Glossary

Packaging EPR Glossary (EU PPWR)

The terms a packaging and sustainability team actually uses under the EU Packaging and Packaging Waste Regulation, defined in plain language by practitioners. For the full walk-through, see the Packaging EPR practitioner's guide.

PPWR

The EU Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40. The EU-wide rulebook for packaging and packaging waste that repeals and replaces Directive 94/62/EC. As a Regulation it applies directly in every Member State, so the substantive rules are the same wherever you sell.

Extended Producer Responsibility (EPR)

The principle that the company first placing packaging on the market funds and accounts for what happens to that packaging across its life, including the collection, sorting, and treatment of the resulting waste, rather than leaving the cost to the public waste system alone.

Regulation (EU) 2025/40

The formal legal reference for the PPWR. It entered into force on 11 February 2025 and applies generally from 12 August 2026, with individual obligations phasing in on later dates that should each be verified.

Directive 94/62/EC

The earlier Packaging and Packaging Waste Directive that the PPWR repeals with effect from 12 August 2026. As a Directive it was transposed into national law country by country, which the PPWR replaces with a single directly applicable Regulation.

Producer

The manufacturer, importer, or distributor that first makes packaging or packaged products available on the market in a Member State, regardless of selling technique, including distance selling and e-commerce. Producer status is determined per Member State and per packaging stream.

Make Available on the Market

To supply packaging for distribution, consumption, or use on the market in the course of a commercial activity. The point at which packaging is first made available in a Member State decides who is the producer there.

Authorised Representative for EPR

A party appointed in a Member State, under written mandate, to take on a producer's extended producer responsibility obligations there. It is commonly required when the producer is established outside that Member State and sells into it.

Authorised Representative

A party appointed under written mandate to act on a manufacturer's product-compliance obligations. This is a distinct role from the authorised representative for EPR, and a company may need both.

Manufacturer

The party that makes packaging, or has it designed or made under its own name or trademark. It places only conforming packaging on the market, runs the conformity assessment, and draws up the technical documentation and the EU declaration of conformity.

Importer

An EU-established party that places packaging from outside the EU on the market. It carries verification duties to confirm the manufacturer completed the required conformity work before the packaging reaches the market.

Distributor

A party in the supply chain, other than the manufacturer or importer, that makes packaging available on the market. It carries due-care duties to check the packaging and its documentation before passing it on.

Fulfilment Service Provider

A party that, for others, warehouses, packs, addresses, or dispatches goods, common in e-commerce. It carries its own PPWR duties and helps verify that a producer is registered before service continues.

Online Platform Provider

A provider of an online marketplace that, before letting a producer sell through it, must obtain the producer's registration number and a self-certification that the producer is meeting its obligations.

Producer Register

The national register of producers each Member State maintains. A producer must be registered in every Member State where it first makes packaging available, and may not make packaging available there unless it, or its authorised representative for EPR, is registered.

Producer Responsibility Organisation (PRO)

A body that discharges extended producer responsibility obligations collectively on behalf of its member producers, including registration, reporting, and financing of waste management. Membership is mandatory in some Member States.

Eco-modulation

The adjustment of a producer's EPR financial contribution to reflect the environmental performance of its packaging. Fees are modulated by recyclability performance grade and may also be modulated by recycled-content percentage, so better packaging pays less.

Recyclability

The property of packaging that is designed for material recycling and, once it becomes waste, can be separately collected, sorted, and recycled at scale. The PPWR requires all packaging placed on the market to be recyclable.

Recyclability Performance Grade

The A, B, or C grade assigned to packaging based on how recyclable it is, against a defined methodology. Grade acts as both a market-access gate over time and a lever on the eco-modulated EPR fee.

Recycled Content

The share of a packaging item made from recovered material. The PPWR sets minimum recycled-content percentages for plastic packaging, phasing in from around 2030, with the recycled material drawn from post-consumer plastic waste.

Minimisation

The requirement to design packaging to the minimum weight and volume needed for it to function. Packaging that exists only to inflate perceived product size, through double walls, false bottoms, or unnecessary layers, is restricted.

Reuse Target

A minimum share of certain transport and grouped packaging formats that an economic operator must keep reusable within a reuse system, with the share rising over time. The obligation falls on the operator that uses the packaging rather than the one that supplies it.

Refill

An arrangement under which a customer fills a container, often their own or one supplied at the point of sale, with a product, reducing single-use packaging. Specific sectors carry refill and reuse-offer obligations.

Reuse System

The organisational and technical setup that lets packaging be used more than once for the same purpose, including the logistics for return, cleaning, and redistribution, against which reuse targets are measured.

PFAS Restriction

The PPWR limit on per- and polyfluoroalkyl substances, a family of persistent chemicals, in food-contact packaging. From 12 August 2026, food-contact packaging may not be placed on the market above the set PFAS limits.

Heavy-metal Limit

The PPWR cap on the sum of lead, cadmium, mercury, and hexavalent chromium present in packaging, which must not exceed 100 mg/kg. The limit is absolute rather than phased in.

Substances of Concern

Substances that have an adverse effect on human health or the environment, or that hinder reuse and recycling. The PPWR requires their presence in packaging to be minimised, on top of the specific PFAS and heavy-metal limits.

Packaging Waste

Any packaging or packaging material that becomes waste. The PPWR covers packaging waste from all sources, whether industrial, commercial, office, service, or household.

Compostable Packaging

Packaging designed to break down in a composting process under defined conditions. The PPWR sets where compostable packaging is required or permitted, separate from the general recyclability requirement.

Design for Recycling

Designing packaging so it can be effectively recycled at end of life, the criteria that underpin the recyclability requirement and the A, B, or C performance grade.

Deposit-return Scheme (DRS)

A system in which a deposit is charged on certain packaged products and refunded when the empty packaging is returned, used to lift separate collection rates for formats such as single-use beverage containers.

EU Declaration of Conformity

The formal statement, drawn up once conformity is demonstrated, that packaging meets the applicable PPWR requirements. It is kept with the technical documentation for a set retention period.

Technical Documentation

The supporting file that demonstrates packaging meets the PPWR requirements, including the evidence behind substance, recyclability, and recycled-content claims. It is retained, generally for five years for single-use packaging.

Member State

A country that is part of the European Union. While the PPWR's substantive rules are EU-wide, the EPR scheme, including registration mechanics, fees, and audit rules, is operated per Member State, so each target country has to be checked on its own terms.

From terms to a mapped program

Compliance Command Center turns these concepts into a defensible, audit-ready program, run by practitioners and backed by software. It determines your producer status across each Member State, builds your EPR registration readiness, and tracks the phased PPWR obligations against your SKUs and formats.

See Compliance Command Center Read the guides