European Commission on recyclability grades is expected by 1 January 2028.
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Is stretch film transport packaging or grouped packaging when it is used around cardboard boxes that themselves function as transport packaging?
In this case, the stretch film is considered transport packaging.
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Is a cardboard box transport or sales packaging if the same box is used both for pallet transport and for product display on a retail shelf?
In cases where packaging can be both sales and transport packaging, it is considered sales packaging.
Questions submitted to Tukes –
Declaration of Conformity (EU DoC)
Questions were answered by Tukes experts Marita Hiipakka and Tiia Salamäki.
Roles and responsibilities related to the Declaration of Conformity
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Is the manufacturer of transport packaging materials always considered the Manufacturer and therefore responsible for preparing the EU DoC, or is the manufacturer of transport packaging considered a supplier?
Transport packaging is considered a separate packaging type for which the actual Manufacturer prepares the EU Declaration of Conformity, unless the transport packaging is clearly branded (see also European Commission FAQ, Chapter VX, Question 12). If the manufacturer of transport packaging acts as a supplier, it must provide the Manufacturer with all information and documentation necessary to demonstrate that the packaging and packaging materials comply with PPWR.
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Who is responsible for ensuring compliance with packaging for products sold directly to end users through distance selling from outside the EU? Does it make a difference whether the end user is a business or a consumer?
If the distance seller is an online marketplace or online store established in a third country, it is responsible for ensuring that packaging and packaged products placed on the EU market comply with applicable EU legislation. From a market surveillance perspective, it makes no difference whether the end user is a business or a consumer.
According to the Market Surveillance Regulation, products offered for sale online or through other forms of distance selling are considered to be made available on the market if the offer is targeted at end users in the Union. An offer is considered to be directed at end users in the Union if the relevant economic operator (for example, a Chinese online store) directs its activities to a Member State.
If a Finnish economic operator supplies products or packaging packed in a third country directly to an end user through distance selling, it is considered the Importer and is subject to importer obligations under PPWR. The Importer must ensure that the Manufacturer established in the third country has fulfilled applicable packaging compliance requirements before the packaging is placed on the market in the EU.
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Who is responsible for the EU DoC for a pallet – the pallet manufacturer or the user? If a company manufactures corner protectors used as components of transport packaging, must the manufacturer of the corner protectors provide an EU DoC? Must each corner protector carry an identifier if it is to be used after 12 August 2026?
Pallets and corner protectors are considered separate packaging types when used as transport packaging. The actual Manufacturers prepare the EU DoCs for these packaging types, unless the transport packaging is clearly branded (see also European Commission FAQ, Chapter VX, Question 12). If the manufacturer of transport packaging acts as a supplier, it must provide the Manufacturer with all information and documentation necessary to demonstrate that the packaging and packaging materials comply with PPWR.
According to Article 15(5) of PPWR, Manufacturers must ensure that packaging bears a type, batch or serial number, or another identifier that enables it to be identified. The Declaration of Conformity is prepared for a packaging type. As transport packaging is considered a separate packaging type, each transport package should therefore carry an identifier.
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Is the following interpretation regarding imports into the EU correct: "The importer is responsible for ensuring compliance of all imported packaging, not only packaging that reaches the customer." In practice, this would mean that due diligence statements for packaging would be required from suppliers for all imports into the EU.
PPWR does not require a due diligence statement. Based on the information provided in the question, it is not possible to give a definitive answer.
Under PPWR, an Importer is a natural or legal person established in the Union who places packaging from a third country on the market. Obligations of the Importer are set out in Article 18 of the Regulation.
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Is a product considered to be placed on the market only after it has been delivered to a retailer's or distributor's warehouse? If a product has already been manufactured but remains in the manufacturer's own warehouse on 12 August 2026, is an EU DoC required?
A product is placed on the market when it is supplied for the first time on the Union market in the course of a commercial activity, whether in return for payment or free of charge, for distribution, consumption or use. Such supply includes any offer for distribution, consumption or use on the Union market that may result in actual delivery of a product that has already been manufactured. Placing on the market requires an offer or agreement (written or verbal) between two or more natural or legal persons concerning the transfer of ownership, possession or any other right relating to the product after the manufacturing stage. Transfer does not necessarily require physical handover of the product.
In the case described in the question, placing on the market takes place when the company, for example, sells the packaged product to a retail chain. A product held in the manufacturer's warehouse may not yet have been placed on the market unless it has been "supplied" as described above. However, if ownership of the product has been transferred after the manufacturing stage from the manufacturer to, for example, a retail chain, the product has been placed on the market even if it remains in the manufacturer's warehouse. Transfer of ownership therefore does not necessarily require physical delivery of the product.
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Must an EU DoC be prepared for packaging that is already in the country and already on store shelves? The products have been available on the market for a long time and were imported before 12 August 2026. Or does the EU DoC requirement apply only to new products and packaging placed on the market for the first time on or after 12 August 2026? Must an EU DoC be prepared for new batches even if the product and packaging remain unchanged?
Placing on the market is assessed individually for each product and package, not at product type or packaging type level. This also applies to packaged products and packaging manufactured in serial production.
If transport packaging, service packaging, primary production packaging or any other packaging or packaged product has not yet been manufactured, it cannot have been placed on the market. New batches placed on the market on or after 12 August 2026 must therefore be covered by an EU DoC, even if the product and packaging are identical to those placed on the market before that date.
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If a packaged product has both sales packaging and transport packaging, are two EU Declarations of Conformity required – one for sales packaging and one for transport packaging?
An EU DoC under PPWR is not supplied together with packaging or a packaged product. An exception applies where other EU legislation applicable to the packaged product specifically requires an EU DoC to accompany the product.
If you are the Manufacturer of both the packaged product and clearly branded transport packaging, a separate EU DoC is required for each packaging type. If the manufacturer of transport packaging acts as a supplier, it must provide the Manufacturer with all information and documentation necessary to demonstrate that the packaging and packaging materials comply with PPWR. If you purchase generic transport packaging from another company, the actual Manufacturer of the transport packaging prepares the EU DoC for that packaging.
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Must an EU DoC also be prepared for transport packaging used in e-commerce?
Yes
Content of the Declaration of Conformity
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What is the unique identifier referred to in the requirements? Can the unique identification number of a packaged product, such as an EAN code, be used for this purpose?
An EAN code is not necessarily a sufficient identifier, at least not on its own.
Identification of the product alone is not sufficient. Packaging must be traceable by type, batch, serial number or another identifier. The European Commission clearly states in its FAQ (Chapter XV, Questions 3 and 7) that packaging itself must be identifiable by type, batch or serial number, or by another identifier.
Traceability of the product alone is generally not the purpose of the packaging identifier requirement
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How should recyclability be demonstrated in practice from August 2026 onwards, and what should the EU DoC state regarding recyclability?
The European Commission has provided further clarification in Section 6 of its guidance. According to the guidance, the requirement applies from 12 August 2026 onwards.
The Commission has further clarified that Manufacturers are not required to demonstrate conformity assessment for recyclability or include information on recyclability in the EU Declaration of Conformity before the delegated act establishing Design for Recycling (DfR) criteria enters into force. Manufacturers may use the existing recyclability standard EN 13430:2004 developed under the Packaging Directive.
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Are PFAS determinations required only for packaging that comes into direct contact with food?
According to the Commission's interpretation set out in Section 5 of its guidance: "Food contact packaging is packaging which is intended to be brought into contact with food or is already in contact with food and was intended for that purpose, as per the scope of EU food legislation." Based on this, food contact material can be interpreted through Framework Regulation (EC) No 1935/2004 and would appear to cover situations beyond direct contact with food.
The Commission has stated that it will further clarify this interpretation in future updates to its guidance. No timetable has been provided for a possible update.
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Is it sufficient for the EU DoC to obtain technical material specifications from a supplier (for example, for paperboard and plastic materials)? Must material claims be verified through laboratory testing, for example if a plastic bag is claimed to be made of PP plastic?
The Manufacturer must carry out a conformity assessment for packaging, prepare technical documentation and, based on these, draw up an EU DoC in accordance with the procedure set out in Annex VII of PPWR. Required elements of technical documentation are listed in Annex VII, including test reports.
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If an EU DoC is required for each packaging type, can packaging of the same type sourced from three different manufacturers be covered by a single Declaration of Conformity, even if sizes differ and materials vary slightly?
European Commission FAQ, Chapter XV, Question 11 provides further clarification on this matter. If the materials differ, even slightly, separate EU DoCs may be required. The question does not specify which materials are used or what is meant by differences in materials. However, as a general rule, packaging made from different materials requires separate EU DoCs, as properties relevant to PPWR requirements may change when materials change.
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How should a "packaging type" be defined for transport packaging when packaging consists, for example, of a pallet, edge protectors and shrink wrap? In other words, for which combination should an EU DoC be prepared?
Transport packaging is considered a separate packaging type for which the actual Manufacturer prepares the EU DoC, unless the transport packaging is clearly branded (see also European Commission FAQ, Chapter VX, Question 12). If the manufacturer of transport packaging acts as a supplier, it must provide the Manufacturer with all information and documentation necessary to demonstrate that the packaging and packaging materials comply with PPWR.
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In relation to transport packaging, this answer appears to suggest that an EU DoC may be prepared for individual packaging components: "12) Does transport packaging also require a conformity assessment and a declaration of conformity? There is no exemption for transport packaging. Indeed, completely different packaging types, such as pallets, pallet collars, wrappings and straps, must undergo separate assessments and must have separate declarations of conformity."
An EU DoC is prepared for each packaging type. Transport packaging consists of separate packaging types for which the actual Manufacturers prepare EU DoCs. If the manufacturer of transport packaging acts as a supplier, it must provide the Manufacturer with all information and documentation necessary to demonstrate that the packaging and packaging materials comply with PPWR.
Providing documentation
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Does PPWR require Declarations of Conformity to be provided to customers, or only to authorities and only upon request?
PPWR does not contain any requirement for "certificates of conformity". Compliance of packaging is demonstrated through an EU Declaration of Conformity (EU DoC). The EU Declaration of Conformity must also be provided to a customer if the customer requires documentation for preparing its own declaration. This may be the case where the customer is the Manufacturer of the packaged product and you are the supplier of the packaging. An EU DoC does not need to be provided to a distributor. Economic operators must provide documentation to authorities upon request. Documentation must be retained for five years (single-use packaging) or ten years (reusable packaging) after packaging or the packaged product has been placed on the market.
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Customers are requesting various technical documents related to PPWR. As a manufacturer, are we required to provide them and, if so, which documents?
If you are a supplier of packaging or packaging materials, you are required to provide the Manufacturer of the packaged product or packaging with all information and documentation necessary to demonstrate compliance of the packaging. This includes information relating to substances in packaging, minimum recycled content and recyclability of packaging (see Articles 5–12). It should be noted that PPWR requirements enter into force with different transitional periods.
Preparation of technical documentation and the EU DoC is the responsibility of the Manufacturer of the packaging or packaged product. If you manufacture unbranded transport packaging, service packaging or primary production packaging, you must prepare technical documentation and an EU DoC for those packaging types.