Across the projects we support, we see the same pitfalls among companies that are only starting now.

1. Suppliers are unaware of their own obligations

Under the PPWR, packaging manufacturers have an explicit documentation obligation. They must draw up a declaration of conformity and make technical documentation available to their customers.

In practice, many suppliers – including large ones – are not yet ready for this. They have not set up an internal procedure, do not know exactly what information is required, or are themselves still waiting for data from their own supply chain.

This has direct consequences for producers and importers. If documentation is missing, you are the one who has to produce the evidence in an inspection – and you may not be able to.

2. For hazardous substances, declarations are not enough

For the restrictions on hazardous substances – and certainly for PFAS – a supplier declaration is not enough.

The PPWR calls for test reports as proof, not just self-declarations. Many businesses do have a statement that their packaging “meets the PFAS limits”, but no test reports to demonstrate it.

And this is exactly where time becomes a risk. Test reports often have to be commissioned from specialised laboratories, and lead times can mount up quickly.

3. Businesses are unclear about their own role

If your brand name is on the packaging, in most cases you are the producer – even if you do not produce or fill the packaging yourself. This also applies to retailers’ private-label packaging, for example.

And if you operate in several EU countries, you count as a producer in each one separately, with the obligations that come with each market. The division of roles determines who must draw up documentation, who is responsible in the event of non-conformity, and who must later register as a producer. Without a clear view of who plays which role, compliance quickly becomes difficult.

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