Regulation (EU) 2025/40 on packaging and packaging waste applies directly in Romania from 12 August 2026. If you produce, import or sell packaged products - including under your own brand - you have concrete obligations: a sheet for every packaging, the technical documentation, the declaration of conformity and the identification on the packaging. The guide below explains them in plain language.
PPWR (Packaging and Packaging Waste Regulation) is the European regulation that replaces Directive 94/62/EC. As a regulation, not a directive, it applies identically in all Member States, with no national transposition: the same text, the same deadlines, the same documents - in Romania as in Germany. Its aim is for every packaging placed on the EU market to be designed for recycling, to contain more and more recycled material, to be as small and light as possible, and to be traceable from the manufacturer to the consumer.
The bottle, the cap, the label, the shrink film, the cardboard divider, the stretch film, the pallet, the sachet in a kit, the tube - each is packaging and each has a level: sales, grouped or transport.
Manufacturer, importer, distributor, packaging supplier - the same company can have different roles on different packagings. The brand on the packaging decides who signs the declaration.
During an inspection, the authority asks for the declaration of conformity and the technical documentation for every packaging type. Documents are kept for 5 years, 10 years for reusable packaging.
PPWR does not split obligations by company type but by role. Find your situation - you may be in several at once.
You produce packaging or have it made under your name or brand - including when you fill a bottle bearing your label. You issue the declaration of conformity, keep the technical documentation and ensure the identification on the packaging.
You bring packaging or packaged products from outside the EU. You check that the manufacturer has done its documents, you keep them and you answer for them on the EU market.
You sell products packaged by others. You check that the declaration exists, the EPR registration and the labelling - you do not sign the declaration, but you must be able to present it.
You place products on the market under your name or brand, even if someone else makes them: you become the manufacturer of the sales packaging (Art. 21), with all obligations - including the declaration.
For every packaging type (not for every batch and not for every shade or flavour, if the physical packaging is the same).
The record per internal code: the body and every component (cap, label, film), materials, weights, pieces, recycled content, level (sales / grouped / transport). It is the source from which everything else is generated.
The evidence file: description and drawings, component materials, assessment of the requirements (Art. 5, 6, 10), test reports (heavy metals, PFAS where relevant), packaging suppliers' sheets and declarations (Art. 16).
The document signed by the manufacturer, with the 8 required points: packaging identification, manufacturer, responsibility statement, description, requirements met, standards, notified body (where applicable), additional information. It is kept version by version.
On the packaging: type, batch, serial or other element (Art. 15(5)); when the packaging cannot bear a marking, the information goes in the accompanying document. Everything archived for 5 years (10 for reusable), with the version history (Art. 39).
If your brand is on the product, you are the manufacturer of the sales packaging. Physical production does not matter.
The declaration is per packaging type and stays valid as long as the specification does not change. Dozens of identical declarations mean wasted work and a risk of inconsistency.
Without the technical documentation and the suppliers' documents, the declaration is a signed sheet without backing. An inspection asks for the file, not just the declaration.
Yvora is not just software. It is built in Romania, with Reciclad'OR expertise, and comes with people, courses and materials that take you all the way.
PPWR consultants who answer your concrete situations - from kits with several containers to the retailer's own brand or pooled pallets. Written opinions, on letterhead, when you need them.
Online sessions on features and legislative updates, workshops with users, recordings available in your account.
Questions from other companies in the same industry, consultants' answers, solved cases - you learn from situations similar to yours.
The Regulation, its annexes, Commission guidance, FAQs and delegated acts, organised and explained, with exact article references.
Step-by-step guides in the application, help texts on every field with the legal article next to it, and implementation manuals by industry.
Your customers and retailers download the current declarations themselves, in Romanian or English, and are notified when a new version appears.
Yes. PPWR has no size threshold for the documentation obligations: if you place packaging on the market, you need a declaration and technical documentation. There is a single exception to the manufacturer role: a micro-enterprise whose packaging supplier is in the same Member State - the supplier is then the manufacturer (Art. 3(1) point 13(b)).
No. It is made per packaging type and covers all batches as long as the specification does not change. The batch goes into the identification on the packaging (Art. 15(5)), not into the declaration.
The manufacturer role follows the brand on the sales packaging: the retailer is the manufacturer of that packaging (Art. 21), and you, as bottler or producer, provide the information and documentation. The grouped and transport packaging (film, divider) remain yours.
They are transport packaging. Unprinted film and dividers cannot bear a marking - the identification goes in the accompanying document. A pooled pallet (EPAL) is not your brand: its declaration comes from the pallet supplier and is kept in the file.
From 2030 every packaging will receive a grade (A, B, C), and packaging below the threshold can no longer be placed on the market. Assessing now shows what needs to change in time - materials, colours, labels, adhesives - and documents in Annex VII that you did the analysis.
For a company with a few dozen packagings and the suppliers' documents at hand, the first sheets and declarations take a few days; a portfolio of hundreds of codes is loaded from Excel and documented in a day. The longest step is usually getting the suppliers' documents - start with it.
Sources: Regulation (EU) 2025/40, Annexes VII and VIII, Art. 3, 5, 6, 7, 10, 12, 15, 16, 21, 24, 39; European Commission guidance and FAQs. This guide is informative and does not replace the analysis of your specific situation.
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