# The PPWR moved packaging duties off Member States and onto one named company per pack

> Directive 94/62/EC told Member States what packaging had to achieve and left them to decide who in the chain carried it; Regulation (EU) 2025/40 applies directly, splits the old essential requirements into separate articles with their own dates, names one manufacturer for each pack and makes that company draw up a technical file and an EU declaration of conformity.

Publisher: Strategic Packaging Insights  
Published: 2026-10-31  
Last updated: 2026-10-31  
Page: https://www.strategicpackaginginsights.com/insights/packaging-directive-to-ppwr-what-changed-brand-owners-converters/

**Directive 94/62/EC told Member States what packaging had to achieve and left them to decide who in the chain carried it; Regulation (EU) 2025/40 applies directly, splits the old essential requirements into separate articles with their own dates, names one manufacturer for each pack and makes that company draw up a technical file and an EU declaration of conformity.**

For 31 years the 1994 Directive reached brand owners and converters only through national law, with conformity presumed for packaging made to harmonised standards. Since 12 August 2026 the Regulation has replaced that chain with one text, yet parts of the Directive still apply to the end of 2028 and 2029, so most packaging files now have to cite both regimes for a while.

## Executive summary

Most coverage of the Packaging and Packaging Waste Regulation (PPWR) treats it as a list of new targets. For brand owners and converters the larger change is structural. Directive 94/62/EC set goals for Member States, and each Member State chose who in the supply chain had to meet them. Regulation (EU) 2025/40 applies the same text in all 27 Member States and assigns each duty to a defined role.

Four shifts follow. First, the legal form: the Directive needed 27 national laws to reach a company, and the Regulation needs none, although Member States still run EPR schemes, registers and penalties. Second, the essential requirements of Annex II, three short groups of design rules, are now split across Articles 5 to 12, and each runs on its own clock between 2026 and 2030 and later. Third, the Regulation defines a manufacturer, normally the company whose name or trademark is on the pack, and the Commission reads the text as allowing only one manufacturer per supply chain. Fourth, that manufacturer must hold a technical file and an EU declaration of conformity for 5 years, or 10 for reusable packaging.

The switch is not clean. Article 70(1), read in the unofficial German consolidated text, keeps the Directive's minimisation rule to 31 December 2029 and several target and reporting articles to 31 December 2028. Commission guidance of 10 June 2026 keeps the old recyclability regime until Article 6(2)(a) applies, no earlier than 1 January 2030.

SPI analysis

The work for brand owners is mostly about ownership of files; the work for converters is mostly about information. A brand owner that puts its trademark on a pack is the manufacturer, even when a converter designs and makes it. A converter becomes the manufacturer only for packaging sold under its own name, or for a micro-enterprise client in the same Member State.

Three moves matter most now: assign the manufacturer and producer for every pack and country, start declarations for the requirements already in force, and replace references to the Directive and its national transposing laws in contracts and specifications. Detailed Ledgers on each requirement are linked in the sections below rather than repeated here.

## Key findings

1. The Directive ran from publication on 31 December 1994 to general repeal on 12 August 2026, about 31.6 years by SPI's calculation, with seven amending acts between 2003 and 2018 (EUR-Lex consolidated text, 4 July 2018; DG ENV).
2. Both texts gave operators the same 18-month runway: the Directive's transposition deadline was 30 June 1996, 18 months after publication, and the Regulation applied 18 months after its entry into force on 11 February 2025, by SPI's calculation (Legislative Observatory).
3. Annex II of the Directive grouped its essential requirements in three points; the Regulation spreads the same ground across seven sustainability articles, Articles 5 to 11, plus labelling in Article 12, with start dates from 12 August 2026 to 1 January 2030 or later (Exhibit 3).
4. The Directive defined no manufacturer or producer; the Regulation defines both, and Commission Notice C/2026/3084 reads Article 3(1)(13) as meaning there is only one manufacturer in a supply chain.
5. Under Article 15(3), the manufacturer keeps the technical documentation and EU declaration for 5 years after placing single-use packaging on the market and 10 years for reusable packaging (lxgesetze.de, unofficial German text).
6. Article 70(1) keeps four groups of Directive provisions alive after 12 August 2026, two of them to 31 December 2029, which is later than the 31 December 2028 end of validity EUR-Lex lists for the Directive (Exhibit 12).
7. **SPI calculation:**  a brand owner that launches or changes 200 pack versions a year, a tenth of them reusable, would hold about 1,100 live conformity files at steady state under the Article 15(3) retention periods (Exhibit 8).

## Legal form: from 27 transpositions to one text

A directive binds Member States as to the result and leaves them the form and method. Directive 94/62/EC said so in its own terms: Article 22(1) required Member States to bring into force the national laws needed to comply before 30 June 1996 (EUR-Lex consolidated text). The companies that made, filled and sold packaging never read the Directive as their legal duty; they read Germany's packaging ordinance and later its Packaging Act, France's decree, Spain's packaging law, and so on.

The Directive also protected the single market with one short article. Article 18 of the [consolidated Directive](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:01994L0062-20180704) reads: "Member States shall not impede the placing on the market of their territory of packaging which satisfies the provisions of this Directive." In practice that protection depended on each Member State's transposition. Recital 1 of [Regulation (EU) 2025/40](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202500040) puts the case in one line: "Fragmented rules and vague requirements cause uncertainty and additional cost to economic operators."

The Regulation's answer is direct application. It entered into force on 11 February 2025 and has applied since 12 August 2026 (Legislative Observatory summary). Article 4(2) bars Member States from prohibiting, restricting or impeding compliant packaging on sustainability, labelling or information grounds, according to the SPI depth record for [PR-EU-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-001/), which draws on the Commission's guidance. National room remains only where the text leaves it, for example Article 70(4), which lets Member States keep restrictions on the Annex V point 2 and 3 formats until 1 January 2030.

What stays national matters as much as what moves. Member States still designate competent authorities (Article 40), run producer registers and EPR schemes (Articles 44 to 47) and set penalties (Article 68). Germany, for example, replaced its Packaging Act with the VerpackDG from 12 August 2026 to align national law with the Regulation ([PR-DE-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/germany/pr-de-001/)); the SPI Ledger on [Germany's packaging law in 2026](https://www.strategicpackaginginsights.com/insights/germany-packaging-law-2026-verpackg-plastic-tax/) covers what that act requires.

SPI analysis

The practical effect for a brand selling in many markets is that design and documentation become one EU job, while registration and fees remain a country-by-country job. Teams organised around national compliance managers may need a central owner for the first and can keep the local structure for the second.

## Essential requirements become article-by-article obligations

The Directive's product rules were short. Article 9(1) allowed packaging on the market only if it complied with all the essential requirements of the Directive, including Annex II (EUR-Lex consolidated text). Annex II had three points: manufacturing and composition (minimum weight and volume, design for reuse or recovery, limits on noxious substances), the reusable nature of packaging, and its recoverable nature, split into material recycling, energy recovery, composting and biodegradability. Article 11 added a heavy metals cap of 100 ppm for lead, cadmium, mercury and hexavalent chromium combined, reached in steps of 600, 250 and 100 ppm.

The Regulation takes that ground and writes each element as its own article with a test, a method and a date (Exhibit 3). The Commission's guidance notes that the new Article 6(1) on recyclability is similar to Annex II point 3(a) of the Directive, but not the same, and that manufacturers follow the Directive's requirements until Article 6(2)(a) applies.

Three things change in the nature of the duty, not only its location. The first is measurability. Annex II asked that weight and volume be kept to the minimum adequate amount for safety, hygiene and acceptance, a qualitative test that harmonised standard EN 13428:2004 turned into a documented procedure. The Regulation adds numbers: a 50% empty space cap for grouped, transport and e-commerce packaging in Article 24, and A to C recyclability grades under Article 6.

The second is the start date. Under the Directive, every essential requirement applied from the same date, three years after entry into force. Under the Regulation, PFAS limits in food-contact packaging have applied since 12 August 2026, the harmonised label no earlier than 12 August 2028, and minimisation, empty space and the Annex V format restrictions from about 1 January 2030 (SPI depth record [PR-EU-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-001/), citing the Commission's guidance).

The third is that some duties have no Directive ancestor at all. Exhibit 4 lists them. A brand owner's gap analysis that only maps old requirements onto new articles will miss them.

The Directive's Member State targets did not vanish. Recital 151 of the Regulation says that the recycling targets added by Directive (EU) 2018/852, and the rules for calculating them, should be retained. The 2025 and 2030 rates, 65% and 70% of all packaging waste by weight, now sit in Article 52, and Article 43 adds per-person waste prevention targets of 5%, 10% and 15% against 2018 for 2030, 2035 and 2040. The SPI Ledger on [PPWR waste prevention targets](https://www.strategicpackaginginsights.com/insights/ppwr-waste-prevention-targets-per-capita-2030/) covers what those mean for brands.

## Who is obliged: the manufacturer and the producer

The Directive never said which company had to comply. Article 3(11) defined economic operators only as a list: suppliers of packaging materials, packaging producers and converters, fillers and users, importers, traders and distributors, and authorities and statutory organisations (EUR-Lex consolidated text). It defined neither a manufacturer nor a producer; the word producer appears only in the definition of packaging, as the start of the chain that runs from the producer to the user or consumer. National laws filled the gap in their own ways, which is one reason a pack could have a different obligated company in each country.

The Regulation separates two roles that national EPR law often merged (Exhibit 5). The manufacturer carries product compliance: design, documentation and labels. The producer carries extended producer responsibility in each Member State: registration, reporting and fees.

The manufacturer test turns on the brand. Article 3(1)(13)(a), as quoted in the Commission's guidance, makes the manufacturer the person that has packaging or a packaged product designed or manufactured under its own name or trademark, whether or not any other trademark is visible on the pack or product. Point (b) carves out micro-enterprises: if the brand owner is a micro-enterprise and its packaging supplier is located in the same Member State, the supplier is the manufacturer. A micro-enterprise has fewer than 10 employees and turnover or a balance sheet total of no more than EUR 2 million (SPI depth record [PR-EU-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-001/)).

The Commission draws a firm conclusion from that wording, in section 2 of its [guidance of 10 June 2026](https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52026XC03084): "The wording of the definition of manufacturer indicates that there is always only one manufacturer in a supply chain within the meaning of the PPWR." The same notice adds that the manufacturer is the sole economic operator bearing legal responsibility for compliance with the sustainability and labelling requirements, whoever drafted the declaration.

The producer is fixed country by country. The guidance says that to decide where EPR obligations apply, it is necessary to check where the packaging is first made available on the territory of a Member State, and that the producer pays the EPR fee in the Member State where the packaging is expected to become waste. One company can therefore be the single EU manufacturer of a pack and the producer in several markets. The SPI Ledger on [the authorised representative rule for non-EU exporters](https://www.strategicpackaginginsights.com/insights/omnibus-ppwr-authorised-representative-non-eu-exporters/) covers the cross-border producer cases in detail.

In practice: Zentrale Stelle Verpackungsregister.

Germany's register authority explains the split in its roles and duties guidance. In the German text of the Regulation the manufacturer is the *Erzeuger*  and the producer the *Hersteller*  (lxgesetze.de, Article 3), so German readers should not read Hersteller as manufacturer. The authority says the Erzeuger is responsible for the design and makeup of the complete pack and prepares the technical documentation and declaration; for commissioned products, the company that puts its name or brand on them is the Erzeuger, even where a supplier is named on the pack. For private-label goods it treats the retailer as the Erzeuger. It also notes that in most cases the earlier option of buying service packaging already enrolled in a scheme by a previous distributor no longer applies.

## A framework: six supply-chain positions

The two definitions combine into a small number of positions. SPI groups them into six, drawn from Article 3(1) points (13), (15) and (17) as quoted in the Commission's guidance and from the German register authority's reading (Exhibit 6). Each position tells a brand owner or converter which file it owns and which it only supports.

Position 3 needs care. A converter is the manufacturer only of packaging that it places on the market under its own name or trademark. Once a brand owner fills that packaging and sells the product under its own brand, the brand owner is the manufacturer of the packaged product. SPI has not yet confirmed how the Commission treats the hand-over between an empty stock pack and the filled product; the guidance's one-manufacturer reading points to the brand owner for the finished pack.

SPI analysis

Most converters therefore sit in a supporting role for most of their volume. Their exposure is commercial rather than legal: a brand owner that must sign an EU declaration will ask for the evidence behind each line, and Article 16 sets information duties for suppliers of packaging or packaging materials. Converters that can hand over a ready-made evidence pack per specification will be easier to buy from.

## Conformity and documentation: from presumption to a signed file

Under the Directive, proof of conformity was a presumption. Article 9(2) required Member States to presume compliance for packaging made to harmonised standards whose references were published in the Official Journal, or to recognised national standards where no harmonised standard existed. The Directive asked for no EU declaration of conformity and no technical file; whatever evidence a company held was a national or commercial matter.

The Regulation imports the product-law model familiar from other EU single market rules. Article 15(2), in the unofficial German text, requires the manufacturer to carry out the conformity assessment under Article 38, or have it carried out, and to prepare the technical documentation listed in Annex VII before placing packaging on the market, then draw up an EU declaration under Article 39. The Commission's guidance confirms that the assessment can be carried out by the manufacturer or by someone else on its behalf, for example a laboratory or a certification scheme, and that the declaration must be drafted by the manufacturer or its authorised representative.

Standards have not disappeared. The Commission's guidance says the Directive's regime and EN 13430:2004 govern recyclability until Article 6(2)(a) applies, and that, under Article 70(1)(b), the existing minimisation requirements and their compliance standard, EN 13428:2004, stay in effect until the end of 2029. The Regulation's own presumption of conformity, for harmonised standards and common specifications, sits in Articles 36 and 37. **SPI analysis:**  existing EN 13428 and EN 13430 files are the first evidence for the new declaration, not a stack to archive.

In practice: Maxcess.

A published EU declaration of conformity from Maxcess Sp. z o.o., in Fałkowo, Poland, shows what a first PPWR file looks like for a company that ships goods to EU customers in its own boxes. It covers nine single-use corrugated box sizes with BOPP tape and a plastic invoice holder, cites Article 39 and Annex VIII, and uses Annex VII Module A, internal production control, with no notified body. It states that the declaration is issued under the sole responsibility of the manufacturer. It marks Article 12 labelling as not yet applicable, treats recycled content and design for recycling as applying from 2030, lists supplier documentation for heavy metals as pending for the plastic holder, and sets retention at 5 years for single-use packaging. The date field reads 8/12/2026; SPI has not yet confirmed whether that means 12 August or 8 December 2026.

## Scenario: how many files a portfolio holds

The retention rule turns documentation into a stock that grows until it reaches a steady level. Every new or changed pack version needs its own assessment under Article 15(4), and each file stays on record for 5 or 10 years. SPI modelled three portfolios (Exhibit 8). Launch and change rates and the reusable share are SPI assumptions; the retention periods are from Article 15(3).

Two features of the result matter. Reusable packaging carries double weight: in the high case it is a fifth of new versions but a third of the files held, by SPI's calculation. And the stock takes 5 years to fill for single-use packs and 10 for reusable ones, so the first years understate the load. Under the Directive, the same portfolio carried no EU-level file count at all.

SPI analysis

The number to manage is the version rate, not the SKU count. Artwork changes that do not touch the pack's design or relied standards may not trigger a new assessment, but a change of material, supplier specification or closure probably will, which makes change control the cheapest lever on the workload.

## Which regime governs each requirement, year by year

Because the Directive's essential requirements are being retired one at a time, a single pack can be governed by the Directive on one requirement and the Regulation on another for several years. Exhibit 9 sets out the position SPI reads from the Commission's guidance and Article 70(1).

The material code row carries a detail that is easy to miss. Article 70(2) repeals Decision 97/129/EC, which set the numeric and letter codes printed on packs under Article 8(2) of the Directive, from 12 August 2028. Article 70(1)(a) keeps Article 8(2) alive until 30 months after the implementing act under Article 12(6) of the Regulation enters into force. SPI has not yet confirmed how those two dates interact if the label act is late; the SPI Ledger on [PPWR labelling](https://www.strategicpackaginginsights.com/insights/ppwr-labelling-harmonised-material-label-digital-marking/) tracks that act.

## Re-mapping the legal references

Article 70(5) of the Regulation, in the unofficial German text, says that references to the repealed Directive are to be read as references to the Regulation according to the correlation table in Annex XIII. SPI has not yet read Annex XIII against the Official Journal. Exhibit 10 is SPI's working map from article titles, for specification and contract clean-up, and it should be checked against Annex XIII before it replaces any reference.

The old references sit in more places than most teams expect: supplier specifications that cite Annex II of Directive 94/62/EC, heavy metals statements that cite Article 11, food-contact declarations that bundle packaging compliance, and customer contracts that warrant compliance with a named national transposing law. **SPI analysis:**  a warranty of compliance with a law that has been replaced, such as Germany's former Packaging Act, may no longer describe the buyer's real risk, which is a breach of the Regulation by the manufacturer of record.

## The national layer that remains

Direct application does not remove national law; it narrows its job. Exhibit 11 sets out what Member States still decide.

In practice: Danone.

The SPI Buyers Database profile of Danone, citing its 2025 Universal Registration Document, records that 87% of the packaging it put on the market in 2025 was designed for recycling, measured against the PPWR definition, with a goal of 95% or more by 2030. That is one sign of how brand owners are moving their own metrics from Directive-era recyclability language to the Regulation's tests before those tests formally apply. SPI has not seen the method Danone uses where the Article 6 delegated acts are not yet adopted, and does not judge the figure; the SPI Ledger on [PPWR recyclability grades](https://www.strategicpackaginginsights.com/insights/ppwr-recyclability-performance-grades-design-for-recycling/) sets out what the grades will require.

## The repeal timeline

DG ENV states that the Directive was generally repealed on 12 August 2026 and that some provisions continue to apply after that date. Article 70(1), in the unofficial German text, names them in four points: (a) Article 8(2) on material identification, until 30 months after the Article 12(6) implementing act enters into force; (b) Article 9(1) and (2), for the minimisation requirement in Annex II point 1, first indent, until 31 December 2029; (c) Article 5(2) and (3), Article 6(1)(d) and (e) and Article 6a, until 31 December 2028; and (d) Article 12(3a) to (4) on reporting, until 31 December 2028, except the transmission of data to the Commission, until 31 December 2029.

The 2029 dates matter for planning. EUR-Lex lists 31 December 2028 as the date the Directive will no longer be in force (SPI depth record [PR-EU-013](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-013/)), but points (b) and (d) of Article 70(1) run a year longer, and point (a) has no fixed end. **SPI analysis:**  files that rely on the Directive's minimisation rule should be kept valid to the end of 2029, not 2028. The SPI Ledger on [the PPWR after 12 August 2026](https://www.strategicpackaginginsights.com/insights/ppwr-after-august-2026/) covers what applies in each year from the Regulation's side.

## Industry reaction

> "However, some provisions of the existing regulation will continue to apply even after that date."

***European Commission, DG Environment** , [Packaging waste](https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste_en), on the general repeal of Directive 94/62/EC on 12 August 2026, consulted 31 October 2026*

Ireland's Small Firms Association, part of Ibec, told members in June 2026 that the Regulation replaces the 1994 Directive and applies directly and uniformly across all Member States, removing the earlier mix of national rules.

> "Today marks the start of the application of the Packaging and Packaging Waste Regulation (PPWR)."

***EUROPEN** , the European Organization for Packaging and the Environment, [quick guide for businesses](https://www.europen-packaging.eu/news/ppwr-starts-applying-from-12-august-2026-a-quick-guide-to-what-businesses-need-to-know/), 12 August 2026*

EUROPEN's guide says manufacturers will need to show compliance through conformity assessment before placing packaging on the EU market, that requirements phase in over time, and that the rules also apply to companies outside the EU that place packaging on the EU market.

The Commission, for its part, stresses the limits of its own reading. Notice C/2026/3084 says it does not replace, add to or amend the provisions of the PPWR, and that the binding interpretation of EU legislation remains the exclusive competence of the Court of Justice of the European Union. The one-manufacturer reading in section 2 is therefore guidance, though it is the reading national authorities will start from.

## What leaders should do now

1. **Heads of regulatory affairs at brand owners, by 31 December 2026:**  build a role matrix for every pack and Member State naming the manufacturer under Article 3(1)(13) and the producer under Article 3(1)(15), with the legal entity and registered address, using the six positions in Exhibit 6.
2. **Packaging development leads, by the end of the first quarter of 2027:**  open a technical file and EU declaration for each live pack version, starting with the requirements already in force, Article 5 substances and the PFAS limits for food-contact packs, and carrying over current EN 13428 and EN 13430 evidence.
3. **Converter commercial and quality teams, now:**  prepare a standard evidence pack per specification, covering substances, material composition and recyclability data, so that brand owner customers can sign their declarations; separate packaging sold under your own name, where you are the manufacturer, from made-to-order packaging, where you are not.
4. **Legal and procurement, during the 2027 contract round:**  replace warranties that cite Directive 94/62/EC or national transposing laws with references to the Regulation's articles, and add clauses on data supply under Article 16 and on change notification that would trigger reassessment under Article 15(4).
5. **Quality and change control owners, by mid-2027:**  define which pack changes trigger a new conformity assessment, because the version rate drives the file count in Exhibit 8.
6. **Compliance teams in Germany and other markets with new national acts, now:**  check registration and scheme contracts against the new role definitions, including private label and service packaging, as the German register authority describes.
7. **Records managers, by 31 December 2026:**  set retention at 5 years for single-use and 10 years for reusable packaging from the date of placing on the market, and keep Directive-era minimisation files valid to 31 December 2029.

## Questions for your board

- For each pack we sell in the EU, which legal entity is the manufacturer, and does it know it signs the declaration?
- In which Member States are we the producer, and does that list match our EPR registrations?
- How many pack versions do we launch or change each year, and who controls changes that trigger reassessment?
- Which of our suppliers can give us the evidence our declarations need, and which cannot yet?
- Which of our contracts and specifications still cite the 1994 Directive or a replaced national law?
- If an authority asked for a technical file, could we hand it over within 10 days?

## What to watch

- **31 Dec 2026:**  the recycled content calculation method due under Article 7, the first of the secondary acts on the Commission's watch list (SPI depth record [PR-EU-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-001/)).
- **30 Jun 2027:**  rules for calculating re-use targets due (Commission Green Forum, as recorded for [PR-EU-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-001/)).
- **1 Jan 2028:**  design-for-recycling delegated acts due, which set the date the Directive's recyclability regime ends.
- **12 Aug 2028:**  Decision 97/129/EC material codes repealed; earliest date for the harmonised sorting label.
- **31 Dec 2028:**  Directive target, calculation and most reporting articles cease; EUR-Lex end of validity.
- **31 Dec 2029:**  the Directive's minimisation rule and data transmission duty cease.
- **1 Jan 2030:**  PPWR minimisation, empty space and Annex V format rules apply; national format bans kept under Article 70(4) lose protection.

## Methodology

- **Data used:**  SPI rule records [PR-EU-013](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-013/) (Directive 94/62/EC) and [PR-EU-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-001/) (Regulation (EU) 2025/40) in the [SPI Regulation Tracker](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-013/), with [PR-EU-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-002/) to [PR-EU-010](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-010/) and [PR-DE-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/germany/pr-de-001/) for dates, and the SPI Buyers Database Danone profile. The tracker holds 79 rules in 25 jurisdictions; this piece uses the EU and German records only.
- **Text of the Directive:**  read in the EUR-Lex consolidated text of 4 July 2018 and the original 1994 text.
- **Text of the Regulation:**  the EUR-Lex HTML text of Regulation (EU) 2025/40 provides the recitals, which are quoted from it. Articles 3, 15 and 70 were read in the unofficial German consolidated text on lxgesetze.de and are paraphrased in English, not quoted. The article and annex structure comes from the unofficial Lexaris table of contents. Article 3(1)(13) is quoted as reproduced in Commission Notice C/2026/3084. SPI has not yet confirmed the English wording of Articles 4, 15, 68 and 70 against the Official Journal.
- **Mapping:**  Exhibits 3, 4 and 10 map Directive provisions to PPWR articles by subject and article title. They are SPI's working maps, not the Annex XIII correlation table.
- **Calculations:**  years and months between dates and the file counts in Exhibit 8 are by SPI's calculation; Exhibit 8's inputs other than the retention periods are SPI assumptions.
- **Cut-off:**  31 October 2026.
- **Limitations:**  this is SPI's reading of official texts and Commission guidance, not legal advice. The guidance is not binding. National successor laws vary and SPI has covered only Germany here. Check with counsel before changing a role assignment, declaration or contract.

## Sources

1. EUR-Lex, Directive 94/62/EC on packaging and packaging waste, consolidated text of 4 July 2018, [https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:01994L0062-20180704](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:01994L0062-20180704), consulted 2026-10-31.
2. EUR-Lex, Directive 94/62/EC, original text, OJ L 365, 31 December 1994, [https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:31994L0062](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:31994L0062), consulted 2026-10-14.
3. EUR-Lex, Directive 94/62/EC, document information page, [https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A31994L0062](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A31994L0062), consulted 2026-10-14.
4. EUR-Lex, Regulation (EU) 2025/40 on packaging and packaging waste, OJ L, 22 January 2025, recitals, [https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202500040](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202500040), consulted 2026-10-31.
5. EUR-Lex, Regulation (EU) 2025/40, ELI record, [https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng](https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng), consulted 2026-10-31.
6. European Commission, Notice C/2026/3084, guidance document for Regulation (EU) 2025/40, OJ C, 10 June 2026, [https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52026XC03084](https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52026XC03084), consulted 2026-10-31.
7. European Commission, DG Environment, Packaging waste, [https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste_en](https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste_en), consulted 2026-10-31.
8. European Parliament Legislative Observatory, summary of Regulation (EU) 2025/40, [https://oeil.europarl.europa.eu/oeil/en/document-summary?id=1802233](https://oeil.europarl.europa.eu/oeil/en/document-summary?id=1802233), consulted 2026-10-31.
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11. EUR-Lex, Commission Decision 97/129/EC, document information page, [https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:31997D0129](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:31997D0129), consulted 2026-10-14.
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16. Zentrale Stelle Verpackungsregister, Rollen und Pflichten, [https://www.verpackungsregister.org/hilfe/rollen-pflichten](https://www.verpackungsregister.org/hilfe/rollen-pflichten), consulted 2026-10-31.
17. Maxcess Sp. z o.o., EU Declaration of Conformity, MXI-PPWR-DOC-POL-CORRUGATED-001, [https://www.maxcessintl.com/wp-content/uploads/2026/08/MXI-PPWR-DOC-POL-CORRUGATED-001.pdf](https://www.maxcessintl.com/wp-content/uploads/2026/08/MXI-PPWR-DOC-POL-CORRUGATED-001.pdf), consulted 2026-10-31.
18. EUROPEN, PPWR starts applying from 12 August 2026: a quick guide to what businesses need to know, 12 August 2026, [https://www.europen-packaging.eu/news/ppwr-starts-applying-from-12-august-2026-a-quick-guide-to-what-businesses-need-to-know/](https://www.europen-packaging.eu/news/ppwr-starts-applying-from-12-august-2026-a-quick-guide-to-what-businesses-need-to-know/), consulted 2026-10-31.
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21. SPI Packaging Buyers Database, Danone profile, citing the 2025 Universal Registration Document, /data/packaging-buyers-database/, consulted 2026-10-31.