The Packaging and Packaging Waste Regulation (PPWR) establishes harmonised EU rules for packaging. For businesses, this includes requirements relating to documentation, traceability and, where applicable, the labelling of packaging.
The Regulation applies to several different economic operators throughout the value chain, and the specific obligations depend both on the type of packaging and the role of the individual business.
Below, we answer some of the questions we are most frequently asked about PPWR, documentation requirements and the allocation of responsibilities.
What is PPWR?
PPWR is the EU Packaging and Packaging Waste Regulation, introduced to harmonise packaging requirements across all Member States.
Among other things, the Regulation requires that packaging, where relevant, can be:
- identified
- traced throughout the value chain
- supported by technical documentation
The technical documentation must demonstrate that the packaging complies with the applicable legal requirements.
Does all packaging need to be labelled?
Not necessarily.
PPWR includes specific labelling requirements that depend on the type of packaging, its intended use and the relevant provisions of the Regulation. There is no general requirement for all information to be physically displayed on every individual packaging unit. However, certain packaging types, materials or applications may be subject to specific labelling requirements.
Labelling requirements must therefore always be assessed on a case-by-case basis for each packaging solution.
Does every package require a QR code?
No.
PPWR does not impose a general requirement for every individual packaging item to carry a QR code or any other form of individual marking.
Instead, the Regulation requires packaging to be identifiable and linked to the documentation demonstrating compliance. This means the packaging must be traceable through a documented and verifiable system, but not necessarily by printing all relevant information directly on each individual package.
Example: A jewellery box may be identified by its product number. That product number is linked to the technical documentation containing information such as material composition, technical specifications and compliance data. This ensures full traceability without requiring every individual box to carry a QR code or extensive physical labelling.
What documentation does PPWR require?
PPWR requires compliance to be demonstrated through technical documentation.
The documentation must be structured, maintained and made available to the relevant authorities upon request.
Depending on the packaging concerned, the documentation may include information relating to:
- material composition
- compliance with applicable legislation
- regulated substances, where relevant
- traceability throughout production, distribution and delivery
What documentation does Westpack provide?
Westpack supports your PPWR compliance by providing relevant product documentation.
For our products, we provide comprehensive Product Declarations containing information including material composition, weight, recyclability and technical specifications. This documentation can be used as part of your own assessment and evidence demonstrating that your packaging complies with applicable requirements.
Who is responsible?
PPWR allocates responsibilities across the different economic operators within the value chain. The specific responsibilities depend on whether your business acts as a manufacturer, importer, distributor or another type of economic operator.
If you have packaging manufactured under your own name or trademark and place it on the EU market, your company is responsible for ensuring that the packaging is correctly labelled, where required, and documented in accordance with the applicable legislation.
As a manufacturer and supplier, Westpack is responsible for the obligations applicable to our role. At the same time, we provide the necessary product and compliance documentation, which can form part of your own assessment and documentation demonstrating compliance with the applicable requirements.
How are PPWR and EPR connected?
PPWR and Extended Producer Responsibility (EPR) are two separate regulatory frameworks that complement one another.
PPWR primarily addresses packaging requirements, documentation, identification and, where applicable, labelling.
EPR defines the responsibilities of the economic operator placing packaging on the market.
Although EPR does not itself impose specific labelling requirements, the responsible economic operator must ensure that the packaging complies with all applicable legislation, including the relevant provisions of PPWR.
How does Westpack work with PPWR compliance?
Westpack applies a proportionate and documented approach to traceability and compliance, tailored to the specific type and application of the packaging.
This ensures a documented link between the packaging and its associated technical documentation, enabling the necessary information to be provided whenever required.
For customised packaging and products with specific design requirements, compliance is achieved through a combination of product identification and supporting technical documentation, rather than physical marking of every individual packaging unit.
Looking ahead
PPWR forms part of a broader European transition towards greater transparency and improved documentation of packaging.
For businesses, this means increased requirements relating to documentation, traceability and the allocation of responsibilities. In certain areas, the final requirements are still awaiting further clarification from the European Commission, and the regulatory framework may continue to evolve as additional guidance and implementing measures are published.
At Westpack, we continuously work to make it easier for our customers to document their packaging and navigate the applicable regulatory requirements.
If you have any questions regarding PPWR, or would like us to review your packaging and the associated documentation, please do not hesitate to contact us.
Last update: 16/07/2026