The technical annex specifying the content of the packaging's technical documentation - general description, composition per component, recyclability assessment, recycled content, substances of concern, applied standards and visual documentation.
Annex VIIThe annex establishing the format and content of the EU Declaration of Conformity required by Art.39 - identification of the producer, identification of the packaging, applied standards, signatory and place/date of issue.
Annex VIIITwo distinct roles. Art.17 - a representative on the design side, appointed voluntarily. Art.45 - a representative on the EPR side, appointed mandatorily by a producer placing packaging on a market where they are not established.
Art. 17 and 45A unit of packaging made of two or more different materials that are part of the weight of the same unit and cannot be separated manually: the beverage carton with plastic and aluminium layers, the paper cup with a plastic lining. It is declared on its main material, and the layers influence the recyclability grade.
Art. 3(1) pt. 2The process by which the producer demonstrates that a packaging meets the essential requirements of Annex II Part 1. Result: a Declaration of Conformity plus the supporting technical documentation.
Art. 39 + Annex IIPackaging in direct contact with food, cosmetics, pharmaceuticals or medical devices. Subject to the PFAS restriction (Art.5), the substances-of-concern regime (Annex III) and a derogation regime for recycled-content thresholds.
Art. 5 · Art. 7The mandatory document by which the producer (or their authorised representative) declares that the packaging meets the essential requirements of Annex II Part 1. Kept at the disposal of the authorities for 5 years (single-use) or 10 years (reusables).
Art. 39 + Annex VIIIA system in which the consumer pays a deposit on a beverage container, refunded upon return. Art.50 requires each member state to have a DRS for plastic and metal containers up to 3 L by 1 January 2029.
Art. 50The criteria ensuring that packaging can be sorted and processed efficiently in the existing infrastructure - material and adhesive compatibility, colour standards, label placement. Established through delegated acts and feeding the grade calculation.
Art. 6A digital record of standardised information about a product. For packaging, the data carrier (QR code) becomes mandatory from 12 August 2028 through Art.12, sharing the same carrier with any product DPP.
Art. 12 + Reg. 2024/1781Selling online directly to end users in other Member States makes you an EPR "producer" in EVERY targeted state: one registration (Art. 44), contributions (Art. 45) and an authorised EPR representative per state (Art. 45(3)). When selling via platforms, the platform checks proof of registration before letting you sell.
Art. 45(3)–(4)An economic operator in the supply chain, other than the producer or the importer, who makes packaging available on the EU market. Must verify the Art.12 labelling and the existence of an upstream Declaration of Conformity.
Art. 3 (definitions)Transport packaging used to deliver products sold online or at a distance to the end user: the courier box, the bubble mailer, protective filling, parcel tape. A subcategory of transport packaging with its own minimisation rules (the empty-space ratio - Art. 24); direct delivery to consumers in other Member States triggers an EPR role in each state.
Art. 3(1) pt. 8 · Art. 24Adjusting extended-producer-responsibility contributions according to the packaging's environmental performance - lower fees for easily recyclable packaging, higher fees for problematic ones.
Art. 44–45The framework obliging producers to bear the cost of the end-of-life management of packaging - collection, sorting, treatment, recycling. Producers register (Art.44) and, when not established locally, appoint an authorised representative (Art.45).
Art. 44–45The criterion deciding whether a service item is packaging: the cup the barista fills is service packaging; the same cup sold empty, in a set of 50, for home use, is a product - and the packaging is only the set's film. At the till, counter or bar → packaging; at home, by the customer → product.
Art. 3(1) pt. 1(d) · Annex I let. CPackaging grouping a number of sales units at the point of sale - sold as such or used only to restock shelves - removable without affecting the product: the film-wrapped multipack, the box of 12 cans, the 4×125 g yoghurt board. It is a DISTINCT packaging: its own sheet, declaration and EPR records.
Art. 3(1) pt. 6The sum of lead + cadmium + mercury + hexavalent chromium ≤ 100 mg/kg (100 ppm), a restriction inherited from Directive 94/62/EC. Applies to all packaging, regardless of food contact.
Art. 5 + Annex IIIA natural or legal person established in the EU who places on the EU market packaging from a producer outside the EU. Must verify design conformity, the existence of the technical documentation and, where applicable, an authorised representative.
Art. 3 (definitions)Any supply of packaging for distribution, consumption or use on a Member State's market in the course of a commercial activity - for payment or free of charge. Together with "placing on the market" it forms the pair of verbs all PPWR roles rest on; "management" concerns only packaging WASTE.
Art. 3(1) pt. 9The operator who has the packaging designed or made under their own name or trademark - responsible for conformity, issues the Declaration of Conformity and keeps the technical documentation. For sales and grouped packaging, the manufacturer is normally the FILLER; for transport, e-commerce, service and primary production - the PHYSICAL PRODUCER, unless the packaging bears the user's brand. One manufacturer per packaging across the whole Union.
Art. 3(1) pt. 13 · Art. 15The activities of the competent national authorities to verify packaging conformity - inspections, sampling, testing, document requests. They can withdraw non-conforming packaging from the market and impose penalties.
Reg. (EU) 2019/1020Under 10 employees and annual turnover or balance sheet of at most EUR 2 million (Recommendation 2003/361/EC). If a microenterprise sells under its brand products filled by someone else, and the packaging supplier is in the SAME Member State, the manufacturer remains the supplier - the exception that moves the declaration duty entirely.
Art. 3(1) pt. 13(b)A platform intermediating sales to consumers must obtain from the seller, BEFORE letting them sell, proof of EPR registration in the consumer's state (Art. 45(4), read with Regulation (EU) 2022/2065 - the DSA) and can take over some reporting obligations under a written mandate.
Art. 45(4) · Reg. (EU) 2022/2065Any product, regardless of material, intended to contain, protect, handle, deliver or present products - from raw materials to processed goods, from the producer to the user or consumer. Includes primary (sales), secondary (grouped) and tertiary (transport) packaging.
Art. 3 (definitions)The unique identifier of a distinct packaging. In Yvora, each code carries the composition, the recyclability grade, the recycled content and the documents - it is the unit at which the assessment is made and the Declaration of Conformity is issued.
The part of a packaging that can be separated by hand or simple physical means: the label, lid, stopper, film, sleeve. A component has no declaration of its own - its data (composition, substances, weights, recycled content) feeds the manufacturer's file through Art. 16. If it ever functions ALONE as packaging, it becomes packaging with the full regime.
Art. 3(1) pt. 1 · Art. 16Art.10 + Annex IV require every packaging to be reduced to the minimum weight, volume and number of layers compatible with safety and functionality. Art.24 caps empty space at 50% in transport packaging from 2030.
Art. 10 + Annex IVPer- and polyfluoroalkyl substances - persistent synthetic chemicals, restricted by Art.5 in food-contact packaging above trace thresholds. Applies from 12 August 2026 for intentionally added PFAS.
Art. 5 + Annex IIIThe first making available of packaging on the Union market. For imports, it happens at customs release for free circulation - including for packaged raw materials brought in for own use. PPWR's operative verb: obligations attach to this moment, not to the later sale.
Art. 3(1) pt. 12The Packaging and Packaging Waste Regulation (EU) 2025/40. It governs design, labelling, recycled content and producer responsibility. It entered into force on 11 February 2025; it applies generally from 12 August 2026.
Reg. (EU) 2025/40Primary (sales) - the unit that reaches the consumer. Secondary (grouped) - groups several sales units. Tertiary (transport) - facilitates handling and transport.
Art. 3 (definitions)The item designed and intended for UNPROCESSED products of farming, fishing and animal husbandry: fruit crates, grain sacks, egg trays, fish boxes. The packaging of processed products (the zacusca jar, the flour bag) is SALES packaging. The category is named in the EPR "producer" definition.
Art. 3(1) pt. 4 · pt. 15Producer Responsibility Organisation - the licensed entity in Romania through which producers collectively meet their packaging EPR obligations (e.g. Reciclad'OR). The rarely used alternative is individual compliance.
Art. 44–45 · GEO 92/2021The operator who FIRST makes the packaging available on a Member State's territory - they register in the Art. 44 register and pay the extended-responsibility contributions (Art. 45), in Romania normally through a PRO (OIREP). A role distinct from the manufacturer: judged separately, on different criteria, and the two can belong to different companies.
Art. 3(1) pt. 15 · Art. 44–45The public register every EPR "producer" joins BEFORE first making available on a Member State's market. Distributors are legally required to check their suppliers' registration before making goods available (Art. 19(2)) - without a valid registration, the goods cannot legally be sold.
Art. 44 · Art. 19(2)A three-level classification (Art.6 + Annex II Table 3): Grade A (≥95%), Grade B (≥80%), Grade C (≥70%). Below grade C, packaging cannot be placed on the market from 1 January 2030; the grade B threshold applies from 1 January 2038.
Art. 6 + Annex IIThe percentage of post-consumer recycled (PCR) plastic incorporated in a plastic packaging. Art.7 + Annex III set minimum thresholds per packaging family from 1 January 2030, with higher thresholds from 2040.
Art. 7 + Annex IIIPackaging conceived, designed and placed on the market to accomplish multiple trips or rotations within a reuse system. Art.11 sets the qualification criteria; document retention is 10 years, versus 5 years for single-use.
Art. 11The organisational, technical and financial arrangements enabling reusable packaging to make multiple rotations: governance, take-back conditions, cleaning, rotation rates (Annex VI). In a CLOSED loop the packaging stays the system's; in an OPEN loop it circulates between participants and ownership changes. Documents for reusables are kept 10 years.
Art. 27 + Annex VI · Art. 15(3)Packaging conceived to constitute a sales unit of products and packaging for the end user at the point of sale: the bottle with its label and cap, the jar, the blister with its box and leaflet. The manufacturer is normally whoever FILLS and sells under their brand - not whoever physically makes the bottle or box.
Art. 3(1) pt. 5The product or set of products offered for sale as one whole to the end user - the box of 5 injectable vials is ONE sales unit, not five. The packaging sheet is drawn up per sales unit, with all its components (vial ×5, stopper ×5, cap ×5, the box, the separator, the label, the leaflet) and the weights summed per unit. The body is the component performing the main containment function.
Art. 3(1) pt. 5 · Guidance C/2026/3084The item designed and intended to be FILLED AT THE POINT OF SALE: the checkout bag, the cup the barista fills, the tray from the hot counter, dry-cleaners' garment covers. The criterion that decides everything is filling at the point of sale: the same cup sold empty, in a set, for home use is a PRODUCT, not packaging (Annex I let. C pt. 2) - likewise bin bags sold as products.
Art. 3(1) pt. 1(d)–(e) · Annex I let. CPackaging conceived, designed and placed on the market to be used only once before disposal or recycling. Certain single-use formats are banned from 1 January 2030 (Art.25 + Annex V).
Art. 3 · Art. 25Chemicals restricted in packaging by Art.5 + Annex III, including the sum of heavy metals (≤ 100 ppm) and the PFAS restriction on food-contact packaging. The Commission may extend the list through delegated acts.
Art. 5 + Annex IIIAnyone selling packaging or packaging materials to an economic operator: they are OBLIGED to provide all information and documentation needed for conformity - composition, substances (including PFAS evidence, on request), weights, recycling performance, recycled content. The data is not a commercial favour but a legal obligation.
Art. 16(1) · Art. 5(4)–(5)Service packaging filled at attended points of sale with drinks or ready-prepared food, transported and consumed immediately elsewhere, usually straight from the packaging: the coffee cup with its lid, the pizza box, the salad box, the take-away soup container.
Art. 3(1) pt. 3The set of information demonstrating the packaging's conformity: description, components, recyclability assessment, substance tests, recycled content, photos. It underpins the Declaration of Conformity.
Art. 39 + Annex VIIEvery economic operator's duty to identify, at the authorities' request, who supplied them and whom they supplied with packaging - 5 years for single-use, 10 years for reusables. Kept at every link of the chain, separately from the technical documentation.
Art. 22Packaging facilitating the handling and transport of sales units, preventing damage: the pallet, stretch film, transport boxes, straps, big bags, IBCs. Road, rail, sea and air containers are excluded. Reversed rule versus sales packaging: the manufacturer is the PHYSICAL PRODUCER, not the user - unless it bears the user's brand.
Art. 3(1) pt. 7Based on Regulation (EU) 2025/40. The terms evolve as the Commission adopts the delegated and implementing acts.