FAQ - Packaging and Packaging Waste Regulation (PPWR)
The Packaging and Packaging Waste Regulation (PPWR) replaces the current packaging directive and is, in principle, directly applicable in all EU member states. The PPWR sets requirements for the entire life cycle of packaging and regulates prevention, design, reuse, recycling and the framework for the extended producer responsibility EPR.
Read more about the Packaging and Packaging Waste Regulation
The Packaging and Packaging Waste Regulation entered into force on 11 February 2025 and was implemented on the 12th of August 2026. Not all requirements enter into force at the same time. From August 2026, the following apply:
Definitions (including for producer, manufacturer, end-user, etc.) cf. Article 3
Certain requirements for substances in packaging, including limits for PFAS in food packaging cf. Article 5
Requirements for technical documentation and declarations of conformity regarding compliance with the sustainability requirements cf. Articles 15–19
Obligations regarding reusable packaging in reuse systems cf. Articles 11, 26, 27 and Annex VI
Obligations regarding refilling in HORECA cf. Article 28
Read more about the Packaging and Packaging Waste Regulation
The Packaging and Packaging Waste Regulation regulates the entire life cycle of packaging and therefore places requirements on all actors in the value chain. As a producer, you may therefore be affected differently depending on whether you are an importer, distributor, manufacturer or final distributor (point of sale).
As regards the extended producer responsibility EPR for packaging, the biggest change is the harmonisation of definitions, including the definition of availability, producer, manufacturer and end user.
Read more about the changes of definitions in VANA guide to PPWR: How to get started here (for members; login required)
View the VANA webinar's on the Packaging and Packaging Waste Regulation for further information on this. There is also a specific webinar about definitions and roles (Danish and for members; login required).
With the packaging regulation, the definition of producer and end user changes from the Danish legislation applicable before August 12 in particularly two areas: the unpacker rule and the new end user definition, which shifts focus from packaging to the packaged product.
Before August 12, 2026
Companies that today import packaged products in transport packaging, which they unpack in Denmark, generally do not have producer responsibility for the transport packaging. In that situation, the responsibility currently lies with the foreign supplier, because the assessment follows the packaging. This will change with the regulation.
After August 12, 2026
From now on, the assessment will more closely follow the packaged product. If the foreign supplier does not sell directly to an end user of the product in Denmark, the supplier will generally not incur producer responsibility for the transport packaging. Instead, the responsibility can be placed on the Danish company that imports and unpacks the product. This is due to the so-called unpacker rule, where the company that unpacks the packaging can take responsibility if no other company has producer responsibility for the packaging.
Read more about the significance of the change in the producer definition in VANA's guide to PPWR: how to get started, here (for memebers, requires login).
See VANA webinars on PPWR here for more information on this (in Danish, for members, requires login).
The Packaging and Packaging Waste Regulation sets out various requirements for the design and construction of packaging in Articles 5-12 — also referred to as sustainability requirements. These requirements apply continuously.
We monitor developments in this area and will regularly update our guide and information on our website along with the ongoing specifications of the requirements and their implementation.
Read more about the sustainability requirements in VANAs guide, PPWR: how to get started, here (for memebers, requires login).
See also VANA's webinar about the sustianability requirements here (in Danish, for memebers, requires login).
The Packaging Regulation (PPWR) takes effect from August 12, which means that producer responsibility may, in some cases, shift from one company to another.
Who is responsible before and after August 12?
Up until and including August 11: The company that was responsible under the current regulations has producer responsibility.
From August 12: The company that meets the producer definition under the new regulations takes over responsibility.
How should reporting to VANA be done regarding the change?
When reporting to VANA on September 1 (for quantities made available in August), the following applies:
Company with responsibility before August 12: Must report quantities made available between August 1 and 11.
Company that takes over responsibility from August 12: Must report quantities made available between August 12 and 31.
Please note that the new responsible company must be registered in DPA and choose a producer responsibility organisation (PRO) if the company has not had producer responsibility before August 12. Registration must be done no later than 14 days before the first availability, which is August 12.
What do we do if we are in doubt about who has producer responsibility?
It is Dansk Producentansvar that has the competence to make a decision if there is doubt/disagreement about the allocation of responsibility.
To assess who is the manufacturer under the packaging regulation, it is particularly relevant to look at:
who manufactures or has manufactured the packaging or the packaged product
who places the order and determines the design specifications
which name or trademark the packaging or the packaged product is labeled with
whether the company is a micro-enterprise
whether the packaging is imported from another EU country or a third country.
A manufacturer is the company that manufactures or has a packaging or a packaged product manufactured. It is not necessarily the company that physically produces the packaging. If the packaging or the packaged product is labeled with a specific name or trademark, it can be assumed that the owner of that name or trademark is the manufacturer. This applies even if another company physically produced or filled the packaging.
The wording of the definition of "manufacturer" indicates that there is always only one manufacturer in a supply chain according to the regulation on packaging and packaging waste.
There are still a number of questionable cases where the allocation of responsibilities under the PPWR has not been definitively clarified, including, among other things, the manufacturer responsibility for grouped and transport packaging. VANA has presented specific examples and issues to the authorities in order to obtain a more concrete clarification and has urged that the guidance in the area be specified.
If there is doubt or disagreement about who has the manufacturer responsibility in a value chain, it is Dansk Producentansvar (DPA) you should contact, as they, as the registration authority, can make the final decision.
If the company that has packaging produced under its own name and trademark is a micro-enterprise and this purchases the packaging from a company in the same country, the manufacturer responsibility will lie with the supplier of the packaging. This applies regardless of whether the latter company is also a micro-enterprise. However, micro-enterprises can still have manufacturer responsibility in cases where they import packaging from the EU or a third country, just as in the Danish regulations.
The company that has another company manufacture packaging or packaged products under its name or trademark is able to determine the characteristics of the packaging, including the branding of the packaging, which can be significant for the assessment of the packaging's compliance.
This also applies when a trader merely opts for a standardized packaging solution and does not request changes to the design or production process.
Read more in the EU Commission's FAQ on PPWR, “Definitions”, point 6.
If the packaging does not bear a name or trademark, the manufacturer can either be the supplier (i.e., the company that actually manufactures the packaging) or the company that puts packaged products into circulation. The decisive criterion is who places the order and establishes the design specifications for this packaging.
The authorities have updated typical questions and answers on their website regarding what applies to packaging with and without trademarks after August 12 with the following:
“Understanding until August 12, 2026:
Packaging is only considered to be manufactured under its own name or trademark if the company’s name or trademark is affixed to the packaging.
Understanding from August 12, 2026:
Packaging and packaged products may be considered to be manufactured under their own name or trademark, even if the packaging does not bear the company’s name or trademark.
What is crucial for whether packaging is considered to be manufactured 'under its own name and trademark' is:
which company places the order for the manufacture of the packaging or the packaged product
which company has determined the design specifications of the packaging
Therefore, it is recommended that companies identify and agree on who has determined the design specifications.”
Read more on The Danish Environmental Protection Agency's website here.
Read more about the manufacturer’s role and responsibility allocation in VANA's guide to the Packaging Regulation – How to Get Started here
As far as sales packaging or grouped packaging is concerned, the manufacturer is typically the trader who performs the final processing steps (e.g., cutting, filling, and sealing) on the packaging supplied by converting companies (i.e., suppliers) and fills it with their product before placing the packaging or the packaged product on the EU market. In other words, the manufacturer for sales packaging and grouped packaging is usually the filler, who is often also the brand owner of the product.
See also the FAQ on "placement of manufacturer responsibility" and "who has the manufacturer responsibility for cardboard boxes without trademark under PPWR?" regarding sales and grouped packaging without a trademark.
Transport packaging is considered as packaging when the empty packaging has reached its final form. This occurs when the packaging is ready to be used as transport packaging without the addition of any further components or supplementary elements.
Here, it is important to distinguish between a combination of different types of packaging (e.g., tape, boxes, wrap, pallets, etc.) and an actual collection/processing of packaging, such as shaping materials or manufacturing a packaging unit from components that do not have an inherent packaging function. The use of several different transport packages together does not mean that each of them has not reached its final form.
For standardised transport packaging without a trademark, the manufacturer will typically be the one who physically produces the packaging.
Examples of packaging definition and placement of manufacturer responsibility:
Cardboard boxes: A cardboard box has reached its final form, even if it is flat and needs to be unfolded before use. If the cardboard box bears a name/trademark, that company must be regarded as the manufacturer. For standardised cardboard boxes without a trademark, the company that physically produces the packaging will be the manufacturer. If a company adds a sticker for shipping purposes, this is not considered a trademark, and thus this company will not be regarded as the manufacturer.
Stretch wrap: Stretch wrap for stabilising packaged products on pallets should be regarded as packaging when sold on a roll, even if it is subsequently cut and used to wrap pallets with products. The manufacturer is the company that physically produces the stretch wrap and markets it as packaging when it is without a trademark, and not the company that purchases the stretch wrap and subsequently uses it to secure goods.
Read more in the EU Commission's FAQ on PPWR, “Definitions”, point 5.
A name or trademark on a packaging is assigned the same weight in determining who has the status of manufacturer under the PPWR.
If a company, for example, manufactures, markets, and distributes products under its own name, e.g., as the responsible food business operator, but under another company's trademark, the status as manufacturer will be attributed to the company that determines the design and specifications of the packaging.
If the licensor, who is the owner of the trademark, for example, requires that a product marketed under its trademark must use a specific packaging design to ensure that the packaging for the products is consistent in member states or globally, the trademark holder will be considered the manufacturer.
Licensors whose trademark appears on the packaging but who do not determine the characteristics of the packaging should, on the other hand, not be regarded as manufacturers.
It will therefore be necessary to make a specific assessment case by case based on the contractual agreement between the two companies, whose names and trademarks respectively appear on the packaging, to determine which company has the decisive decision-making authority.
Read more in the European Commission's FAQ on PPWR, “Definitions”, point 7.
If a company orders custom-made packaging from another company, the company placing the order will be considered the manufacturer according to PPWR.
This is because the determining criterion for packaging that does not bear a name or trademark is who places the order and establishes the design specifications for the packaging. If the packaging is custom-made for a specific product, the characteristics of the packaging will be based on the product, and the decisive decision-making authority will therefore lie with the company that orders the custom-made packaging.
Read more in the EU Commission's FAQ on PPWR, “Obligations of manufacturers”, point 14.
On the website of the Danish Environmental Protection Agency under typical Q&A about Environmental Requirements for Packaging, the following is stated about cardboard boxes:
“A grouped packaging, which is also used for transport, will still be a grouped packaging. The Commission's updated guidance from August 3, 2026, specifies that grouped packaging also includes display packaging and can be removed without changing a product's characteristics, which is the case for the cardboard box around the spreading packages.”
Based on the Commission's guidance material (FAQ) and the above from the Danish Environmental Protection Agency's website, it is VANAs immediate assessment that cardboard boxes should be considered as grouped packaging.
Read more on the Danish EPA's website with Q&A about Environmental Requirements for packaging and the EU Commission's FAQ on PPWR, “Definitions”, point 4.
The Commission's updated guidance of August 3, 2026, clarifies that grouped packaging also includes display packaging, which can be removed without changing the characteristics of the product. This is the case for example for a cardboard box with deli packs. Furthermore, it is clarified that the producer responsibility for packaging without a trademark depends on who places the order and has influence over the design specifications. If the packaging is custom-made for a specific product, the properties of the packaging will be based on the product, and the crucial decision-making authority will therefore lie with the company that orders the custom-made packaging.
On this basis, VANA initially assesses that the trademark holder on the primary sales packaging as a rule also has the producer responsibility for the cardboard box. However, it must always be assessed concretely who has defined its design specifications.
The allocation of responsibility is not finally clarified. VANA has therefore submitted a concrete example to the authorities and urged a clarification of the guidance.
If there is a disagreement or doubt about who has the producer responsibility in a value chain, you should contact Dansk Producentansvar (DPA), as they, as the registration authority, can make the final decision.
Read more in the EU Commission's FAQ on PPWR, “Obligations of manufacturers”, point 14.
See also the FAQ on "Manufacturer of packaging without a trademark"