What do Swiss companies need to know about the Packaging and Packaging Waste Regulation?

The Packaging and Packaging Waste Regulation (PPWR) applies to all companies placing packaging on the EU market, including Swiss companies. Under the regulation, any company supplying packaged products on the EU market must provide stricter evidence that its packaging is recyclable, free from dangerous substances and correctly labelled, and must maintain appropriate documentation. Against this background, companies need to understand the requirements early and request information from suppliers to ensure compliance.

Key points of the PPWR

The PPWR replaces the existing European Packaging and Packaging Waste Directive (PPWD), introducing more comprehensive and harmonised requirements for packaging across the EU. This regulation affects every economic operator (brand owners, importers, retailers, e-commerce providers and packaging manufacturers) along the packaging supply chain that place products on the European market.

The PPWR is generally applicable with effect as of 12 August 2026. From 2030 onwards, further key requirements will come into force, including those relating to recyclability, recycled content and packaging minimisation.

Companies should clarify now which packaging is affected, what role they play in the supply chain and what evidence they need to provide to customers, importers or trading partners.

 

Why is the PPWR relevant?

Packaging has been subject to increasing regulatory pressure in the EU for years. The PPWR is more than just environmental regulation. It links sustainability, product design, supply chain data, labelling and market access.

The EU is pursuing three main objectives with this regulation: reduce packaging waste; cut down on use of virgin raw materials in packaging production; and make packaging easier to recycle. In addition, the EU is seeking to reduce national packaging rules and harmonise requirements more closely within the EU single market.

Breaches of the PPWR can lead to fines, product recalls and restrictions on access to the European market.

 

Who is affected by the PPWR?

The PPWR applies to economic operators along the packaging value chain. The decisive factor is therefore not solely the location of a company’s registered office, but whether packaging or packaged products enter the EU. This means that even non-EU companies are affected by this regulation of they place products in the EU market.

The regulation defines specific roles for individual stakeholders, although a company may fulfil several roles in parallel. The respective compliance obligations depend on the role within the supply chain. Accordingly, companies should clearly identify their role(s) within the supply chain.

The primary roles defined under the PPWR are:

  • Suppliers – companies that manufacture empty packaging or packaging materials for other economic actors.
  • Manufacturers – companies that place their brand or trademark on packaging, or that commission packaging designed to meet the specifications of their products. Manufacturers are subject to the broadest range of compliance obligations under the PPWR.
  • Importers – companies established within the EU that import packaged products from third countries into the EU market.
  • Distributors – companies, other than manufacturers or importers, that make packaging or packaged products available on the market, e.g. traders and logistics providers.
  • Final distributors – companies that sell or deliver packaged products directly to end consumers, such as retailers and e-commerce businesses.
  • Producers – companies placing packaged products on the market in an EU Member State where the packaging ultimately becomes waste. A producer may be a manufacturer, importer, distributor or final distributor, depending on the circumstances. Producers are responsible for fulfilling Extended Producer Responsibility (EPR) obligations, including the payment of EPR fees in each applicable Member State.

Companies based outside the EU need to examine their situation particularly carefully. Depending on their business models, obligations may lie directly with the EU importer; in practice, however, data, documents and evidence may be required from the non-European companies. Anyone supplying goods to the EU should therefore not wait until customers or authorities make enquiries.

Micro-enterprises with fewer than 10 employees and annual turnover of less than EUR 2 million are exempt from certain PPWR requirements.

Which types of packaging are within scope of the PPWR?

The following packaging types fall within the scope of this regulation, regardless of the material used:

  • Sales packaging – packaging designed for individual products sold to end consumers in retail settings, such as shampoo bottles, beverage cans, cereal boxes, milk cartons, mobile phone boxes, and packaging for clothing, footwear and household goods.
  • Grouped packaging – packaging used to combine multiple sales units for easier handling, storage or sale, such as multipacks of beverage bottles or yoghurt cups, or multiple cans of food in cardboard trays.
  • Transport packaging – packaging used for the transport of goods between businesses and to retail locations, including pallets, shrink wrap and strapping materials.
  • E-commerce packaging – packaging used for products sold online and delivered directly to consumers.
  • Takeaway packaging – packaging filled at the point of sale for food or beverages, including beverage cups and takeaway food containers.
  • Primary production packaging – packaging used for the handling and transport of unprocessed raw materials, such as drums of fluids like lubricants and oils, and sacks for dry bulk materials like cement and powdered raw materials.

Certain types of packaging used for medicinal products or for the transport of dangerous goods are exempt from PPWR requirements.

PPWR misconceptions that could prove costly for businesses

«This only affects packaging manufacturers.»

Wrong. Packaging manufacturers are significantly affected by the regulation, but they are not the only ones. Businesses that have packaged products, affix their brand name to the packaging, or import, distribute or sell products online may also be subject to certain obligations or documentation requirements.

«Our suppliers will take care of it.»

Short-sighted view. Suppliers provide data and evidence. However, the PPWR clearly places responsibility for compliance on the companies for whom the packaging is manufactured or whose brand appears on the packaging.

«We still have until 2030.»

Not strictly true. The key starting point for fulfilling PPWR requirements is 12 August 2026. Additional requirements, such as labelling obligations and EPR fees, must be met even before the packaging recycling requirements come into force in 2030.

What are the PPWR requirements that companies need to comply with?

Although the European Commission has not yet published all technical criteria and delegated acts for the requirements outlined below, companies should begin preparations early, as the compliance targets and timelines have already been established.

  • Recyclability requirements
    From 1 January 2030, all packaging placed on the EU market must be recyclable. Packaging recyclability will be classified into performance grades A, B or C based on defined technical criteria. Packaging with a recyclability rate below 70% will be considered non-recyclable and may not be placed on the market. From 1 January 2038 onwards, only packaging classified as grade A or B will be permitted.
    For businesses, this means that packaging materials, material combinations, labels, adhesives, inks, inlays and closures must be tested. Composite materials, components that are difficult to separate and packaging without established recycling routes are particularly critical.
  • Minimum recycled content
    Binding minimum recycled content requirements for plastic packaging will apply from 1 January 2030. The required recycled content levels will vary by packaging type. For example, single-use plastic beverage bottles must contain at least 30% recycled content. These thresholds will become more stringent from 2040 onwards.
    Companies should assess at an early stage whether suitable grades of recycled material are available, whether food safety or product protection are affected and what evidence suppliers can provide.
  • Minimisation of packaging and empty space
    From 1 January 2030, packaging must be limited to the minimum weight and volume necessary to ensure product safety, hygiene and communication of essential information. Packaging designs that artificially increase perceived product volume or weight will be prohibited. This includes non-functional features such as double walls, false bottoms or excessive empty space. In addition, the empty space ratio for grouped, transport and e-commerce packaging must not exceed 50%.
    The procurement, packaging development, logistics and marketing departments will need to work together to assess whether existing packaging is technically justifiable.
  • Harmonised packaging labelling
    From 2028, packaging placed on the EU market must carry harmonised labels identifying material composition and waste sorting. The objective is to support consumer waste sorting and improve recycling outcomes across the EU. Labels must be clear, easily understandable, visible and permanently affixed to the packaging. Misleading claims or symbols regarding sustainability, recyclability or disposal methods will not be permitted. Certain packaging types will also require QR codes to support reuse systems and provide additional packaging information to consumers.
    Companies should not view labelling projects in isolation. Changes to labels, packaging layouts and digital information have long lead times.
  • Substance restrictions and product safety
    The PPWR sets out requirements – effective as of August 2026 – regarding substances of concern, including certain heavy metals and PFAS chemicals in packaging. The exact assessment depends on the type of packaging, the material used and the intended packaging use.
    A general supplier’s declaration is not sufficient in this case. Companies require reliable material information and laboratory test results.
  • Extended Producer Responsibility (EPR)
    While most EU Member States already operate EPR schemes, the PPWR will introduce a more harmonised EU-wide framework, including a new EPR registry system that Member States will be required to implement by 2028.
    Praktisch bedeutet das: Ohne Verpackungsinventar, Lieferantendaten, Materialnachweise und klare interne Zuständigkeiten wird PPWR-Compliance schwer steuerbar.


What obligations do companies have to fulfil in 2026?

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The PPWR has been in force since 11 February 2025. It will generally come into effect on 12 August 2026. The following obligations must be taken into account:

  • By 12 August 2026, companies must have clarified their scope of application, roles, packaging inventory and documentation requirements. In addition, manufacturers must ensure that all packaging placed on the market complies with the specified limit values for substances of concern and heavy metals.
  • To demonstrate compliance with PPWR requirements, companies must maintain internal technical documentation for each packaging type placed on the market. This documentation should include, among other elements, a description of the packaging, dimensions and technical drawings, materials used, applicable packaging standards and relevant test results.
  • Manufacturers are also required to issue a Declaration of Conformity (DoC) for each packaging type and provide this to importers and distributors of the packaged products.

Upon request by the competent authorities, the technical documentation and DoC must be submitted within 10 working days. Failure to do so may result in fines, enforcement actions or restrictions on market access.

How can BDO Switzerland help in ensuring PPWR compliance?

BDO Switzerland applies a practical approach to support your PPWR readiness. Our expertise spans impact analysis, clarification of roles, packaging inventory, gap analysis, supplier data, documentation structure and implementation roadmaps.

We match our services to your company’s situation and needs. For example, we can assist you with:

  • PPWR quick check for companies with EU business
  • Workshop on impact and role allocation
  • Templates for Declarations of Conformity (DoC)
  • Establishment of a packaging inventory
  • Identification of critical packaging
  • Roadmap development to become compliant

Contact BDO Switzerland for a free 30-minute consultation or use our contact form to arrange an initial assessment.

Non-binding initial consultation on the PPWR

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