Question 1

Which obligations can we actually work on today?

Accepted Answer

Eight headings, none of which depend on a pending act: the PFAS and heavy-metal limits, the Annex IV design rules on packaging that only looks bigger, the Annex VII technical file and Annex VIII declaration, producer registration, environmental claims, the operator roles in Articles 15–22, and extended producer responsibility. Together these cover most of what an inspection would ask for first.

Question 2

Does PPWR apply to us if we manufacture outside the EU?

Accepted Answer

If packaging is placed on the EU market under your name or trademark, Article 3(1)(13)(a) makes you a manufacturer, with the technical file and the declaration of conformity as your responsibility. It does not make you a producer: that role belongs to whoever first makes the packaging available inside a Member State, so registration and extended producer responsibility usually fall to your EU importer. You may appoint an authorised representative under Article 17, but drawing up the technical file cannot be delegated.

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