PPWR: Is my product a packaging – and who is responsible?

With the EU Packaging and Packaging Waste Regulation (PPWR), new requirements will apply to packaging on the EU internal market from 12 August 2026. Two fundamental questions arise for companies:

• Is the item a packaging within the meaning of the PPWR at all?
• Who is responsible for the packaging’s conformity?

Step 1: Is the item a packaging?

Under the PPWR, what matters is not the form of an item but its function within the supply and use chain.

An item is generally classified as packaging if the following questions can be answered with yes:

• Is the item passed on along the supply chain?
• Does it serve to contain, protect, handle, deliver or present a product?
• Is it not an integral part of the product itself?
• Does it constitute a finished packaging unit?
• Can it be classified as sales, grouped or transport packaging?

Key point: Classification is not decided by the material, the form or the product name, but by the specific intended use.

Step 2: Who bears the responsibility?

The PPWR distinguishes different roles along the supply chain.

Our role: supplier

Semadeni typically supplies packaging, packaging components or packaging materials such as containers, bottles, canisters, cups or closures.

Under the PPWR we therefore regularly act as a supplier. As a supplier we make available to our customers the information and documentation we hold that they need in order to meet their regulatory obligations. This includes, for example, technical specifications, material information or available evidence on the materials used.

Who is a producer?

Central responsibility lies with the company that develops the packaging or has it manufactured, or that places the packaged product on the market under its own name. According to the interpretation of the European Commission, this is often the filler or the brand owner.

The producer is responsible in particular for:

• packaging conformity assessment,
• technical documentation,
• declaration of conformity (DoC),
• compliance with the PPWR requirements,
• proof of recyclability,
• proof of recycled content shares,
• compliance with substance requirements and minimisation rules.

Important information for our customers

Semadeni typically does not know the specific use of the ordered products. Whether a container, cup, canister, pouch or film qualifies as packaging under the PPWR in a given case depends on the actual use.

Before contract conclusion and before placing on the market, the customer is responsible for:

• checking the intended use,
• classifying the item as packaging or non-packaging,
• determining their own role under the PPWR, and
• ensuring that the packaging used meets the applicable PPWR requirements.

Where products are intended to be used as packaging within the meaning of the PPWR, we recommend discussing this with us at an early stage.

Do you need support?

We are happy to support you on questions such as:

• packaging or non-packaging,
• sales, grouped and transport packaging,
• roles under the PPWR (producer, supplier, importer, distributor),
• technical product information,
• material and recycling information.

Further information

Further background on the PPWR and our approach to sustainability can be found in the article on our corporate website:

To the blog article: PPWR and sustainability at Semadeni