7 PPWR Compliance Steps for UK Exporters

Our guide to the key PPWR requirements explains the wider regulatory framework and implementation timetable. This article focuses on the practical side of PPWR compliance, following a UK business that manufactures and packages its own products for export to the EU and highlighting seven actions that can help reduce compliance risks.

The worked example follows products exported from Great Britain (England, Scotland and Wales) to EU markets. Northern Ireland operates under different arrangements through the Windsor Framework, meaning some PPWR requirements apply differently. DAERA guidance explains which provisions currently apply and how businesses should assess their obligations.

1. Identify who is responsible for PPWR compliance

Let's start with your homeware business making ceramic vases in Great Britain and selling them under your own brand. You buy branded boxes, protective inserts and labels from suppliers in Great Britain, pack the vases, and sell them to a French wholesaler for resale.

Your business is the manufacturer for PPWR purposes, even though another company makes the boxes. You are responsible for checking that the finished packaging meets the applicable rules and keeping the evidence. That check is called a conformity assessment; step five explains what it involves.

The French wholesaler is the importer because it first places your packaged goods on the EU market. It needs to check that you have completed the packaging assessment and paperwork, so agree what you will provide before the goods are supplied.

The wholesaler is also the EPR producer in France and will need to ensure compliance there. In most countries this is done by joining a collective compliance scheme, which covers financing the management of packaging waste and supports their registration and reporting duties. Requirements and the EPR scheme operator will differ in each country in the EU.

If you sell the same boxed vase directly to a French consumer, your business takes on the French EPR producer role.

The business responsible for checking the packaging and the business responsible for EPR can therefore be different. For each country, establish whether you or your customer must register and report.

2. Check packaging EPR registration requirements in every EU country

Check registration and scheme arrangements in each EU country where your business is the EPR producer. For our vase-maker, this includes direct sales to French consumers or other end users; the wholesaler handles the French obligations for goods bought for resale.

Continue using the national systems already operating. Check that your existing registrations cover the countries where you sell and the sales for which your business is responsible under EPR.

PPWR will introduce common formats for the information you submit, while keeping separate national registers. The Commission has consulted on its proposed rules for these formats, but has yet to adopt them. Once the first set of rules takes legal effect, EU countries will have 18 months to bring their producer registers into line.

For packaging supplied to Northern Ireland, UK packaging EPR (pEPR) applies. You must also meet the PPWR requirements that apply there, including substance limits and the assessment and documentation needed to demonstrate compliance. New labelling and recyclability requirements will be phased in later.

If you sell from the UK directly to EU customers who use rather than resell your goods, you must appoint a local person or organisation to act for you on packaging EPR in each country concerned. This is your Authorised Representative, and the appointment must be agreed in writing.

The registration process differs between countries. In France, if you join a packaging compliance scheme, it registers your business with the national authority and sends you your producer identification number. A compliance scheme manages packaging-waste obligations collectively for its members. In Germany, you must register your own business in LUCID, the national packaging register. Your authorised representative handles other EPR duties, but cannot complete that registration for you.

For help arranging representation and managing registration and reporting, talk to us at ERP UK. As part of Landbell Group, we can support your packaging compliance across EU countries.

3. Understand Current and Future PPWR Compliance Requirements

With packaging you are sending to the EU now, the substance limits are an immediate concern. Heavy-metal limits apply across packaging, while food-contact packaging must also meet the PFAS limits introduced in August. This is why the evidence from your supplier matters. Even if a supplier says it does not add PFAS, that does not establish whether the finished packaging is within the permitted limits.

Ask your supplier for the packaging specification and supporting compliance evidence, including relevant test reports. If you use food-contact packaging, PFAS test reports need to identify the material or packaging tested, the method used and the results, so these can be checked against the limits. If the evidence does not cover the packaging you use, including relevant coatings or other components, ask a suitably qualified laboratory what further testing is needed and keep the evidence with the technical documentation supporting your Declaration of Conformity.

You have more time to prepare for the new EU label showing what the packaging is made from. It will apply from 12 August 2028, or later if needed to allow 24 months after the detailed rules take legal effect. For now, the local labelling rules in the countries you sell into still apply.

That longer timetable is useful when you are talking to suppliers about your next packaging order. A design you choose now may still be in use when the new recyclability, recycled-plastic content and reuse requirements start to apply, mainly from 2030. Ask how the proposed packaging will meet the changes relevant to it. The dates and exceptions vary, and reusable-packaging labels follow a separate timetable.

4. Gather supplier evidence and packaging compliance records

Your packaging suppliers must provide the information you need to demonstrate compliance. Start with the records you already hold, then work out what is missing from your suppliers and your own production or quality team.

For your vase box, the supplier provides the specification for the board, printing, coatings and glue, along with the supporting compliance evidence. The insert and label suppliers do the same for their components. Together, these records should describe the packaging you actually use.

Your packing records complete the picture: which box, insert and label go with each product, how they are assembled, and any tape or glue your team adds. Link these records to the specification version and production batch. If a contract packer does the work, arrange to get the same information from them; your business still has responsibility for its own-brand packaging.

The records need to keep up with production. A change of coating or adhesive could mean an old test report no longer covers the pack. Agree how suppliers and any contract packer will tell you about changes, and check whether the assessment needs updating before using the revised packaging. Include changes made by your own team.

5. Complete your PPWR conformity assessment and declaration of conformity

Review the supplier evidence and packing records together to establish whether the finished pack complies. This conformity assessment can be done by a suitably qualified colleague or packaging specialist. Your business remains responsible, and EPR scheme membership does not necessarily include the work.

Keep the supporting evidence in a technical file. It should explain which rules apply, what risks were considered and how compliance was established, using the packaging specifications, relevant drawings, standards or methods, assessments and test reports.

For your vase box, assess the box, insert and label together. One declaration can cover the unit, but evidence for unprinted board alone will not cover the finished pack. Check who is responsible for the declarations covering your shipping cartons and pallets too; the retail-pack declaration does not automatically cover them.

Once compliance is established, prepare the EU Declaration of Conformity (DoC), your formal statement that the packaging complies, using the prescribed template. Identify the packaging, have it signed and dated, and use the language required by the destination country. A product declaration does not automatically cover its packaging.

6. Provide PPWR documentation to your EU importer

The French wholesaler must check your assessment, paperwork, labels, packaging identification and contact details before putting the goods on the EU market, and provide its own contact details.

Give the importer the signed DoC and agree how it can access your technical file. It must retain the declaration and make the file available to authorities, without needing its own copy of every supporting document.

Keep your declaration and technical file for five years after single-use packaging is placed on the market, or 10 years for reusable packaging. The importer's retention and access duties last as long. Agree a named contact: either business may need to produce the documents within 10 days of a reasoned request from an authority.

The importer must hold back packaging it has reason to believe is non-compliant.

7. Manage Packaging EPR Reporting Across EU Markets

We recommend keeping a record for each country showing the responsible business, registration number, packaging covered, scheme or representative, and reporting deadlines. Agree who checks and submits the figures, and what data customers handling EPR need from you.

The specifications gathered for your packaging assessment also provide the weights and materials needed for reporting. Combined with sales and shipment records, they show how much packaging went to each country. You will need to separate the sales reported by the French wholesaler from direct sales you must report yourself - this helps prevent gaps or double counting. Those calculations need to reflect the packaging actually shipped, so a change in the box or insert may also change the figures.

Keep UK packaging EPR reporting separate. An EU registration does not cover those obligations, even where both reports use the same records.

Smaller businesses selling directly to consumers can find details of Landbell Group's registration and reporting service in our guide to PPWR support. Packaging assessment is not included.

Need Help with PPWR Compliance Across Europe?

Completing these seven steps will help demonstrate PPWR compliance, establish clear responsibilities for registration and reporting, and ensure the necessary evidence and documentation are in place before your products reach EU markets.