Your packaging supplier is not handling your PPWR compliance. You are.

The 12 August 2026 deadline is no longer a distant warning. It is an immediate compliance requirement.

The EU Packaging and Packaging Waste Regulation, PPWR or Regulation 2025/40, came into force in February 2025 and applies generally across the EU from 12 August 2026. For refurbished tech operators, it is probably the most significant piece of packaging legislation in a decade. And most of the industry is either unprepared, misinformed, or quietly hoping someone else will deal with it.

RePack has been working on reusable e-commerce packaging since 2013. We were involved in shaping this regulation during its preparation phase, and we felt its consequences directly when the final text killed provisions we had built our original business model around. We know this regulation in detail. We are not neutral observers, but we are informed ones.

This guide explains what is actually required right now, what is coming later, and what the difference between EU-manufactured and Chinese-sourced packaging means for your compliance position.

What PPWR is

PPWR replaces the older Packaging and Packaging Waste Directive and upgrades it from a directive, which Member States could interpret loosely, to a regulation that applies uniformly across the EU from day one. It covers all packaging placed on the EU market, regardless of where it was manufactured. If you ship refurbished phones to consumers in Germany, France, or Finland, your packaging is in scope.

Internal transfers can also bring packaging into scope. If you use transport packaging that your company did not manufacture to move devices or parts between two of your own processing or repair sites, that packaging is considered placed on the market and PPWR applies.

The regulation runs to 2038 in terms of its full ambition. But the obligations that land on 12 August 2026 are specific, immediate, and not optional.

What is enforceable right now: August 2026

There is a lot of noise about PPWR covering recyclability grades, reuse targets, and void fill limits. Most of that is real, but most of it applies from 2028 or 2030, not today. Here is what actually lands on 12 August 2026.

The Declaration of Conformity. Each packaging type first placed on the EU market from 12 August 2026 must have a signed Declaration of Conformity backed by technical documentation. This is a standalone obligation. It is not linked to CE marking. It is not something your supplier handles on your behalf by default. First establish who the manufacturer is under PPWR. If that is your company, the Declaration and the technical documentation are your responsibility. Manufacturers must also ensure that series production remains in conformity and consider whether changes to the packaging design, its characteristics or the standards referenced require a reassessment.

What can and cannot be delegated. A third party, such as a laboratory or certification scheme, may carry out the conformity assessment on the manufacturer's behalf. An authorised representative may draft the Declaration of Conformity. But the manufacturer cannot delegate the obligation to draw up the technical documentation, and remains legally responsible for compliance. No contract can transfer that responsibility.

One Declaration can cover a complete packaging unit. A body, closure and label do not each need a separate assessment and Declaration, provided the single Declaration includes relevant information on every component. Different sizes may also share one Declaration where the size difference does not affect compliance with Articles 5 to 12.

Existing stock does not have to be destroyed, remanufactured or relabelled merely because it was produced or held in stock but not placed on the market by 12 August 2026. For that stock, the identification and manufacturer information required by Articles 15(5) and 15(6) may be supplied in an accompanying document. Packaging already placed on the market before 12 August 2026 may remain there even if it does not comply with PPWR.

There is an important limit for new production. For packaging manufactured after 12 August 2026, an accompanying document may be used only where it is not possible to put the identifier and the manufacturer's name and address on the packaging itself. This must be assessed case by case, taking account of the packaging's dimensions, shape and functional characteristics.

Substance restrictions. Article 5(4) of PPWR limits the combined concentration of lead, cadmium, mercury and hexavalent chromium to 100 mg/kg in packaging or any packaging component. The Commission FAQ recommends CEN report CR 13695-1/2000 for measuring and verifying compliance. Ask your supplier for a test report or Certificate of Analysis that identifies the method used. Without adequate evidence, you cannot sign a valid Declaration of Conformity.

Article 5(1) also requires manufacturers to minimise the presence and concentration of substances of concern in packaging materials, components and emissions. That obligation applies from 12 August 2026. The FAQ says the assessment should follow Annex C of EN 13428:2004. The standard may still be used until an updated harmonised standard becomes available, but it no longer creates a presumption of conformity with the PPWR substances-of-concern rules.

The manufacturer question: why Chinese-sourced packaging is exposed

This is the part most refurb operators have not thought through.

Case 1: custom-made packaging. Where your company orders packaging made to its specifications, your company is the manufacturer under PPWR. If the packaging has no name or trademark, the decisive question is who placed the order and decided the design specifications. Custom packaging is designed around a specific product, so that power rests with the orderer. A refurb operator that specifies dimensions and materials is therefore the manufacturer, whether or not its logo appears.

As a general rule, if one branded name or trademark appears on the packaging, the owner of that name or mark is the manufacturer, regardless of who physically produces the packaging. The regulation has a narrow micro-enterprise exception where the supplier is established in the same Member State, and cases with different companies' names or marks require an assessment of who controls the packaging specifications.

Case 2: generic standardised packaging. For unbranded standardised boxes bought off the shelf, the company that physically manufactures them is normally the manufacturer. If those boxes are imported from outside the EU, the EU buyer is normally the importer under Article 18, not the manufacturer.

The importer's duties are different. The importer must confirm that the third-country manufacturer carried out the Article 38 conformity assessment and drew up the Declaration of Conformity, check that the Article 15(5) and 15(6) identification requirements are met, ensure the required documents accompany the packaging, and add its own name, registered trade name or trademark, postal address and electronic contact details to the packaging or an accompanying document. The FAQ confirms that these duties also apply to generic and unbranded imported packaging materials.

Documentation. Manufacturers outside the EU are not uniformly prepared to provide PPWR-compliant technical information. Getting the right test reports, material breakdowns and manufacturing documents from overseas suppliers is possible, but it takes time and active management. Many operators have not started.

Missing information for older packaging is not an automatic dead end. Where information for packaging manufactured before 12 August 2026 is missing or insufficient, the PPWR manufacturer must make best efforts. That means requesting it from the former supplier, asking the successor company after a takeover, merger or acquisition, or carrying out its own assessment.

Manufacturer and producer are different roles. The manufacturer carries the Declaration of Conformity and technical documentation duties. The producer is the company that first makes packaging or packaged products available on the territory of a Member State and carries EPR registration, reporting and fee obligations there. A company can be one, both or neither. Establish the manufacturer role first, using the cases above, then establish the producer role market by market.

Producer registration. EPR is not new and it is not waiting for PPWR. National packaging EPR schemes have existed for years under the previous directive, separately in each Member State. A company making packaging or packaged products available to consumers in a Member State for the first time may already owe registration and fees there today, and many cross-border sellers have never registered. PPWR harmonises the registration and reporting data, deadlines and frequency, reporting detail, producer definition and criteria for fee eco-modulation. Member States still retain wide flexibility, and the harmonised registers phase in over the coming years, so existing national duties continue meanwhile.

Selling across Germany, France, Finland and the Netherlands means four separate registrations, and in most cases registration must precede the first shipment into each market. Under Article 39(2), the Declaration of Conformity must also be drawn up in, or translated into, the languages required by each Member State where the packaging is placed or made available, so market surveillance authorities can verify it.

Marketplaces make this visible. Under Article 45, an online platform that lets consumers conclude distance contracts with producers must obtain the producer's registration details for the Member State where the consumer lives and a self-certification that the relevant packaging EPR obligations are met before allowing that producer to use the platform. The platform must make best efforts to assess whether the information is complete and reliable. For refurb operators selling through marketplaces, this is a practical enforcement route that does not depend on a regulator taking an interest first.

There is no general micro-enterprise exemption from producer registration. Producers making less than 10 tonnes available in a Member State in a calendar year have lighter reporting, and Member States may set lower administrative fees for smaller producers, but registration still stands. A separate narrow rule applies where the company that has packaging designed or manufactured under its own name or trademark is a micro-enterprise and its packaging supplier is established in the same Member State. The supplier is then treated as the manufacturer. Whether it is also the producer still depends on the producer definition and the Member State in which the packaging is first made available.

EPR cost structure. Fees are calculated on the weight of packaging made available on the territory of a Member State. A durable box bought once and used for several journeys is one unit made available; four single-use boxes are four units. That follows from the number of units purchased and first made available, and does not depend on whether the durable box is classified as reusable packaging under PPWR.

Where the customer does operate a reuse system, EPR still applies. The Commission FAQ confirms that EPR covers both single-use and reusable packaging, that the obligation stays with the producer, and that the reuse system must include procedures supporting those obligations when packaging in the system becomes waste, as Annex VI, Part A requires.

None of these problems are insurmountable. But they require your procurement team to act now, not later.

Designed for reuse is not the same as placed on the market as reusable

Most operators assume that the classification travels with the packaging. It does not. Article 11 sets out when packaging is considered reusable. The first condition is that it has been conceived, designed and placed on the market with the objective of being reused multiple times. Design is only one part of that test.

The system is the other half. Article 26 requires the economic operator that first makes reusable packaging available in a Member State to ensure that a compliant reuse system is in place there. Article 27 requires economic operators that use reusable packaging to participate in one or more reuse systems and ensure those systems comply with Annex VI, Part A. RePack supplies packaging designed for reuse. It does not operate a reuse system. The customer decides whether to put that system behind the packaging and carries the operating duties if it does.

The same physical packaging can therefore be treated differently in two customers' hands. One customer may use it within a collection, reconditioning and redistribution system and place it on the market with the objective of repeated use. Another may buy the same design and use it once, without any reuse system. The second case does not become reusable packaging merely because the supplier designed it to last.

That classification changes the compliance work. Packaging placed on the market as reusable must meet Article 11, be supported by the Article 26 and Article 27 system arrangements in Annex VI, Part A, and, when Article 12(2) applies, carry the reusable packaging label and digital data carrier. The system must support rotation counting and reporting unless a specific derogation applies. Technical documentation and the Declaration must be retained for ten years rather than five.

The evidence also splits. The Commission FAQ says the manufacturer must demonstrate in the technical documentation, at the time of placing the packaging on the market, that both the packaging design and the related reuse system allow the minimum number of rotations to be met. RePack can supply the design-side evidence. Only the customer or other operator running the system can supply the system evidence, including collection, reconditioning, redistribution and rotation data.

Treat supplier claims with the same distinction. Reusability is a packaging property regulated by PPWR, so Article 14 applies to environmental claims about it. A supplier can accurately describe the design function as designed for reuse where it can substantiate that design and does not present it as proof of the full regulatory classification. Claiming that packaging is reusable, or implying that a reuse system exists when none does, is a different claim and needs evidence for the complete regulatory position.

Article 14 allows claims about packaging properties regulated by PPWR only where they concern performance exceeding the applicable minimum requirements and specify whether the claim relates to the packaging unit, part of it or all packaging placed on the market by the operator. Claims outside PPWR's scope also need to be assessed under consumer law, including the changes made by the Empowering Consumers Directive (EU) 2024/825.

What happens if you do not comply

Non-compliant packaging will not automatically be banned. Under Article 62, a Member State must first require the operator to end the non-compliance. That means a warning and a reasonable opportunity to take corrective action. Prohibition, recall or withdrawal follow only if the non-compliance persists.

The Commission directs market surveillance authorities to support responsible operators rather than take a sanction-oriented approach. That support may include awareness-raising, requests for information and requests for corrective action with a reasonable timeline.

There is no routine notification step. Manufacturers do not have to notify competent authorities merely because packaging is placed on their territory. Authorities make contact when they carry out a check. Notification is required only when a manufacturer or distributor becomes aware that packaging it placed on the market is non-compliant.

The more immediate risk is commercial. The regulator will warn you first, your customers will not. B2B partners, marketplaces and enterprise buyers are already asking for Declarations of Conformity as part of procurement qualification. If you cannot produce one when asked, the result may be a lost contract, a delisted product or a paused shipment. For refurb operators selling through third-party platforms or retail partnerships, that is a more immediate risk than formal enforcement.

What EU-manufactured mono-material packaging means

The clearest path through PPWR compliance is packaging designed with the regulation in mind: EU-manufactured, built from a single recyclable material, with a supplier who can provide the complete technical dossier.

EU-manufactured packaging comes with a shorter and more legible supply chain. The supplier is subject to EU regulations directly. Material certifications, heavy metal reports, and harmonised standard documentation are standard outputs from compliant EU manufacturers.

Mono-material packaging, built from paper without plastic film inserts, laminates, or mixed adhesives, is well positioned for the 2030 recyclability grades. It does not guarantee an A or B grade, because the detailed methodology has not yet been finalised, but it avoids the multi-material complexity that is most likely to score poorly.

For refurb tech operators specifically, durability matters beyond the regulatory classification. A box purchased once and used for several journeys is one unit made available for EPR purposes, while four single-use boxes are four units. The economics improve with each additional use whether or not the operator places the durable packaging on the market as reusable under PPWR.

Where to start

The operators who will find August 2026 manageable are the ones who have already been talking to their suppliers. The ones who will find it stressful are the ones who assumed their supplier was handling it.

A note on RePack Vie

RePack Vie is EU-manufactured and built from materials that are straightforward to certify under PPWR.

The tray component is made from a starch and cellulose compound, over 80% bio-based carbon content, derived entirely from plant-based sources. It is recyclable with paper, with a validated 99% fibre recovery rate, and the fibres it adds to the paper stream improve the quality of the recycled paper produced. Heavy metal content is well below PPWR Article 5 limits. The fibres are FSC certified. The carton sleeve is a standard mono-material paperboard. All components are designed for easy disassembly, supporting separation for recycling at end of life.

RePack Vie is designed for reuse and meets the design-side criteria in Article 11. RePack supplies the material, design and test evidence that customers need for that part of their technical documentation.

RePack does not operate a reuse system. A customer that places RePack Vie on the market as reusable must ensure that its own system meets Article 26, Article 27 and Annex VI, Part A, and must count its own rotations. The customer supplies the system-side evidence that RePack cannot supply.

RePack Vie already carries a machine-readable QR code. If a customer places it on the market as reusable, the code is the digital data carrier that its Article 12(2) duty will require, so it does not need to be retrofitted before 12 February 2029 or the later conditional date. This does not mean RePack is meeting the customer's obligation. An open-loop system without a system operator is exempt from the reusable packaging label and data carrier, and from rotation reporting under Annex VI.

REACH Annex IV lists starch and cellulose pulp as substances exempt from registration under Article 2(7)(a). That exemption is substance-specific and should not be read as a blanket exclusion for every ingredient in a cellulose premix.

We provide customers with the design-side documentation for their Declaration of Conformity: material composition data, manufacturing specifications and test reports. Where the customer is the PPWR manufacturer, it remains responsible for assembling the complete technical documentation and Declaration.

A customer that does not operate a reuse system is not placing RePack Vie on the market as reusable packaging. The Article 11 reusable classification, Article 12(2) labelling and Article 26 and Article 27 system duties do not arise, and the technical documentation retention period is five years rather than ten.

The EPR benefit has a separate basis. A durable RePack Vie box bought once and used for four journeys is one unit made available; four single-use boxes are four. That remains true whether or not the customer operates a reuse system and the packaging is classified as reusable under PPWR.

If you want to understand what PPWR compliance looks like in practice for your current packaging setup, we are happy to work through it with you.

If your supplier cannot answer these questions clearly and in writing, you have a compliance gap to close.