The PPWR Regulation applies to all entities that place packaging or packaged products on the EU market, or that handle packaging within the supply chain. This includes in particular packaging manufacturers, importers, distributors, online sellers, packers, fillers, logistics service providers and e-commerce operators.

PPWR will therefore affect practically every company that manufactures, imports, distributes or sells packaging or products in packaging on the EU market.

PPWR may apply to a company from the perspective of packaging compliance with PPWR. In this case the company, the so-called manufacturer, must ensure that the packaging meets the prescribed packaging requirements, such as packaging identification, identification of the manufacturer, substances in packaging, recyclability, recycled content, compostability or labelling. Compliance is demonstrated through a conformity assessment procedure, technical documentation and an EU declaration of conformity.

PPWR may also apply to a company from the perspective of extended producer responsibility - EPR. In this case the company, the so-called producer of packaging for EPR purposes, is responsible for ensuring and financing the collection and recovery of packaging waste. In most cases these obligations are fulfilled through producer responsibility organisations - PROs. In general, the producer of packaging for EPR purposes is the company that uses packaging - a packer or filler - places products in packaging from abroad on the Slovak market, or, in the case of transport packaging, service packaging and primary production packaging, may be the actual manufacturer of the packaging. These are companies that place packaging or packaged products on the Slovak market first.

PPWR also sets out further requirements for entities using packaging, such as obligations to minimise empty space, a ban on the use of certain packaging formats, obligations related to the use of reusable packaging, reuse targets and obligations in the HORECA sector for takeaway sales.

PRO NATUR-PACK ensures the fulfilment of companies' obligations arising from extended producer responsibility - EPR - in the Slovak Republic, for which it has authorisation from the Ministry of the Environment of the Slovak Republic. These obligations are fulfilled for companies referred to as "producers of packaging" for EPR purposes - generally packers/fillers, transporters and importers of packaged goods on the Slovak market that are the first to place packaging or packaged products on the Slovak market.

The main obligation of these companies is to ensure and finance the collection and recovery of packaging waste. This is supplemented by the obligation to register in the register of producers of packaging, keep, store and report records on packaging placed on the Slovak market and ensure recycling targets.

PRO NATUR-PACK ensures the fulfilment of EPR obligations for its clients, the so-called producers of packaging for EPR purposes.

Obligations related to the compliance of packaging with PPWR packaging requirements, such as identification of packaging and of the manufacturer, recyclability, recycled content or labelling, are obligations of the so-called manufacturer. They include the conformity assessment procedure for packaging against individual PPWR requirements, preparation of technical documentation and the EU declaration of conformity, as well as environmental claims on packaging relating to packaging requirements. These obligations are fully within the competence of the company concerned, as are obligations relating to minimisation or reusability. NATUR-PACK may provide its clients with consultations and advice in this area; however, clients cannot fulfil these obligations through PRO NATUR-PACK.

Manufacturers are companies that are the first to place packaging or packaged products on the EU market. In general, these are packers/fillers, importers into the EU and, in the case of transport, service and primary production packaging, the actual manufacturers of such packaging.

In some cases, a company may be considered both a producer of packaging for EPR purposes, because it is the first to place packaging or packaged products on the Slovak market, and a manufacturer, because it is the first to place packaging or packaged products on the EU market. In such a case, both EPR obligations fulfilled through a PRO and manufacturer obligations that the company must fulfil itself will apply.

The manufacturer of packaging is the company that manufactures the packaging or packaged product. Depending on the type of packaging, this may be the physical manufacturer of the packaging or the packer/filler. According to the PPWR FAQ prepared by the European Commission and published in August 2026, the decisive criterion for determining the manufacturer should be who places the order and decides on the design specifications of the packaging.

There is only one manufacturer within the EU - the company that first places the packaging or packaged product on the EU market.

In the case of consumer and grouped packaging, the manufacturer should be considered to be the company that uses the packaging to pack the product, i.e. the packer or filler, because it is this company that completes the packaging into its final form.

In the case of transport packaging, service packaging and primary production packaging, the manufacturer should be considered to be the actual manufacturer of the packaging, because these types of packaging usually have their final shape, i.e. final form, already when empty.

According to the PPWR FAQ published by the European Commission in August 2026, the manufacturer of transport packaging must therefore be determined at the moment when the empty packaging has reached its final form. Packaging has reached its final form when it can be used as transport packaging without adding further components or auxiliary elements. In this context, it is important to clearly distinguish the combination of packaging items used for the transport, handling or sale of products from the actual assembly or transformation of packaging, such as shaping material directly on site or creating a packaging item from components which do not themselves perform a packaging function.

The joint use of several packaging items, such as tapes, films, boxes or pallets, does not mean that the individual items have not yet reached their final form. A single shipment of packaged products may contain packaging from several manufacturers, and each manufacturer must, when placing its packaging on the market, prepare and have available the necessary technical documentation and information proving compliance with applicable requirements, which serve as the basis for issuing its EU declaration of conformity.

Examples

A cardboard box has reached its final form even when it is supplied flat and must be assembled. For unbranded standardised cardboard boxes, the manufacturer is the company that physically manufactures them.

Stretch film used to stabilise packaged products on pallets is considered packaging already when sold on a roll, even if it is subsequently cut and used to wrap a pallet unit. If it is unbranded, the manufacturer is the company that physically manufactures the film and places it on the market as packaging, not the company that buys it and subsequently uses it to secure goods.

Who is the manufacturer of service packaging?

The manufacturer of service packaging should be determined in the same way as for transport packaging - at the moment when the empty packaging has reached its final form. For common service packaging, such as paper bags, carrier bags, takeaway food packaging or pizza boxes, the manufacturer is usually the physical manufacturer of such packaging.

Example

If a shop buys standard unbranded paper bags or plastic cups from their physical manufacturer and provides them to customers, the manufacturer of those bags or plastic cups is usually the manufacturer of the bags or plastic cups.

However, if a company has packaging or a packaged product designed under its own name or trademark, that company is considered the manufacturer.

If a transport cardboard box bears the name or trademark of a company, the manufacturer is the company whose name appears on the box or which owns the trademark. If a company adds a label to an unbranded box only for shipment purposes, this is not considered branding and that company is therefore not considered the manufacturer.

The same applies to service packaging, where, if a restaurant chain uses food packaging bearing its logo, the manufacturer is the restaurant chain under whose brand the packaging is placed on the market.

The same logic also applies to consumer and grouped packaging: where the packaging bears the name or trademark of a company, that company is considered the manufacturer, even if another entity carries out the production and packing of the product.

A company that has packaging designed or manufactured under its own name or trademark is not considered the manufacturer only if the definition of "micro-enterprise" applies to that company. In such a case, the obligations of the manufacturer under Article 15, such as the conformity assessment procedure, technical documentation, EU declaration of conformity, archiving, identification of the manufacturer and identification of the packaging, are fulfilled by the packaging supplier, if located in the Union.

The manufacturer is responsible for ensuring that the packaging complies with the requirements of the PPWR Regulation. Before placing packaging on the market, the manufacturer must ensure its compliance with the applicable requirements under Articles 5 to 12, carry out the conformity assessment, prepare the technical documentation and the EU declaration of conformity. The manufacturer must also ensure the traceability of the packaging, keep the documentation and make it available to market surveillance authorities upon request.

Packaging compliance is demonstrated for the requirements of Articles 5 to 12 of PPWR that are applicable at the given time. In August 2026, this includes Article 5 - substances in packaging - and Article 11 - reusable packaging, i.e. the conditions under which packaging is considered reusable.

Other requirements, such as recyclability, recycled content, compostability, bio-based substances, minimisation and labelling, will apply gradually over the coming years. From around 2030, virtually all requirements should already apply, with gradual tightening in subsequent years.

The manufacturer must ensure that the packaging can be identified and that it is possible to determine who is responsible for its compliance. The packaging must therefore indicate:

• the name or business name of the manufacturer, registered trade name or trademark, if used,
• the postal address at which the manufacturer can be contacted,
• an electronic contact, such as an email address or website.

This information should be provided directly on the packaging. If the size or nature of the packaging does not allow this, it may be provided via a QR code or in accompanying documentation.

The packaging must also be marked with a type number, batch number, serial number or another identification element so that it can be linked to the technical documentation and the EU declaration of conformity. The marking should refer to the packaging unit, not to each individual packaging component - for example, a bottle should be marked as a whole, not the bottle, label and cap separately. A unique number is not required for each individual item of packaging. This marking should be on the packaging and, if this is not technically possible, it should be included in the accompanying documentation.

If packaging or packaged products have already been produced but have not yet been placed on the market and do not have the required markings on the packaging, the identification of the manufacturer and the identification of the packaging may be provided in accompanying documentation in order to avoid the unnecessary destruction of already produced packaging. However, if packaging is produced after 12 August 2026, the required identifications must already be provided on the packaging, if technically possible.

Service packaging is packaging designed and intended to be filled at the point of sale for the purpose of handing over a product. Typical examples include shopping bags, bakery bags, plastic trays, cups or packaging for takeaway food and beverages.

A micro-enterprise has fewer than 10 employees and an annual turnover or balance sheet total not exceeding EUR 2 million.

In practical terms, the company must meet the following:

• fewer than 10 employees, and at the same time
• annual turnover of up to EUR 2 million or a balance sheet total of up to EUR 2 million.

How do I find out whether the customer is a micro-enterprise?

In practice, a declaration by the customer will most often be used. The entrepreneur is responsible for the accuracy of the data on the number of employees, turnover and any linked enterprises. We recommend keeping the declaration archived in case of an inspection.

Do exemptions for micro-enterprises also apply to self-employed persons?

Yes, if the self-employed person meets the conditions for a micro-enterprise under the European definition. The status should be demonstrated by a declaration.

If you buy packaged products in Slovakia and only resell them in Slovakia, you usually act as a distributor. In that case, you generally have only a verification obligation to check whether the responsible entity has fulfilled its obligations.

However, if you import products from abroad from EU countries and resell them in Slovakia, under PPWR you are in the position of a producer of packaging for EPR purposes, which gives rise to EPR obligations.

If you import these goods from countries outside the EU, you are considered a producer of packaging for EPR purposes, with EPR obligations, and also an importer of packaging, with importer obligations to ensure that the relevant obligations have been performed.

If you sell goods to end users in another EU Member State, you are considered a producer of packaging for EPR purposes in that EU country, and you need to register in that country and fulfil EPR obligations there.

If you buy packaged products from a supplier established in the EU and resell those products, you usually act as a distributor. Your main task is not to demonstrate packaging compliance with PPWR in the same way as the manufacturer, but to ensure that you do not make available on the market products or packaging that you know, or may reasonably assume, do not meet the requirements of the Regulation.

A distributor must act with due care. Before placing a product in distribution, the distributor should verify in particular:

• whether the packaging is properly labelled according to PPWR requirements,
• whether the manufacturer has fulfilled its obligations related to conformity assessment and documentation,
• whether the information and documents required by legal regulations are available,
• whether the product or packaging shows any obvious non-compliance with PPWR,
• whether goods or packaging are handled in such a way that the compliance of the packaging with PPWR is maintained,
• whether the so-called producer of packaging for EPR purposes is entered in the register of producers of packaging, if the distributor is not the producer for EPR purposes itself.

If you use the goods for your own needs, your supplier is considered the producer of packaging for EPR purposes.

If you further distribute these goods to other entities, your company is considered the producer of packaging for EPR purposes.

If you buy packaged products from countries outside the EU, for example China, Turkey, the USA, the United Kingdom or Serbia, and place them on the EU market for the first time, you act as an importer under PPWR. Unlike a distributor, it is no longer sufficient merely to act with due care. The importer bears significant responsibility for ensuring that packaging or packaged products that do not comply with PPWR requirements are not placed on the EU market.

Verify packaging compliance before placing it on the EU market

Before placing a product on the market, the importer must verify that the manufacturer has fulfilled all PPWR requirements, in particular:

• the conformity assessment has been carried out,
• technical documentation exists,
• an EU declaration of conformity has been drawn up,
• the packaging meets all relevant PPWR requirements.

Keep documentation

The importer must have available and be able to submit to supervisory authorities upon request:

• the EU declaration of conformity,
• technical documentation.

Documentation is kept for 5 years in the case of single-use packaging and for 10 years in the case of reusable packaging.

Provide identification details

The importer's contact details must be provided on the packaging or in accompanying documentation so that the entity responsible for placing the product on the EU market can be identified. Typically, this includes the business name or registered trade mark, if any, postal address and contact details.

Do not place a non-compliant product on the market

If the importer has reason to believe that the packaging or packaged product does not comply with PPWR requirements, it must not place it on the market until the non-compliance has been remedied.

Connection with extended producer responsibility (EPR)

In most cases, the importer will also be considered the producer of packaging for EPR purposes in the Member State where it first places the packaged product on the market. This means that, in addition to PPWR obligations, the importer will have to register under national legislation, fulfil reporting obligations, finance separate collection and recovery of packaging waste and pay the relevant recycling fees.

Each supplier of a transport cardboard box should be able to demonstrate the compliance of its packaging under PPWR and should provide you with an EU declaration of conformity.

You should request technical documentation for the relevant boxes from each supplier so that you can carry out the conformity assessment procedure and prepare the EU declaration of conformity.