The PPWR glossary: Packaging Regulation terms explained

Declaration of conformity (DoC)

The document by which the producer declares a packaging’s conformity with the PPWR requirements — mandatory from 12 Aug 2026 (Art. 39). Annex VIII prescribes its structure and content: number, subject with traceability, relevant legislation, harmonised standards, place/date and signatory. The template contains no “valid until” field.

Digital product passport (DPP)

A machine-readable data record per product (from the ESPR ecodesign regulation), retrievable e.g. via QR code: materials, recycled content, repair and disposal information. For packaging, Art. 12 PPWR opens the door via QR labelling — the data foundation is the same one that sits in the technical documentation today.

Empty-space rule (Art. 24)

From 2030, e-commerce, grouped and transport packaging may contain at most 50% empty space; in parallel, packaging must generally be minimised to the necessary weight and volume (Art. 10, Annex IV).

EPR (extended producer responsibility)

The principle that whoever places packaging on the market bears the cost of its collection and recovery. In practice: registration and volume reporting in every target market with the competent register or scheme — in Germany e.g. LUCID plus scheme participation.

EUR-Lex / CELEX 32025R0040

The official source of EU law. The PPWR is available there under CELEX number 32025R0040 in all official languages — for questions of detail, the regulation text beats any secondary source.

GTIN / EAN

The Global Trade Item Number (barcode number) uniquely identifies a product. In PPWR practice it links product and packaging: declarations of conformity typically list the products concerned via their GTINs in an annex.

Harmonised labelling (Art. 12)

From 12 Aug 2028, packaging must carry harmonised labelling — material composition and disposal guidance, prospectively via a data carrier such as a QR code. Implementing acts define the details; the date may shift accordingly.

Harmonised standards

European standards whose application triggers the presumption that the related legal requirements are met. The declaration of conformity names the standards or common specifications applied — one of the mandatory items under Annex VIII.

Heavy-metal limit (100 mg/kg)

The sum of lead, cadmium, mercury and chromium VI in packaging or packaging components must not exceed 100 mg/kg (Art. 5). Evidence usually comes via the material suppliers’ declarations of conformity.

LUCID / Central Agency (Germany)

The public packaging register of Germany’s Central Agency (ZSVR). Anyone placing packaged goods on the German market must register there and additionally contract a dual system (scheme participation) — already today, independent of the PPWR.

Packaging component

A hand-separable part of a packaging — e.g. jar, lid, label, pouch. Many PPWR requirements (substance limits, recyclability, weights for EPR) apply at component level, which is why recording each component with material and weight pays off.

Performance grades (recycling grades)

The grading of recyclability into classes (A–C per Annex II): grade A from 95%, B from 80%, C from 70% recyclable weight share. From 2030 grade C is the entry threshold; from 2038 the requirement rises to grade B.

PFAS limits

Per- and polyfluoroalkyl substances (“forever chemicals”). For food-contact packaging, Art. 5(5) sets limits from 12 Aug 2026 — effectively a PFAS ban for food contact. Suppliers must declare compliance; the declaration belongs in the technical documentation.

Placing on the market

The first making available of a packaging on the Union market — the moment PPWR duties attach. Importers place goods from third countries on the market and thereby assume producer-like duties.

PPWR (Regulation (EU) 2025/40)

The EU Packaging and Packaging Waste Regulation. It applies directly in all member states from 12 Aug 2026 — unlike the previous directive, without national transposition laws — and governs substance restrictions, recyclability, recycled content, labelling and conformity documentation for packaging.

Primary, secondary, tertiary packaging

The three levels: sales packaging on the product (primary), grouped packaging (secondary) and transport packaging (tertiary). The PPWR covers all three — duties such as labelling or empty-space rules differ per level though.

Producer (role)

The actor who first places packaging on the market together with a product — for own brands typically the company that fills or has products filled. The producer bears the main duties: conformity assessment, declaration, technical documentation, labelling.

Recyclability (Art. 6)

From 2030, packaging must be designed for recycling and is graded into performance classes; packaging below the minimum grade may then no longer be placed on the market. The EU sets the harmonised assessment methodology in delegated acts — until then, gradings are professional estimates.

Recycled content (Art. 7, PCR)

The share of post-consumer recyclate in a packaging’s plastic part. From 2030, minimum shares apply per packaging category (annex to Art. 7), with higher tiers from 2040. This can only be evidenced with documented shares per layer or component — supplier specifications are the source.

Reuse & refill targets (Art. 29)

From 2030, reuse targets apply to certain sectors and packaging types (e.g. transport packaging and beverages). Affected companies must evidence their shares — one more reason to track packaging volumes cleanly per category.

Scheme participation

The paid participation of your packaging volumes in a take-back scheme (in Germany: the dual systems). Licence fees depend on material category and weight — which is why clean per-component volume tracking pays off.

Technical documentation (Annex VII)

The evidence file behind the declaration of conformity: packaging description, materials used, test and calculation results, supplier evidence. It must be available to authorities on request and kept up to date over the years.

Packstr supports PPWR documentation and is not legal advice.