The EU Packaging and Packaging Waste Regulation (PPWR) introduces a new framework for packaging compliance across the European Union. Much of the discussion has focused on recyclability, labelling and packaging minimisation.
Less attention has been given to another practical question: how will manufacturers actually demonstrate compliance?
Under most EU product legislation, harmonised standards provide recognised methods for demonstrating that regulatory requirements have been met. Under the PPWR, however, those standards have not yet been published.
With the regulation entering into force in February 2025 and beginning to apply from August 2026, manufacturers are left preparing for compliance without one of the tools they would normally expect to rely on.
The usual route to demonstrating compliance
Across European product legislation, harmonised standards play a practical role.
Rather than creating new legal obligations, they provide established technical methods for demonstrating that regulatory requirements have been met. When manufacturers apply the relevant harmonised standards, packaging is generally presumed to comply with the corresponding requirements of the regulation.
This offers a straightforward route to demonstrating compliance and gives both manufacturers and market surveillance authorities a common technical reference point.
For the PPWR, however, that route is not yet available.
Does the absence of harmonised standards delay compliance?
No.
The absence of harmonised standards does not automatically postpone the obligations introduced by the PPWR. Manufacturers remain responsible for ensuring that their packaging complies with the applicable requirements and for being able to demonstrate that compliance.
In other words, the regulatory obligations already exist, even if the supporting standards are still under development. Waiting for harmonised standards is not, by itself, a compliance strategy.
So how can manufacturers demonstrate compliance?
Unlike many other European product frameworks, the regulation does not require the involvement of a notified body. Instead, manufacturers are responsible for assessing conformity themselves and declaring, under their own responsibility, that their packaging complies with the regulation.
Instead, without harmonised standards to rely on, manufacturers need a well-documented approach to demonstrating compliance.
Under the PPWR, manufacturers are expected to prepare documentation that enables competent authorities to assess whether their packaging meets the applicable requirements. The documentation should clearly explain the packaging design, materials, assessment methods and supporting evidence used to demonstrate compliance.
Depending on the packaging, this may include design information, test reports, risk analyses and the technical specifications applied during the assessment.
Preparing before the standards arrive
Harmonised standards are not the only route to determining compliance.
Whether that means reviewing packaging designs, preparing technical documentation or assessing existing compliance strategies, early preparation can make the transition much smoother.
At Obelis, we work with manufacturers to support each stage of that process, helping them prepare for both today’s requirements and those still to come.
How is your company approaching PPWR compliance while harmonised standards are still pending? We’d be interested to hear your perspective.
References:
European Commission (2025). Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC. Retrieved on 14/07/2026.
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