An EU buyer placing an order no longer asks only about price and lead time. They ask about your packaging too: the carton, bottle, film, pouch, pallet wrap. Which material, backed by which records, with which paperwork? The reason is the EU Packaging and Packaging Waste Regulation, PPWR for short, which started to apply on 12 August 2026.
It has been discussed less than CBAM or CSRD, yet its reach may be wider. A carbon declaration touches a handful of sectors. Packaging is part of almost everything sold into the EU.
What is PPWR and when did it start?
The full name is Regulation (EU) 2025/40. According to the European Commission’s environment pages it entered into force on 11 February 2025 and applies from 12 August 2026. It replaces the 1994 Packaging Directive (94/62/EC).
Two differences matter:
- A regulation, not a directive. Member States do not have to transpose it one by one; the rules apply directly across the EU. Country-by-country interpretation shrinks.
- A broad goal. The Commission states the aim of making all packaging on the EU market recyclable in an economically viable way by 2030. Reuse targets, recycled content and limits on certain single-use items are part of the package.
The rules phase in. Not everything started on 12 August 2026; some obligations stretch to 2028 and beyond.
How does it affect a Turkish manufacturer?
Anyone selling packaged goods into the EU is somewhere in this chain. Three typical cases:
- Exporters of packaged consumer goods: food, cosmetics, cleaning products, household items, small appliances. The sales packaging is within PPWR.
- Packaging producers selling into the EU: plastic, paperboard, glass, metal or composite packaging. The packaging is your product.
- Industrial exporters using pallets, wrap or wooden crates: transport and bulk packaging fall within scope as well.
Which obligation lands on the producer, the exporter or the EU importer needs to be split out clearly. If roles are left vague in contracts, a responsibility gap appears. Confirm the role split, and whether an authorised representative in the EU is needed for your product, with your legal adviser or your EU buyer.
What changed from 12 August 2026?
Below is the common ground between the Commission and secondary commentary. Check article numbers and thresholds against the regulation text in the EU Official Journal.
- Hazardous substances. A combined cap applies to lead, cadmium, mercury and hexavalent chromium in packaging (commentary cites 100 mg/kg in total). PFAS in food-contact packaging are limited as well; take the exact thresholds from the regulation text.
- Technical file and declaration of conformity. The packaging manufacturer is expected to prepare technical documentation showing conformity and to draw up an EU declaration of conformity.
- Traceability details. A batch or serial number and manufacturer contact details are expected on the packaging or in an accompanying document.
- Design for recycling. The requirement to design recyclable packaging tightens in stages, with 2030 as the main milestone.
- Labelling. According to secondary sources, the harmonised material label comes from 12 August 2028; the reusable-packaging label comes later.
The Commission published implementation guidelines in March 2026 and FAQs in August 2026. Separately, the Environmental Omnibus proposed in December 2025 would suspend the obligation to appoint an authorised representative for direct-to-consumer sales; the proposal is still being examined by the European Parliament and the Council. Some details are still moving.
Documents your buyer may ask for
An EU buyer may ask their supplier for the following to meet their own obligations:
| Document | Content | Usually sourced from |
|---|---|---|
| Material declaration | Type and weight of the materials in the packaging | Purchasing and the item master |
| Hazardous substance compliance | Statement on heavy metal and PFAS limits | Packaging supplier, laboratory |
| Technical file and declaration of conformity | File showing the packaging meets the requirements | Packaging manufacturer |
| Recycled content share | Share of recycled material in the packaging | Supplier declaration, batch records |
| Packaging weight and quantity | Packaging placed on the market per product and per country | ERP and shipment records |
Note the last row. Producer-responsibility schemes usually rest on “how many kilos of which packaging did you send to this country”. If packaging data is not linked to the item record, that figure is built by hand.
Three data problems SMEs run into
Packaging is not in the item record. In most ERPs the product exists, but its packaging, weight and material live elsewhere: in a spreadsheet or in one person’s head. Defining packaging as a material item and linking it to the bill of materials is the first step.
Supplier declarations are not collected. Paperboard, film and labels come in, but the supplier’s written statement on material and substances is never requested. When it is needed, weeks are lost.
Shipment data by country is scattered. Which product went to which country in which packaging is in shipping and invoice records, but nobody has joined them.
These are the same data problems we see in CBAM and carbon footprint work. The discipline from our master data article applies here too: one item record, one unit list, an owner for every field.
Packaging is part of the green transition
PPWR is the packaging leg of the circular economy agenda. A manufacturer that already tracks scrap, offcuts and waste streams has an easier job; our zero waste regulation and waste data article covers that tracking discipline. Lighter packaging, a move to mono-materials and recycled content are both a compliance item and a cost item, and material savings sometimes show up directly as profit.
Steps you can take this week
- Build a packaging inventory. For your top 10-20 export products, list sales, bulk and transport packaging with material and weight.
- Write to packaging suppliers. Ask for material declarations, hazardous substance compliance and, where relevant, the technical file and declaration of conformity.
- Agree roles with EU buyers. Who prepares which document, and who keeps the records?
- Link packaging to the product in the ERP. Make weight, material type and supplier mandatory fields.
- Follow the official sources. Check the Commission’s guidelines and FAQs, and watch the outcome of changes such as the Omnibus proposal.
What İkiz Eksen does here
We do not give legal opinions; we help build the data behind packaging compliance. Our twin transition approach rests on the measure, software and compliance chain: we collect packaging and shipment data in your ERP, make supplier declarations traceable and make the reports your buyer asks for something the system can produce. We deliver this as turnkey projects across Türkiye, backed by the experience built with Qera (550+ customers, 15+ sectors, 100+ ERP systems) and a Microsoft Azure infrastructure.
If you want to see where your packaging data stands, write to us through the contact page or browse our solutions.
Frequently Asked Questions
Does PPWR bind manufacturers in Türkiye directly?
The regulation concerns anyone placing products or packaging on the EU market, wherever they are established. A Turkish exporter should prepare compliance documents in a form their buyer or importer can request. Confirm the split of obligations with your contract and your adviser.
Is only plastic packaging covered?
No. Paper, paperboard, glass, metal, wood and composite packaging are all in scope. Some requirements, such as recycled plastic content, concern specific materials only.
Who is responsible for the technical file?
In general terms, the party that makes the packaging or places it on the market under its own name is responsible for conformity. If you sell a product in ready-made packaging, ask your packaging supplier for the documents. For the exact role definition, check the regulation text and your legal adviser.
When does labelling start?
According to secondary sources, the harmonised material label applies from 12 August 2028, or up to 24 months after the relevant implementing acts. Confirm dates against Commission sources.
Where should I start?
With a packaging inventory. List the packaging material, weight and supplier for your most exported products in one place; missing documents become visible from that list.