FAQ - the 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 applies from 12 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.
View the VANA webinar on the Packaging and Packaging Waste Regulation for further information on this (for members; login required).
We continuously update our knowledge page on the Packaging and Packaging Waste Regulationn with new information and hold thematic webinars on, among other things, sustainability requirements, documentation and definitions.
The Ministry of the Environment has stated in its draft bill on the implementation of the Packaging and Packaging Waste Regulation that the harmonisation of the producer and end-user definition may mean that, as of 12 August 2026, the producer responsibility in some cases will be transferred from one producer to another.
We continuously update our knowledge page on the Packaging and Packaging Waste Regulation with new information and hold theme webinars on, among other things, sustainability requirements, documentation and definitions.
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 the information on our website and host a themed webinar in which we will review the requirements. Keep an eye on our website and member newsletter for announcements.
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.