PPWR: What this means for the chemical industry and Polychem Systems’ clients

What is the PPWR and what changes does it introduce?

“PPWR” stands for the Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40 on packaging and packaging waste). It replaces Directive 94/62/EC, which has been in force since 1994. Importantly, the PPWR applies directly in every European Union Member State, without the need for transposition into national law.

The regulation is a comprehensive legal act that fundamentally transforms the approach to packaging. Primarily, it aims to restrict the volume of packaging placed on the market, thereby reducing the amount of packaging waste generated. Furthermore, it shifts the burden of responsibility for packaging quality and its properties to the design stage and the point of placing the packaging on the market. New packaging must be designed for reusability and easy recycling in industrial conditions. This approach is intended to help conserve resources through the reuse of materials.

All packaging, regardless of the type of material used and its function, must comply with the requirements of the regulation after 12 August 2026. Non-compliance with the regulations will result in a ban on placing the packaging on the market.

The PPWR is a true revolution in every industry – it harmonises rules across the entire EU market and forces every supply chain participant to reassess their packaging strategy, from the manufacturer of the empty container to the filler (manufacturer), importer, and distributor.

Who does the PPWR apply to?

The new regulation imposes obligations on all entities involved in the packaging supply chain. The key to understanding your responsibilities is correctly classifying your company into one of the following roles.

• Manufacturer: The entity that manufactures packaging OR has it manufactured and places it on the market under its own brand/logo. An important nuance: if you purchase empty containers and package your product in them under your own brand, under the PPWR you become the manufacturer of that packaging. The obligation to conduct a conformity assessment, prepare technical documentation, and issue an EU Declaration of Conformity (DoC) rests with you.

• Supplier: The entity that supplies empty containers or packaging materials to the manufacturer. Pursuant to Article 16 of the PPWR, they have a legal obligation to provide the manufacturer with all necessary technical data and partial declarations required to demonstrate the packaging’s compliance with legal regulations.

• Importer: A company based in the EU that imports packaged goods or empty packaging from third countries (e.g. from Asia or the United Kingdom). The importer assumes full legal responsibility; they must ensure that the non-EU supplier has completed the formalities and, in the absence of documents, conduct the tests and compile the documentation themselves, just like a manufacturer.

• Distributor: An entity in the supply chain (other than the manufacturer or importer) that merely makes the goods available on the market under the manufacturer’s unaltered brand. The distributor verifies whether the goods bear the required markings but does not draw up their own DoCs.

Note: It is possible to fulfil multiple roles, depending on the packaging!

The Gradual Implementation of the PPWR Requirements

The cut-off date for the regulation’s initial provisions to take effect is 12 August 2026. It is worth noting, however, that the PPWR is a long-term initiative; the schedule of EU-wide changes extends to 2040. The key packaging sustainability requirements set out in Articles 5–12 of the PPWR will be phased in gradually, and for many of them, detailed application criteria are yet to be defined in the European Commission’s implementing and delegated acts.

The PPWR assesses the entire packaging life cycle and introduces stringent requirements regarding:

• heavy metal content: an absolute limit on the sum of concentration levels of lead, cadmium, mercury, and hexavalent chromium (chromium VI) capped at 100 mg/kg;
• designed for recycling: mandatory recyclability performance grades (A, B, C) from 2030;
• minimum recycled content: a mandatory share of recycled plastics in plastic packaging (targets for 2030 and 2040);
• minimisation of packaging weight and volume: an end to false bottoms and double walls (from 2030);
• void space limits: restricted to 50% in grouped and transport packaging (from 2030);
• use of harmonised labels: information to facilitate waste sorting for consumers (from 2028);
• use of reusable packaging: incentives for reuse.

The regulation also addresses the producer register and Extended Producer Responsibility.

What do the new regulations mean for the construction chemicals sector?

For the chemical and polyurethane sector, implementing the PPWR is a process that extends far beyond standard environmental reporting. Until now, packaging issues were primarily associated with annual reporting to the BDO (the Polish waste management database) and contracts with Packaging Recovery Organisations. From 12 August 2026, packaging becomes an integral part of the product itself and will be subject to rigorous market surveillance.

The chemical industry is already facing several key challenges:

• Stringent limits: the necessity to verify every packaging component (drums, IBCs, tins, and even labels) for heavy metal content.
• Documentation gathering: by purchasing empty packaging and filling it with their product, an entity becomes a manufacturer within the meaning of the PPWR. They must obtain complete technical data from the packaging supplier (e.g. technical data sheets with drawings, specifications, and material composition), even if they did not physically manufacture the container themselves.
• Legal liability for placing packaging on the market: before placing packaging on the market, the manufacturer must carry out a conformity assessment procedure to ensure compliance with the regulation’s requirements, compile technical documentation, and draw up an EU Declaration of Conformity (DoC). Without demonstrating compliance, the legal sale of products will be impossible. Crucially, the regulations do not impose an obligation to pass the DoC further down the supply chain with every individual shipment. However, these documents must be archived and ready to be made available to supervisory authorities upon request.
• Importing raw materials and packaging from outside the EU: in the event of importing raw materials or packaging from third countries, the company becomes an importer. The importer bears obligations virtually identical to those of the manufacturer: they must ensure that the non-EU supplier has provided complete documentation and a declaration of conformity. If the foreign entity fails to do so, full legal liability and the obligation to independently conduct a conformity assessment and compile the documentation fall upon the importer.

Is Polychem Systems implementing the PPWR, and what exact changes will this involve?

At Polychem Systems, we are not leaving things until the last minute. The regulations come into force in mid-August 2026, but we have initiated the process of adapting our production, logistics, and IT systems well in advance.

Our implementation activities include:

• verifying our role as a manufacturer of polyurethane products in the context of each item of packaging;
• inventorying and auditing packaging indices: we are analysing our entire portfolio of primary, secondary, and transport packaging;
• verifying suppliers under Article 16 of the PPWR: we are obtaining partial declarations, laboratory tests, and technical specifications from packaging and raw material manufacturers to confirm that the packaging meets the PPWR requirements;
• upgrading our ERP system: we are adapting our database to ensure full packaging traceability and facilitate the straightforward issuance of EU Declarations of Conformity;
• staff training: we are tracking legislation, regulations, and updates on implementing acts, as well as participating in webinars and external training sessions.

What does the PPWR mean for our clients?

How the new regulations affect our business partners depends on the cooperation model and the brand under which the product is placed on the market.

Products in Polychem Systems branded packaging

When a client purchases our products in standard packaging bearing the Polychem Systems logo, we act as their manufacturer. We assume full legal responsibility: we verify the packaging and issue an EU Declaration of Conformity. You receive a finished product that is 100% legally compliant.

Products manufactured under the private label model

If we fill packaging distributed under the client’s brand or trademark with our product, the brand owner legally becomes the manufacturer of the packaged product. Polychem Systems will then supply the complete set of technical data sourced from the container manufacturers, which is necessary for the client to draw up their own EU Declaration of Conformity. An important exception: if the client is based in Poland and holds micro-enterprise status (employing fewer than 10 people and with an annual turnover or balance sheet total of up to EUR 2 million), the PPWR obliges Polychem Systems to ensure the compliance of the packaging placed on the market alongside the product. This means that we assume the obligations of the manufacturer.

Summary

The PPWR Regulation ushers in a new era in packaging management on the European market. Although the scale of operational and formal changes is significant, we are approaching the upcoming transitions with confidence. 12 August 2026 marks the beginning of a multi-year overhaul of the packaging market in Europe, in which we will be actively participating.
At Polychem Systems, we view the forthcoming requirements not as a hurdle, but as an integral part of building a secure and sustainable value chain. Thanks to our early preparatory work, the harmonisation of our packaging database, and close cooperation with packaging suppliers, we can provide our Partners with complete legal security and guaranteed supply continuity after 12 August 2026.

Do you need support in determining the packaging status for your private label products?

Our expert will be happy to provide you with the information you need.

Author:
Aleksandra Raszke – Environmental Protection Specialist