Free download  ·  First edition, September 2026

PPWR Compliance FAQ

Thirty-five questions on the EU Packaging and Packaging Waste Regulation, answered for the Irish market — against Regulation (EU) 2025/40, the Commission's guidance and its second-edition FAQ.

  • Which role you hold — manufacturer, producer, importer, distributor — and what each one triggers
  • Why a supplier's compliance certificate is not your Declaration of Conformity
  • What Repak membership does and does not cover
  • What already applied on 12 August 2026, and what is still to come
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Cover of the Ninety8 Compliance PPWR Compliance FAQ
17 pages  ·  PDF  ·  5 sections

The obligation most organisations missed

PPWR has applied since 12 August 2026. Most preparation has been aimed at the 2030 material targets — recyclability, recycled content, empty space. Those matter, and they will take redesign.

But the obligation that took effect first is a documentation obligation. Every distinct packaging type placed on the EU market needs a signed Declaration of Conformity, backed by a technical file, producible within ten days of a request. There was no transition period and no sell-through allowance. That is why organisations working towards 2030 are frequently non-compliant today.

12 Aug 2026 Applied in full. No transition, no grace period.
10 days To produce the declaration and technical file on request.
1 per type A blanket declaration across a portfolio does not qualify.

What's inside

1

Scope — what counts, and who it reaches

Domestic-only sales, transport and B2B packaging, labels and tape, intra-group movement, export.

2

Roles — who carries which obligation

Manufacturer against producer, importers, distributors, repacking, the micro-enterprise question, delegation.

3

Substances of concern

Heavy metals and PFAS limits, what supplier evidence actually discharges, when testing becomes the fallback.

4

Declaration of conformity and the technical file

How many you need, grouping, who signs, what goes in the file, retention, and the supplier-certificate trap.

5

Marking, enforcement, and the Irish position

What goes on the pack now, existing stock, who enforces it here, what Repak covers, and the road to 2030.

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Where this usually starts

A PPWR Position Review establishes every role you hold, builds the packaging inventory, assesses each type against the obligations in force, and returns a prioritised gap register with an owner and a date against each item. Fixed fee, delivered remotely.

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Thirty minutes, no charge.

Written by Ninety8 Compliance. Regulatory and technical guidance for organisations placing products on the EU market.

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