PPWR the next steps

Helping you navigate the PPWR

The PPWR now applies across the EU. We’re here to help you understand what it means for your packaging, what matters now, and what comes next.

The Packaging and Packaging Waste Regulation (PPWR) has applied across the EU since August 12, 2026. If you fill and sell packaged products in Europe, you should now be able to demonstrate that your packaging meets the requirements that currently apply.

For Miron glass packaging, the immediate impact is mainly about documentation and substance requirements, not redesign.

The glass jar or bottle itself has not suddenly changed. The requirements expected to have a greater effect on packaging design arrive later, particularly from 2030. For glass packs, many of those changes are likely to concern closures and other components rather than the glass itself.

Here are four areas to work through first.

Step 1

Understand your obligations

Four steps towards conformity

Your role in the supply chain determines your responsibilities.

Under the PPWR, the manufacturer is generally the party that has packaging designed or manufactured and markets it under its own name or trademark. The company that physically produces an individual packaging component is not necessarily the manufacturer of the finished packaging placed on the market.

For example, if you buy a jar and closure from us, fill the jar with your serum, label it, and sell the finished pack under your brand, you may be considered the manufacturer of that packaging under the PPWR. Miron remains the supplier of the components we provide.

Three steps to start with

How to meet your obligations

For manufacturers, three important steps follow:

Carry out a conformity assessment for each packaging type placed on the market.
Compile the technical documentation that supports the assessment.
Draw up and sign the EU Declaration of Conformity, then keep it available and up to date.

Your suppliers support this process by providing relevant information and documentation for the components they supply.

Additional responsibilities may apply when packaging or packaged goods are imported into the EU from outside the EU. Importers should therefore check the requirements that apply to their specific role.

Step 2

Build the documentation behind your declaration

The EU Declaration of Conformity follows the model in Annex VIII of the PPWR. The declaration itself is relatively short. Most of the work sits in the assessment and evidence behind it.

Below you will find the thee steps of building all documentation.

Step 1 in documentation

Carry out the conformity assessment

Start with the packaging unit as you place it on the market. List each component, such as:

glass bottle or jar
closure
liner
pump or pipette
decoration
label
secondary packaging
transport packaging for which you are responsible

Record the material and weight of each component. This bill of materials gives you a practical foundation for the rest of the assessment.

The PPWR's sustainability requirements are set out in Articles 5 to 12. They cover areas including substances, recyclability, recycled content, compostability, packaging minimization, reuse, and labeling.

These requirements do not all become applicable at the same time. Your assessment should therefore distinguish between requirements that apply now and those that will apply at a later date.

Step 2 in documentation

Compile the technical documentation

Annex VII of the PPWR sets out the technical documentation requirements.

Your file should include a description of the packaging, relevant design and manufacturing information, and evidence supporting the conformity assessment.

Much of this information will come from suppliers. Depending on the packaging, this may include:

material composition
component weights
substance statements
test reports
relevant documentation required under other EU legislation

Requesting this information by packaging type rather than by individual order can make the process easier to manage. It is also useful to record the date and version of each document.

There is an important change concerning the heavy metal requirement. Under the previous packaging directive, EN 13428 was used to support a presumption of conformity. That standard has not yet been harmonized under the PPWR. Where no applicable harmonized standard is available, your technical documentation should explain the assessment route used and the evidence supporting it.

For a glass jar with a plastic closure and printed decoration, for example, the file could contain a supplier statement covering the glass, supporting information for the closure, and appropriate evidence for the decoration. The exact evidence needed depends on the materials and risks involved.

Step 3 in documentation

Draw up the declaration

The EU Declaration of Conformity records responsibility for the conformity being declared. It is therefore important to define the packaging covered by it clearly.

Where packaging is subject to more than one relevant EU act, it may be possible to combine the required declarations, provided the applicable legislation is clearly identified.

The PPWR also sets retention requirements for conformity documentation.

Changes to materials, design, components, or suppliers may mean the underlying assessment needs to be reviewed.

A practical question is how to define a packaging type. Similar SKUs may be covered together where the relevant design, materials, and components are genuinely equivalent. A change such as a different liner or closure may affect that assessment.

Step 3

Check the substance requirements

Substance restrictions are among the PPWR requirements with an immediate impact on packaging documentation.

Heavy metals

The combined concentration of lead, cadmium, mercury, and hexavalent chromium is limited to 100 mg/kg in packaging.

This requirement is not new. It existed under the previous EU packaging framework. What matters now is being able to support conformity under the PPWR.

Specific provisions apply to recycled glass. Recycled cullet can contain traces of substances introduced into the recycling stream historically.

Under the applicable derogation, glass packaging may exceed the general threshold under defined conditions, including where the exceedance results from recycled material and the regulated metals have not been intentionally introduced during manufacturing.

For the glass Miron supplies, none of these four metals is intentionally added.

PFAS

The PPWR also introduces PFAS limits for food-contact packaging.

For the food-contact materials we supply, Miron's statement confirms that PFAS are not intentionally added during manufacture and that, based on the information available to us, we have no indication of their presence above the applicable PPWR limits.

This is different from describing packaging as "PFAS-free."

PFAS are widespread in the environment, which means unintended trace presence cannot always be ruled out through supply chain information alone. A statement based on intentional use and available evidence provides a more precise description of what can be supported.

For glass packaging, the assessment may also need to consider other components and treatments, including closures, liners, coatings, and decorations.

Step 4

Separate today's requirements from what comes next

The PPWR introduces requirements in stages. Keeping those stages separate makes it easier to decide what needs attention now and what should inform future packaging development.

Applicable now: requirements include relevant substance restrictions and conformity documentation obligations.
Coming later: further requirements include harmonized labeling, recyclability performance requirements, recycled content targets for plastic packaging, and packaging minimization requirements. Major design-related requirements begin to apply from 2030, with further recyclability requirements following later.
Still being developed: important methodologies and implementing rules are still to come. These include methods that will determine how some recyclability, recycled content, and packaging minimization requirements are assessed in practice.

This means some future packaging performance cannot yet be classified with certainty.

For glass packaging, two points are particularly useful to keep in mind. Recycled content targets under the PPWR concern plastic packaging rather than glass. In a predominantly glass pack, plastic components such as closures may therefore require particular attention.

The broader design direction is also becoming clearer: packaging components will increasingly need to support effective recycling, material separation, and efficient use of resources.