In short
- There is no turnover or headcount threshold. If you make, import, distribute or fulfil packaging placed on the EU market, the product requirements reach you.
- The micro-enterprise carve-outs are real but article-specific: reuse targets, refill duties on final distributors, and a shift of the manufacturer's obligations in one narrow supply case.
- Being in scope in 2026 is lighter than it sounds. Three things bite now. The rest is 2028 and 2030.
If you manufacture, import, distribute or fulfil packaging that is placed on the EU market, or you are a producer for extended producer responsibility purposes, then yes. Regulation (EU) 2025/40 has applied since 12 August 2026 and it binds by role in the chain rather than by company size. There is no general turnover or headcount threshold, so unlike CSRD a small converter is in scope of the product requirements. The one-minute test is not how big you are, it is what you do to packaging and whether that packaging ends up on the EU market.
What is the test, stated exactly?
Two questions, and both have to be answered yes.
First, is packaging placed on the EU market as a result of what you do? Placed on the market is the trigger, not manufactured in the EU. An importer bringing in filled or empty packaging is caught by the same product requirements as a converter in Belgium.
Second, which role do you occupy? The regulation names manufacturers, importers, distributors, fulfilment service providers and producers for the purposes of extended producer responsibility. Those roles carry different duties, and one company routinely holds more than one. A brand owner that specifies packaging, imports some of it and sells online can sit in three of them at once.
What the test is not: a size test. Anyone who tells you your business is too small for PPWR is describing a different regulation.
Which roles carry which obligations?
| Role | Typical company | What the regulation reaches |
|---|---|---|
| Manufacturer | Converter, printer, moulder | The product requirements on the packaging itself: substances now, and later recyclability, recycled content, minimisation and labelling |
| Importer | Anyone bringing packaging or packaged goods into the EU | The same product requirements, on packaging you did not make |
| Distributor | Wholesaler, retailer, final distributor | Making packaging available, plus the refill and reuse duties placed on final distributors |
| Fulfilment service provider | Third party warehousing and shipping | Named explicitly, so outsourcing the physical handling of a parcel does not move it outside the regime |
| Producer for EPR | Whoever the national scheme designates | Extended producer responsibility, collection and deposit systems, which are rebuilt around the product rules |
The row most people miss is the fulfilment service provider. PPWR names them, which closes the gap that would otherwise open when a seller outsources the physical handling of the parcel.
Are micro-enterprises exempt?
No, and this is the misreading that costs the most time.
There is no blanket small-company exemption in PPWR. What exists is a set of targeted carve-outs written into individual articles, all defined by reference to Recommendation 2003/361/EC as applicable on 11 February 2025. The ones the regulation contains are the reuse targets in Article 29, the refill and reuse obligations placed on final distributors in Articles 32 and 33, and a shift of the manufacturer's obligations where a micro-enterprise brand owner is supplied from within the same Member State.
Read that list against what it does not cover. The substance restrictions that started on 12 August 2026 are not on it. Neither is the restriction on environmental claims. A three-person converter making food-contact packaging is inside both.
What actually binds you today if you are in?
Less than the coverage suggests, and it is worth separating the live obligations from the ones being written about.
Live since 12 August 2026. Food-contact packaging may not be placed on the market containing PFAS at or above the Article 5(5) limits: 25 ppb for any single PFAS by targeted analysis, 250 ppb for the sum of targeted PFAS, and 50 ppm for PFAS including polymeric. The sum of lead, cadmium, mercury and hexavalent chromium in packaging or a packaging component must not exceed 100 mg/kg under Article 5(4), and substances of concern must be minimised under Article 5(1). Article 14 restricts environmental claims about packaging properties that PPWR itself regulates: the claim may only be made where the packaging exceeds the applicable minimum requirement, it has to state whether it relates to the unit, part of the unit or all packaging you place on the market, and it has to be demonstrated in the Annex VII technical documentation.
Not yet live. Harmonised labelling arrives in 2028. Recyclability grading, minimum recycled content, packaging minimisation, the banned formats in Annex V, reuse targets and the maximum empty space ratio are 2030 items, each with a "or a number of years from the relevant act, whichever is the latest" qualifier attached.
If you have read that empty space in e-commerce parcels is capped at 40 percent from 2026, that figure is wrong twice. Article 24(1) sets the maximum empty space ratio at 50 percent, and it applies from 1 January 2030 or three years from the entry into force of the implementing act adopted under Article 24(2), whichever is later. That implementing act is not itself due until 12 February 2028.
What do you do if you are in?
Three things, in order, and none of them is a report.
Establish what is in your packaging. Substance compliance is a materials question answered from supplier declarations and, for food contact, from analysis. If you cannot say what a grade contains, you cannot say whether Article 5 is satisfied.
Audit every environmental claim you currently make about packaging. Article 14 is live now and it is the obligation most likely to be breached already, because claims outlive the evidence behind them. Our claims checklist sets out what substantiation has to look like in practice.
Build the material composition dataset once. The 2030 requirements are recycled content by polymer, recyclability grade and minimisation. All three run off the same purchase-level material data, and so does any product footprint a customer asks you for. Building it twice is the avoidable cost here.
What do you do if you are out?
Check again from the buyer's side, because being outside the regulation does not put you outside the paperwork.
If you supply material or components to someone who is in scope, their Article 5 and Article 14 evidence has to come from you. That request arrives as a supplier questionnaire rather than as a legal obligation, which is the same pattern we describe in what a value chain cap does to ESG questions.
Does being in scope mean you now need a carbon footprint?
No. PPWR creates no greenhouse gas accounting obligation at all. There is no footprint, no inventory and no product carbon footprint requirement anywhere in it. It is a materials and waste regime that happens to land on the same desk that receives the carbon questionnaires, which is why the two get conflated.
The honest connection is that the dataset overlaps. Material composition and recycled content by polymer or grade is exactly what an EPD or a product carbon footprint runs on, so the work is reusable in one direction. The Hedgehog platform does the organisational carbon side of that and reports 5,000+ users on its platform page. The limitation to know before you assume it covers PPWR too: a mid-market reviewer on G2 in June 2026 said it is less complete as a broad ESG reporting platform, with no data source management feature. PPWR compliance is a document and specification problem, and carbon software is not where it lives.
Sources: Regulation (EU) 2025/40 (OJ L, 2025/40, 22 January 2025), European Commission news item of 11 August 2026, Hedgehog platform, Hedgehog on G2. Verified 28 August 2026, re-checked 17 September 2026 with no changes needed.
Facts on this page were last verified on 2026-09-17.
