What PPWR Obligations Do I Have as a Filler?
What Should Fillers and Food Manufacturers Consider Regarding the PPWR?
As a filler or food manufacturer, it is advisable to start preparing for the requirements of the PPWR at an early stage. The demands regarding packaging, documentation, traceability and supporting evidence are expected to increase significantly over the coming years.
It is important to understand that, in many cases, the assessment is not limited to an individual packaging component. Instead, the focus is on the final packaging system used to place your product on the next stage of the supply chain.
In addition to buckets, tubs, trays, films or lids, the final packaging system may also include labels, adhesives, printing inks, coatings, barriers, closure systems, secondary packaging and other functional components.
| Topic | What You Should Review |
|---|---|
| Packaging Inventory | Create a structured overview of all packaging used for your products, including primary, secondary and transport packaging where relevant. |
| Final Packaging System | Assess the complete packaging combination rather than individual materials only. For example, a food tub may consist of the container, lid, label, adhesive and additional packaging elements. |
| Materials and Components | Identify all materials used, determine whether multilayer or composite structures are involved, and document which components are intended for food contact. |
| Packaging Minimisation | Evaluate whether packaging can be reduced or optimized without compromising product protection, hygiene, shelf life, storage or transportation performance. |
| Recyclability | Review material combinations, separability of components, coatings, barriers, labels and printing inks, as these factors may influence recyclability. |
| Restricted Substances | Review available information regarding PFAS, BPA, phthalates, heavy metals, REACH substances and SVHC substances where applicable. |
| Documentation | Collect and maintain declarations of conformity, technical data sheets, specifications, certificates and other available regulatory documentation. |
| Plausibility Review | Do not simply collect documents. Verify whether information appears complete, current, consistent and appropriate for the intended application. |
| Document Management | Define how documents are stored, monitored and updated, including responsibilities and review intervals. |
| Traceability | Ensure that packaging materials, suppliers, batches and supporting documents can be clearly linked and traced. |
| Customer and Authority Requests | Prepare processes that enable efficient responses to customer, retailer or regulatory inquiries regarding packaging compliance and documentation. |
| Internal Responsibilities | Define who is responsible for packaging compliance, supplier communication, document management and regulatory monitoring. |
| Recommended Action | Practical Implementation |
|---|---|
| Create a Packaging Inventory | Establish a complete list of all packaging systems and packaging components used. |
| Map Materials | Document materials, packaging components and suppliers for each packaging system. |
| Collect Documentation | Maintain declarations of conformity, technical data sheets, specifications and certificates in a structured manner. |
| Identify Risks | Flag missing documents, incomplete information, critical materials or inconsistent statements. |
| Monitor Validity Dates | Regularly review the validity and currency of available documentation. |
| Ensure Traceability | Link products, packaging, suppliers, batches and documents in a traceable system. |
| Define Internal Processes | Establish responsibilities, review intervals and escalation procedures where required. |
Bikapack supports its customers by providing available manufacturer information and documentation relating to supplied packaging products. This may include declarations of conformity, technical data sheets, product specifications, certificates and available statements regarding recyclability or substance restrictions.
However, the assessment of your specific packaging application, your final packaging system and your role within the supply chain remains your company's responsibility. This is particularly important where multiple packaging components, labels, adhesives, trays or secondary packaging are involved.
Disclaimer: This information is intended solely as practical guidance and does not constitute legal advice. Many aspects of the PPWR are still being clarified through implementing acts, delegated acts and technical standards. For legally binding interpretations, companies should consult qualified legal advisors, competent authorities or relevant industry associations.