A packaging supplier often sees itself as a technical link, removed from regulatory obligations that would mainly target its customers placing products on the market. The PPWR overturns this reading. As a manufacturer of empty packaging, you are on the contrary on the front line: it is the packaging that bears most of the regulation’s design requirements, and it is you who designs it. Regulation 2025/40, applicable from 12 August 2026, makes the packaging supplier an actor whose documentation and material choices determine the compliance of the entire chain downstream.

Packaging supplier: why the regulation looks to you first

The logic of the PPWR is simple to grasp. The requirements on durability, recyclability, recycled content or substances apply to the packaging as a product. Yet the packaging is designed and manufactured by you, before it is even filled by your customer. When a brand orders a format from you, it is also buying, without always saying so, a promise of compliance.

In practice, the manufacturer of a packaging item must be able to demonstrate that it meets the regulation’s requirements, draw up the corresponding technical documentation and write a declaration of conformity. If you do not provide these elements, your customer in turn cannot prove its own compliance. The matter then becomes a commercial argument as much as an obligation.

The concrete requirements to carry

Several blocks of obligations are concentrated on the design of the packaging.

Substances of concern

The regulation governs the substances present in packaging. The most immediate ban concerns PFAS in food-contact packaging, applicable from 12 August 2026. For a supplier, this means knowing the actual composition of its materials and being able to attest to it, coatings and additives included.

Minimisation

The regulation calls for reducing the weight and volume of packaging to the minimum needed for its function, and limits excessive empty space. Over-packaging is no longer just a matter of image; it becomes a compliance point that the manufacturer must be able to justify.

Recyclability by design

From 1 January 2030, packaging will have to be designed to be recyclable, according to criteria and performance classes defined by the regulation. This is the most far-reaching issue for a supplier, as it affects the choice of materials, multi-material combinations and elements such as glues, inks and lidding films.

Recycled content

For plastic packaging, minimum recycled-material rates also apply by 2030. Securing a supply of quality recycled material becomes an industrial challenge, not just a regulatory one.

Documentation: your real day-to-day obligation

Beyond the substantive requirements, the heart of compliance work is proof. A packaging supplier must build and keep up to date a technical file per reference, able to answer a simple question: does this packaging meet the regulation, and how can I demonstrate it. Serious customers will start to require these files as a condition of listing. Those who have prepared them in advance will gain a clear commercial edge.

A particular case to know: the customer’s brand

The regulation provides for a situation that concerns you directly. When a micro-enterprise has packaging manufactured under its own brand and its supplier is established in the same Union country, it is the supplier that is regarded as the manufacturer within the meaning of the regulation. In other words, depending on your customer’s profile, you may carry obligations that the customer thought it had delegated to you. It is better to clarify this point in your contracts than to discover it during an inspection. To place each role in the chain, our article on who is affected by the PPWR sorts it out.

Where to start

Three undertakings give a clear trajectory. First, document the actual composition of your ranges, material by material, as everything else follows from it. Next, assess each reference against the recyclability targeted for 2030 and identify the formats to evolve. Finally, prepare a template technical file and declaration of conformity that you can adapt product by product.

To place these obligations within the overall timeline, the regulatory roadmap situates each deadline, and the complete PPWR guide details each requirement. To clarify your exact status, the EPR Responsibilities tool guides you in a few questions.

A question about your specific situation? Write to us at contact@packaginghub.fr.