Who Owns PPWR Compliance Inside Your Company?

Who Owns PPWR Compliance Inside Your Company?

Who owns PPWR in your organization?

For many companies, the answer is not obvious.

And there is a good reason for that.

The EU Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, creates legal responsibilities for economic operators such as manufacturers, importers and distributors.

But the information needed to meet those responsibilities is often spread across several departments.

Procurement knows the suppliers.

Packaging teams know the specifications.

Supply-chain teams know how products move.

Legal and compliance teams interpret regulatory requirements.

Quality may hold test reports and technical evidence.

Sustainability may manage packaging data and Extended Producer Responsibility.

The result is an important distinction:

One function may coordinate PPWR compliance internally, but no single department necessarily holds everything needed to make it work.

In brief: Who should own PPWR compliance?

A company should have a clearly identified owner for PPWR implementation.

That person or function should coordinate the process, monitor requirements, identify gaps and make sure the right teams provide the right information.

But internal ownership does not change the legal responsibilities assigned by the PPWR.

If the company acts as a manufacturer for a particular packaging flow, the manufacturer's obligations still apply.

If it acts as an importer, importer obligations apply.

If it acts as a distributor, distributor obligations apply.

The internal question is therefore not simply:

“Which department owns PPWR?”

A better question is:

“Who coordinates PPWR, and which teams own the information and actions needed to meet our obligations?”

Legal responsibility and internal ownership are not the same thing

This distinction matters.

Under Article 15 of the PPWR, manufacturers may only place on the market packaging that conforms to the applicable requirements under Articles 5 to 12.

Manufacturers must carry out, or have carried out, the applicable conformity assessment and prepare the required technical documentation. Once conformity has been demonstrated, they must draw up the EU Declaration of Conformity.

The European Commission's 2026 guidance reinforces the point: the manufacturer remains the economic operator legally responsible for the packaging's compliance with the relevant sustainability and labelling requirements, even where other parties help prepare documentation or perform parts of the assessment.

Importers have their own responsibilities under Article 18.

Among other things, before placing packaging on the market, importers must ensure that the manufacturer has carried out the required conformity assessment and prepared the technical documentation.

Distributors also have obligations under Article 19, including due-care and verification requirements.

Those are regulatory roles.

But inside an organization, delivering on those obligations may require several different functions.

Why PPWR quickly becomes cross-functional

Consider a company selling an own-brand packaged consumer product in several European countries.

To understand its PPWR position, it may need to answer questions such as:

What packaging is being used?

Who designed or commissioned it?

Which company supplies each relevant packaging component?

What materials are involved?

Where is the finished product manufactured?

Does it enter the EU from a third country?

Whose name or trademark is on the product?

Which packaging requirements currently apply?

What supporting evidence exists?

What information is still missing?

Has the packaging changed since the evidence was issued?

Which Member States receive the product?

Who manages EPR obligations in those countries?

No single department necessarily knows all of those answers.

That is why PPWR implementation becomes an information and coordination challenge, not simply a regulatory-reading exercise.

Packaging and product teams: What are we actually assessing?

Packaging, product-development and engineering teams may hold some of the most important factual information in the PPWR process.

They may know:

• the packaging configuration;

• packaging and component specifications;

• materials;

• dimensions and weights;

• design versions;

• packaging suppliers;

• technical drawings;

• changes to packaging designs; and

• how packaging components come together.

This information is fundamental.

A company cannot reliably determine what evidence it needs if it cannot identify the packaging concerned.

Packaging teams may therefore become an important source of PPWR data even if they are not the function formally responsible for regulatory compliance.

Procurement: Can our suppliers provide what we need?

Procurement often controls another essential part of the process: the supplier relationship.

Under Article 16 of the PPWR, suppliers of packaging and packaging materials must provide manufacturers with the information and documentation necessary for manufacturers to demonstrate conformity.

But the regulatory team may not have direct relationships with those suppliers.

Procurement may need to help determine:

• who supplies the packaging;

• who the appropriate technical contact is;

• what information has already been provided;

• what remains outstanding;

• when suppliers should be followed up with; and

• whether PPWR information requirements need to become part of future supplier onboarding or contracting.

The challenge is not simply sending a supplier questionnaire.

It is making sure that a request is connected to the correct packaging and that the response resolves an actual information or evidence gap.

Quality, regulatory and compliance: Does the evidence actually support the requirement?

Receiving a document does not automatically mean a compliance question has been answered.

Someone needs to evaluate what the information demonstrates.

Depending on the organization, that work may sit with quality, regulatory affairs, product compliance, legal or another specialist function.

The review may need to determine:

• which packaging the evidence relates to;

• which version it covers;

• what requirement it supports;

• whether it is sufficiently specific;

• whether further evidence is necessary; and

• whether a change has affected the previous assessment.

This is an important distinction.

A supplier may have responded.

A PDF may have been uploaded.

A request may appear complete.

But the underlying compliance gap may still be open.

PPWR therefore needs a way to distinguish between information received and information reviewed and found sufficient for its intended purpose.

Supply chain and logistics: How does the product actually reach the market?

Supply-chain teams often hold information that can materially affect PPWR role determination.

For example:

Is the finished product manufactured inside the EU?

Is it imported from China, the United States or another third country?

Which company acts as importer?

Is the product transferred between EU Member States?

Does the route differ by customer, channel or market?

Is the same product sourced through more than one flow?

These facts can matter because PPWR responsibilities depend on what an economic operator is actually doing within the supply chain.

A company cannot necessarily determine its role simply from its corporate description.

“Retailer,” “brand” or “distributor” may describe the business generally without resolving the regulatory role for a particular product flow.

Legal: What obligations follow from the company's role?

Legal teams can play an important role in interpreting the Regulation and resolving situations where economic-operator status or contractual responsibilities are unclear.

This is particularly relevant where the company:

• sells products under its own brand;

• uses contract manufacturers;

• imports finished packaged products;

• modifies packaging supplied by another company;

• operates through several entities;

• sells across multiple Member States; or

• relies on third parties to carry out parts of its compliance process.

But legal interpretation needs factual input from the rest of the organization.

The legal team cannot determine the correct role if it does not know how the product is actually manufactured, branded, supplied and placed on the market.

Sustainability and EPR: What happens across different EU markets?

PPWR also interacts with responsibilities concerning packaging waste and Extended Producer Responsibility.

The PPWR concept of a “producer” is distinct from the manufacturer role used for packaging conformity.

For organizations operating across multiple Member States, EPR-related responsibilities can therefore add another layer to the internal process.

Sustainability, environmental compliance, finance or local market teams may already manage:

• packaging reporting;

• EPR registrations;

• packaging volumes;

• producer-responsibility organizations;

• national reporting requirements; and

• fees.

Those processes should not be confused with packaging conformity, but they form part of the broader PPWR landscape companies need to manage.

Data and systems: Can the organization connect the information?

This becomes especially important as the number of products, packaging configurations, suppliers and markets increases.

Consider a company with:

500 products.

150 suppliers.

Several packaging components per product.

Multiple EU markets.

Supplier evidence arriving by email.

Specifications stored in shared drives.

EPR information in spreadsheets.

Compliance documents with different naming conventions.

Packaging changes managed in another system.

At that scale, PPWR is no longer simply a question of whether a particular document exists.

The organization needs to be able to connect information across the process.

For example:

Which packaging are we assessing?

Which supplier information supports it?

Which requirement does that evidence address?

Has the evidence been reviewed?

What is still missing?

Who needs to take the next action?

Has anything changed since the assessment was completed?

Companies do not necessarily need a complex new system on day one.

But they do need a way to answer those questions reliably.

The problem with making PPWR “the sustainability team's job”

Sustainability teams are often among the first people inside an organization to encounter PPWR.

That makes sense.

The Regulation deals extensively with packaging sustainability, recyclability, recycled content, waste prevention and reuse.

But PPWR implementation reaches much further.

A sustainability manager may understand the regulation extremely well and still not control:

supplier specifications,

contract-manufacturing arrangements,

technical testing,

packaging design changes,

import flows,

product master data,

legal interpretation,

or conformity documentation.

The same problem arises if PPWR is assigned entirely to legal.

Legal may interpret the Regulation but not own packaging specifications or supplier relationships.

Assigning PPWR solely to procurement creates another gap.

Procurement manages suppliers but may not be positioned to determine whether technical evidence adequately supports a regulatory requirement.

The solution is not to have everyone own PPWR.

That usually creates the opposite problem.

The solution is to have clear coordination and clear responsibility for the individual inputs and decisions that make compliance possible.

A practical internal PPWR model

For many organizations, a workable approach starts with one central PPWR owner or coordinating function.

That function does not need to personally perform every task.

Instead, it should be able to see the status of the process and identify where action is required.

For example:

The exact allocation will vary by company.

A smaller organization may have one person performing several of these roles.

A large multinational may have different teams in different countries.

The important point is not the organizational chart.

It is whether the company has clear ownership of the information, decisions and follow-up actions necessary to support compliance.

Start with a product, not an organization chart

If responsibility currently feels unclear, one of the easiest ways to expose the gaps is to choose a real product.

Take one packaged product and ask:

1. What is the product flow?

Where is it manufactured, how does it reach the EU and where is it sold?

2. What role does the company have?

Manufacturer? Importer? Distributor? More than one role depending on the flow?

3. What packaging is involved?

Identify the relevant packaging configuration and supporting components.

4. Which suppliers hold information about it?

Determine where specifications and technical evidence originate.

5. What PPWR requirements are relevant?

Separate requirements that apply now from those with later application dates.

6. What evidence already exists?

Find the information already held across the organization.

7. What is missing?

Identify the actual gaps.

8. Who owns the next action?

Supplier follow-up? Technical review? Role clarification? Documentation? EPR registration?

Doing this for a small number of real products can reveal far more than creating a theoretical PPWR responsibility matrix.

Five warning signs that PPWR ownership is not yet working

Your organization may need a clearer PPWR operating process if:

1. Different teams give different answers about who is responsible.

2. Supplier documents are being collected but nobody is consistently reviewing what they demonstrate.

3. Nobody can quickly connect a document to the packaging it supports.

4. Packaging changes can occur without triggering a compliance review.

5. PPWR knowledge sits with one person, while the underlying information remains scattered across the organization.

These are not simply administrative problems.

They make it harder to determine whether the company can actually demonstrate compliance when required.

Frequently asked questions

Which department should own PPWR compliance?

There is no single organizational answer that works for every company. A company should establish a clear coordinating owner, but PPWR implementation will often require input from packaging, procurement, compliance, quality, legal, supply chain and sustainability teams.

Can sustainability manage PPWR?

Sustainability can coordinate PPWR, particularly in organizations where the team already manages packaging and environmental compliance. However, the team will usually need information and actions from several other functions.

Should legal own PPWR?

Legal may play an important role in interpreting economic-operator responsibilities and regulatory requirements, but legal teams typically do not control all of the packaging specifications, supplier evidence and operational data necessary for implementation.

Is PPWR only a packaging-team responsibility?

No. Packaging teams may own critical technical information, but PPWR also creates responsibilities involving suppliers, conformity documentation, imports, distribution, EPR and market placement.

Does assigning an internal PPWR owner change who is legally responsible?

No. Internal organizational responsibility does not change the economic-operator obligations established by Regulation (EU) 2025/40.

What is the best place to start?

Choose a small number of actual product flows and determine your role, packaging, suppliers, applicable requirements, available evidence, gaps and next actions. This usually exposes where internal ownership needs to be clarified.

PPWR is becoming an operational process

The PPWR has applied generally since 12 August 2026.

For many companies, the question is therefore moving beyond:

“What does the regulation say?”

The next question is:

“How do we actually make this work inside the business?”

That requires more than regulatory knowledge.

It requires connecting products, packaging, suppliers, evidence, roles, markets and people.

The organizations that make PPWR manageable will not necessarily be the ones with the largest compliance teams.

They will be the ones that can clearly answer:

What needs to happen?

What information supports it?

Who owns the next action?

PPWR Academy is hosting a free webinar focused on exactly this transition from regulation to implementation.

Join us: https://events.ppwracademy.com/webinar/

We will work through practical examples involving:

• manufacturer, importer and distributor roles;

• supplier evidence;

• technical documentation;

• immediate PPWR obligations;

• product and supply-chain scenarios; and

• practical ways to make PPWR more manageable across an organization.

If PPWR touches packaging, procurement, supply chain, sustainability, compliance, legal, quality or product teams in your company, this session is for you.

REGISTER FOR THE FREE PPWR WEBINAR

Related PPWR Academy resources

PPWR Supplier Readiness: 7 Questions to Ask Your Packaging Suppliers
How to move from generic supplier requests to a structured evidence process.

You May Be a PPWR Manufacturer Without Realizing It
Why economic-operator roles need to be assessed against actual product and supply-chain flows.

PPWR Technical Documentation: What Evidence Must Support Packaging Conformity?
A detailed explanation of technical documentation, supporting evidence and the EU Declaration of Conformity.

PPWR Obligations Starting 12 August 2026: What Companies Need to Know
Which PPWR obligations matter now and which major requirements apply later.

Sources and further reading

Regulation (EU) 2025/40 on packaging and packaging waste

European Commission, Guidance document for Regulation (EU) 2025/40 on packaging and packaging waste (C/2026/3084), 10 June 2026

Disclaimer: This article provides general educational information about Regulation (EU) 2025/40 and does not constitute legal advice.