PPWR in Practice: Complex and Demanding – but Solvable

trinasco GmbH’s experience from customer projects involving household articles and textiles

Since August 12, 2026, the EU Packaging Regulation (EU) 2025/40 – the PPWR for short – has applied directly in all Member States. It replaces the Packaging Directive 94/62/EC, which set the framework for around three decades. The date of application was not postponed, despite unresolved questions of interpretation and demands from industry.

trinasco GmbH advises many companies from a wide range of industries on implementation. This article describes our approach in six steps and answers the questions we encounter most frequently in our projects. The examples come from two projects: a gift set with household articles and the packaging used by a shirt supplier.

The Structure of This Article

The article is divided into three parts. They build on one another – the experience from the projects is difficult to classify without the process, and the questions at the end come directly from those projects. Each part can nevertheless also be read on its own.

• Part 1 – The PPWR requirements and the path to implementation. The six packaging categories defined by the Regulation, how a packaging unit is distinguished from its components, and how we move in six steps from the packaging inventory to the signed Declaration of Conformity.
• Part 2 – Two practical projects. A gift set with household articles involving a single sales packaging, and a shirt supplier whose entire packaging range had to be recorded – including the question of what was still open after six weeks.
• Part 3 – Questions from the projects. Nine questions we encounter most frequently: when a polybag is sales packaging and when it is transport packaging, whether clothes hangers and needles count as packaging, who prepares the Declaration of Conformity for standard transport packaging, what applies to existing stock, and how much effort is involved within the company itself.

Anyone who came here with a specific question will find the answer fastest in Part 3. Each answer there is written so that it remains understandable without the preceding parts.

Part 1: The PPWR Requirements and the Path to Implementation

This part describes what the PPWR requires of companies and how it can be worked through: from clarifying one’s own role and classifying the packaging to the six steps we apply in our projects – from the packaging inventory to the signed Declaration of Conformity.

Producer or Manufacturer? Two Terms That Do Not Mean the Same Thing

This distinction comes first because everything that follows remains ambiguous without it. The PPWR uses two role designations that mean the same thing in everyday German, but trigger different obligations in legal terms.

A company can be both at the same time. But it can also be a producer without being a manufacturer – and vice versa. Anyone who fails to distinguish between the roles will look for the Declaration of Conformity in the wrong place or report quantities that they do not have to report at all.

Once the roles have been clarified, the actual implementation follows. In our projects, it proceeds through six steps that build on one another: without an inventory there is no prioritization; without a list of requirements there is no targeted supplier request; without verified evidence there is no Declaration of Conformity.

Step 1: Which Packaging Do We Place on the Market at All?

The first question is not “Which requirements apply?” but “What do we place on the market – and what function does it have?” The PPWR distinguishes packaging by its function, not by its material. The same cardboard box can be sales, grouped or transport packaging depending on how it is used. The classification determines which obligations apply: the harmonized labeling under Art. 12, for example, does not apply to transport packaging – but it does apply to e-commerce packaging, which is legally a subcategory of transport packaging.

It does not apply immediately either: labeling under Art. 12 is expected to apply from August 12, 2028, and in any event only 24 months after the entry into force of the implementing act that establishes the symbols (see Table 5). This act has not yet been adopted. At the beginning of 2026, the Commission’s Joint Research Centre (JRC) submitted a technical proposal for a system of pictograms, color coding and text, which is currently being discussed; it is not binding.

A systematic review of the entire range along the six packaging categories in Art. 3 PPWR has proven effective:

Packaging Unit, Integrated and Separate Components

Within each category, the individual packaging unit is considered (Art. 3(1)(45) PPWR): the unit made up of all components that together perform a packaging function. For the packaged shirt, this is not just the polybag, but the bag, collar support, clips and labels together. Three further terms also appear in Art. 3(1) PPWR:

• Integrated components (No. 43) are essential to the function, do not need to be separated from the main part, and are typically disposed of at the same time – for example, an affixed label.
• Separate components (No. 44) are completely removed from the main part and typically disposed of beforehand and separately – for example, a loose insert or a collar support.
• Composite packaging (No. 24) consists of two or more materials that cannot be separated by hand – unless one material accounts for no more than 5% of the total mass. Labels, colors, printing inks, adhesives and varnishes are disregarded.

This distinction determines how recyclability is assessed, which weights by material are included in EPR reports, and which evidence is needed from the supplier. In our two projects, the review resulted in seven components for the gift-set box and five for the packaged shirt – plus a sewn-in care label that is not packaging.

The Product/Packaging Matrix

The result of Step 1 is a matrix: each row represents a packaging unit, and each column a product with which it is placed on the market. It almost always becomes clear that a large product range can be reduced to significantly fewer packaging units – and that is where efficiency is created: a packaging unit is documented once and applies to all assigned products.

The two gift-set variants differ only slightly in their contents and are delivered in the same packaging unit. It is therefore documented only once. The same applies to grouped, e-commerce and transport packaging.

Step 2: In What Order Do We Process the Packaging?

For manageable ranges, all packaging units can be processed in parallel. With several hundred items, an order is needed. One important point in advance: prioritization determines the order in which work is carried out – not whether it is carried out. Every packaging unit placed on the market must comply with the PPWR. The first criterion is the most important because it determines the scope of all further obligations:

If role, material, supply chain and control risk are combined into a regulatory risk and set against quantity, four quadrants – and therefore an order – emerge:

• Priority A – high quantity, high risk. This is where the work begins. In the textile project, these were the polybags in the standard sizes – high quantities, plastic and a supply chain reaching into Asia – as well as the printed labels and hangtags.
• Priority B – high quantity, low risk. The gift-set box belongs here despite its seven components: the monomaterial approach significantly reduces the risk. The standard shipping carton also belongs here – the packaging supplier issues its Declaration of Conformity, not our client.
• Priority B – low quantity, high risk. The polybags in special sizes: the same material and supply chain as the standard sizes, but significantly smaller quantities.
• Priority C – low quantity, low risk. The outer carton for supplying stores. It is processed, but last.

There is currently no official list of the types of packaging that authorities are focusing on particularly. What can be substantiated is that the Commission is taking a warning-first approach at the outset. In Germany, the Central Agency Packaging Register primarily monitors registration, reporting and EPR obligations; the authorities responsible under state law conduct on-site inspections. At EU level, the Commission has declared coordinated controls of products sold online and imported products a priority.

This results in an increased control risk for online channels and imports from non-EU countries, as well as for packaging whose substance limits can be readily verified in a laboratory.

Step 3: Which Requirements Apply to Each Packaging Unit?

For this step, we use the market-leading Product Compliance platform. What matters for the PPWR is that it allows not only products but also packaging to be created and processed as separate objects. Based on the packaging category, materials, components, target markets and the time of marketing, the platform generates a list of requirements that covers not only the PPWR but also substance law, national requirements, standards and voluntary standards.

The time of marketing is decisive, because the PPWR introduces its obligations in stages: the same packaging must meet different requirements today than from 2028 or from 2030.

The efficiency gain lies in the linking: the packaging is connected to the associated products – the matrix from Step 1 is mapped directly in the system. Evidence is stored once with the packaging and is available for all linked products. If a legal act changes, for example through new entries in the REACH Candidate List, the list of requirements is updated.

Technical Documentation and Declaration of Conformity from One System

The platform thereby covers two obligations that have applied since August 12, 2026: before placing packaging on the market, the producer must carry out a conformity assessment procedure (Art. 38), prepare technical documentation under Annex VII and – if conformity has been demonstrated – issue an EU Declaration of Conformity under Art. 39. The old Packaging Directive did not provide for a formal Declaration of Conformity for packaging.

Neither is created as a separate Word document; both are generated from the same data as the list of requirements. The declaration can be generated in all official EU languages – practically relevant because it must be translated into the language of the Member State in which the packaging is placed on the market; English alone is not sufficient. It can also be linked to the company’s own website or a Product Information Management (PIM) system, so that business partners and authorities always see the current version.

Example: 41 Requirements for a Gift Box

For the gift-set box targeting Belgium, France, Italy and Spain, the list of requirements comprises 41 individual requirements. What sounds like a lot quickly falls into place:

• PPWR core: heavy-metal limit (sum of lead, cadmium, mercury and hexavalent chromium max. 100 mg/kg), minimization of substances of concern and microplastics, recyclability as a principle, minimization under the requirements that remain temporarily applicable, empty space, technical documentation and Declaration of Conformity.
• Substance law: REACH Candidate List and Annex XVII, the POPs Regulation, and the French ban on mineral oils in packaging and printing inks.
• National implementation: EPR registration and packaging requirements in Belgium, Spain and Italy; in France, the Triman logo, the Info-tri sorting instruction and environmental information under Décret 2022-748.
• Documentation and standards: bill of materials (BoM), packaging identity declaration, artwork, relevant EN standards, material identification under Decision 97/129/EC, and FSC standards.

Five requirements are marked as “not yet mandatory” – those that will apply only from 2030 or later. They remain visible and can be activated in good time. Two documents prove particularly valuable. The bill of materials is the basis for all assessments and EPR reports. The identity declaration – also called an identification certificate – proves that the packaging delivered is the same as the packaging to which the test reports refer.

Why this is necessary is shown by a typical case from packaging procurement: a film manufacturer produces PE film under its internal designation and supplies it to several customers – each under its own item number, and some under its own name. The heavy-metal test report is issued under the manufacturer’s internal designation. For our client, this report cannot be used without a connecting document, because there is no way to prove that its bag variant and the tested film are the same material. The identity declaration provides precisely this bridge.

Without it, an otherwise valid test report cannot be assigned to a specific packaging unit.

What Applies When?

Step 4: Which Evidence Do We Need from Suppliers?

Under Art. 16 PPWR, suppliers of packaging and packaging materials must provide the producer with all information and documents needed for the proof of conformity, including the technical documentation under Annex VII. The list of requirements from Step 3 makes the request precise: we do not ask generally for “PPWR compliance”, but specifically for the documents that cover individual requirements.

Two Starting Situations with Different Levels of Complexity

• Case a) The company sources the packaging itself. It purchases cartons, inserts or films from packaging suppliers and packages its products itself or has them packaged. The evidence is requested directly from the suppliers of the packaging materials – through exactly one tier.
• Case b) The company sources the product fully packaged. The product supplier delivers the product and packaging as one package. The company requests the documents for both product and packaging from this supplier.

In our projects, Case b) is the standard situation – and this is where the greatest challenge in implementing the PPWR lies. The product manufacturer generally does not produce the packaging itself, but in turn sources it from one or more packaging suppliers. It therefore has to request the documents from its upstream suppliers. In the case of Asian product suppliers, these upstream suppliers are usually also based in Asia and are rarely fully informed about the PPWR requirements.

If documents from the upstream supplier are missing, the packaging documentation remains incomplete – or it is created only with a considerable loss of time because every follow-up question has to pass through two tiers. This does not change who is responsible: anyone who has products manufactured under their own name or trademark is a producer, even if they do not produce a single piece of packaging themselves.

What helps in Case b):

• Provide the evidence list: a specific list for each packaging component that the product supplier can pass on to its upstream suppliers – ideally in English and with templates.
• Make upstream suppliers visible: who supplies the film, carton, labels, clips and printing inks? This overview alone significantly speeds up follow-up questions.
• Anchor PPWR evidence contractually: in specifications, purchasing terms and orders, especially for new orders.
• Plan laboratory testing as a fallback, if evidence cannot be obtained or cannot be obtained in time.

Ideally, all components of a packaging unit would come from one supplier – then one set of documents would be sufficient. In reality, this is rare: film, cartons, metal goods and printing come from different industries and are purchased wherever the product is assembled. The question is still worthwhile for new developments, because every upstream supplier eliminated saves ongoing maintenance effort.

Step 5: How Do We Check the Documents Received?

A folder full of documents is not yet proof of conformity. Every piece of evidence received is checked before being assigned to a requirement. Three questions are central:

This is where the preliminary work pays off: the identity declaration links the company’s own item number to the designation on the test report, while the list of requirements shows the outstanding gaps. Every verified piece of evidence is assigned directly to the relevant requirement, so the processing status is visible at all times. Incomplete evidence is returned to the supplier with a specific follow-up question – not with a general “please improve this”.

Step 6: How Is the EU Declaration of Conformity Created?

Once all applicable requirements are supported by verified evidence, the conformity assessment is complete. The producer issues the EU Declaration of Conformity under Art. 39, whose structure is specified in Annex VIII. The technical documentation under Annex VII forms the basis and must remain available for market surveillance.

Who signs – and who is liable? The declaration is signed on behalf of the producer. To the outside world, the company therefore stands behind the fact that the packaging meets the requirements.

For the people who sign, however, the matter is not over. Anyone who releases packaging without checking the requirements and the evidence bears a personal risk – in two ways.

First, liability towards the company itself. Managing directors owe it the diligence of a prudent businessperson (§ 43 GmbHG). If the company later incurs a fine, a recall or a contractual penalty, the shareholders can claim precisely this damage from the managing director.

Second, fines for breach of supervisory duties. They are imposed under §§ 9, 130 OWiG on the responsible person. This can also be a person with specialist responsibility, for example in quality management, if the task was expressly delegated.

Anyone who signs should therefore be able to demonstrate at any time which verified evidence they relied on. What matters is not the signature itself, but the documented process behind it.

Because the technical documentation and Declaration of Conformity are generated from the same data as the list of requirements, this step is not a separate major project, but the logical consequence of Steps 3 to 5. It is important to keep the declaration up to date: if a packaging supplier changes, a material changes or the legal situation changes, it is reviewed and, if necessary, reissued.

Part 2: Two Practical Projects

The following two projects come from different industries – and they differ above all in scope. The gift set involved a single sales packaging: a pure cardboard package, albeit with seven components. For the shirt supplier, the entire packaging range had to be recorded – packaging units made from four materials, suppliers in two regions of the world and several sales channels. At the end, we explain what went quickly and what was still open after six weeks.

Example 1: The Gift Set with Household Articles

At first glance, a simple cardboard package – on closer inspection, a packaging unit with seven components. All are made of paper, cardboard or corrugated board. This means it is not composite packaging, the minimum recycled-content requirements under Art. 7 do not play a role, and the starting position for recyclability is favorable.

We nevertheless recorded two questions in the inventory. First: is the box sent directly to end customers or in an additional shipping carton? This may create a second packaging unit in the e-commerce packaging category. Second: are all inserts necessary to protect the product? From February 12, 2028, empty space in sales packaging must be reduced to the minimum necessary for the function (Art. 24). An insert that protects the product can be justified; one that merely creates volume cannot.

Example 2: The Packaged Shirt of a Textile Supplier

The supplier sources its shirts in two ways: some from suppliers in Eastern Europe, i.e. within the EU, and others from Asia. The shirts are delivered folded and individually packaged. What looks like “one bag” is a packaging unit made up of several components and materials.

Because the supplier has polybags and labels printed with its own brands – with different brands depending on the range –, it is a producer under Art. 3(1)(13)(a) PPWR. This applies regardless of who manufactures the bags and in which country.

Together, we reduced the entire range to 10 sales packages, differing essentially in bag size and labeling, and 3 transport packages. That makes 13 packaging units for a much larger product range. These 13 can be created as separate objects in the Product Compliance Management System, linked to the associated articles and documented once each.

What Went Quickly – and What Was Still Open after Six Weeks

For the gift set, the Declaration of Conformity was prepared and signed in less than two weeks. The reason was the supplier: it provided the requested documents in full within a few days. Much of the information was not new – the heavy-metal limit already applied under the old Directive, and corresponding test reports were available. For paper and cardboard packaging, a few documents also cover a large part of the requirements: bill of materials, heavy-metal test report, substance declarations, FSC certificate.

For the textile range, the vast majority had been mapped after six weeks – but it was not complete. Two groups remained open:

• Individual packaging variants with significantly lower sales volumes. They had deliberately been placed at the back of the prioritization – exactly as Step 2 provides.
• Individual transport packaging units for which supplier evidence or Declarations of Conformity were missing. Because these are standard packaging units not manufactured specifically for the client, responsibility for the Declaration of Conformity lies with the packaging supplier. We initially deferred these as well.

This is not a stopgap, but the result of the prioritization from Step 2: first, work is carried out on what quantity and regulatory risk put at the front. After six weeks, the remaining work was therefore exactly where it carried the least weight – with small quantities and with packaging for which the supplier is responsible for the Declaration of Conformity in any event.

Customer statement

“We deliberately tried to begin the work more than six months in advance and standardized and reduced packaging. We also attended numerous webinars and exchanged information with associations. Nevertheless, many practical questions are not clearly answered in the Regulation and the guidelines, and it was not clear to us how to structure the large number of packaging units and link them to the products. trinasco’s packaging inventory and the linking of packaging and products, the preparation of the technical documentation and the Declaration of Conformity via the Product Compliance Management Platform showed us a very efficient way forward.”

Managing Director of a textile company

Part 3: Questions from the Projects

The following nine questions have come up most frequently in these and other projects. Each answer stands on its own – so you can go directly to the question that concerns you. The answers reflect our approach and do not replace a legal review of the individual case.

Is a Shirt’s Polybag Sales Packaging or Transport Packaging?

Legally, it depends on the sales channel. In practice, we recommended that our client treat the polybag consistently as sales packaging.

There are two theoretical cases: if the end user receives the shirt in the bag – for example, through distance selling –, the bag and shirt form a sales unit and the bag is sales packaging under Art. 3(1)(5). If a specialist shop removes the shirt from the bag and sells it without the bag, the bag never reaches the end user; its function was to protect the shirt during handling and transport, so it would then be transport packaging under Art. 3(1)(7).

Three reasons argue against reproducing this distinction:

• In online sales, the bag reaches the end user in every case. There, it is clearly sales packaging.
• The supplier can neither know nor control whether a brick-and-mortar retailer removes the bag before sale.
• Two parallel classifications of the same packaging mean duplicate documentation, duplicate maintenance and a classification question for every delivery.

Classifying it consistently as sales packaging is the stricter option. It safely covers the online channel and avoids distinguishing between cases. The practical consequence: the labeling obligations under Art. 12, which apply from 2028, are planned for all bags – not only those sold online. Because the client’s brand appears on the bag, it is also the producer of this sales packaging, regardless of the channel.

Are Clothes Hangers, Needles and Labels Packaging?

In most cases, yes. Annex I of the PPWR contains an indicative list that becomes very specific for textiles:

• Plastic coverings such as the polybag are packaging.
• Labels attached directly to or affixed to the product – such as hangtags – count as packaging. RFID tags, on the other hand, are expressly excluded.
• Staples are expressly listed as packaging. This is the appropriate point of reference for the small needles and clips used to fix the folding of the shirts.
• Clothes hangers are packaging when sold with a garment – hangers sold without clothing are not.

The sewn-in care label is not packaging: it is permanently attached to the shirt and does not perform a packaging function. We explicitly record such distinctions in the inventory – including cases that ultimately are not packaging. The question will arise again at the next audit, and a documented justification saves a second discussion.

Do You Become a Manufacturer When You Unpack a Delivery?

Yes. Anyone who unpacks packaged products without being an end user is considered a manufacturer under Art. 3(1)(15)(e) PPWR for the purposes of extended producer responsibility – with registration and reporting obligations for this packaging.

This is everyday practice for the shirt supplier: the goods arrive in large cartons, some of which are unpacked, and their contents are forwarded in the company’s own transport packaging. For the inventory, this means that it records not only the packaging purchased, but also the packaging generated by its own process. This is one of the points at which a packaging inventory becomes larger than expected – and at the same time one at which the work quickly pays off, because otherwise an entire packaging type can pass unnoticed through the net.

Who Prepares the Declaration of Conformity for Standard Transport Packaging?

The supplier. Anyone who manufactures packaging is its producer – unless someone has it manufactured under their own name or trademark. A standard shipping carton from a packaging manufacturer’s catalog is not made for a specific client. The packaging manufacturer therefore issues the Declaration of Conformity.

The user’s task is to obtain and check it – not to prepare it themselves. The situation is different for specially designed transport packaging or transport packaging printed with the user’s own brand: there, the user is the producer. This distinction has a direct impact on prioritization, as the portfolio in Step 2 shows.

Are Suppliers from the EU Easier Than Suppliers from Asia?

Legally, yes; in practice, not necessarily.

The legal position is clear: a supplier based in an EU Member State is itself an economic operator within the meaning of the PPWR, is directly subject to the Regulation and is accessible for market surveillance. Although the definition of supplier in Art. 3(1)(16) does not distinguish according to registered office, in practice the information obligation vis-à-vis a supplier outside the EU can only be enforced contractually. In addition, upon importation the purchaser itself becomes the importer (Art. 3(1)(17)).

In practice, our textile project showed the opposite. Some suppliers in Eastern Europe had less prior knowledge and a thinner data base than individual suppliers in Asia. It is therefore not safe to assume automatically that documents will be easier to obtain simply because the supplier is based in the EU. The legal starting position is one thing – how well a supplier knows and has documented its own materials is another.

What Applies to Existing Stock Already in the Warehouse or in Retail?

What matters is not when packaging was manufactured, but when it was first made available on the Union market.

• Placed on the market before August 12, 2026: this stock need not be recalled, repackaged or destroyed. It may be sold off normally.
• Manufactured before the reference date, but not yet placed on the market: the PPWR applies. In its FAQs, however, the Commission has clarified that such stock does not have to be destroyed or relabeled. The traceability information under Art. 15 – unique identification and producer details – may be provided in an accompanying document instead of appearing on the packaging itself.

This relief is narrowly defined. It concerns the traceability information – not the PFAS limits for food-contact packaging and not the Declaration of Conformity. Anyone relying on it should be able to prove when packaging was first made available: invoices, delivery notes and warehouse data are the usual evidence for this.

For enforcement, the Commission instructs market surveillance authorities to initially request the elimination of non-conformity and provide an opportunity to correct it before prohibitions or recalls follow; an enforcement-oriented approach is to be avoided. This is guidance for the authorities, not a postponement of the date of application.

Do the Materials Have to Be Listed in the Declaration of Conformity?

No, the Declaration of Conformity does not require a list of materials. It refers to the packaging unit – not to a packaging type – and must identify that unit unambiguously. Annex VIII requires a unique identifier for the packaging and a description of the object of the declaration that permits traceability. The materials, on the other hand, belong in the technical documentation under Annex VII, which contains designs, manufacturing drawings and the materials of the components.

In practice, many producers nevertheless include a brief material statement in the description because it makes the packaging unit unambiguous; this is not mandatory.

This has practical consequences far beyond the document. The packaged shirt combines four materials in a single sales unit: plastic, cardboard, metal and printing inks. Because the components can be separated by hand, it is not composite packaging – but each material must appear with its weight in the bill of materials because EPR reports are made by material fraction. From 2030, the plastic content also brings the minimum recycled-content requirements under Art. 7 into play.

Anything not properly recorded in the inventory is ultimately missing from the technical documentation and EPR reports – precisely where the company must demonstrate to retailers and authorities that it knows its packaging.

Does the PPWR Also Apply in Switzerland?

No. Switzerland is not part of the EU internal market; the PPWR does not apply there directly. In practice, this relieves companies supplying the DACH region: the Swiss restrictions on heavy metals in packaging and packaging components are identical to those in Regulation (EU) 2025/40 – in the type and scope of the regulated heavy metals, the packaging concerned and the exceptions. Packaging that meets the EU requirements may therefore also be placed on the market in Switzerland; the test reports can continue to be used.

Waste management and take-back, by contrast, are governed by Swiss law and must be considered separately.

How Much Effort Is Involved Within the Company Itself?

This depends above all on two things: how well the company’s own range is prepared and how professionally the suppliers cooperate. Both explain why our two projects progressed comparatively quickly.

For the shirt supplier, the preliminary work was decisive. The person responsible had begun at least six months earlier to standardize packaging and reduce additional materials. Without this preliminary work, 13 packaging units would have become significantly more – and six weeks would have become a longer project.

For the gift set, it was the supplier: an established cardboard manufacturer with much of the evidence already available because the 100 mg/kg heavy-metal limit had already applied under Directive 94/62/EC. Anyone who has neither of these prerequisites should plan for a longer lead time. The bottleneck is then almost always the supply chain, not the company itself.

Conclusion: Complex and Demanding – but Solvable

The PPWR is complex, especially for large ranges – but it can be complied with using the right steps and the right tools. The time-critical factor is generally not within the company itself, but with the suppliers and their upstream suppliers. Packaging requirements have never previously been in the spotlight to the same extent as product requirements. The necessary evidence is therefore often not available from packaging producers – it first has to be created, checked or determined in a laboratory. For products sourced fully packaged, every inquiry passes through at least two tiers of the supply chain.

Four prerequisites have proved decisive in our projects:

1. Start without delay. The obligations already exist and have been mandatory since August 12, 2026. Authorities are still relying on warnings and opportunities to correct rather than sanctions – this phase should be used.
2. A clear approach. Six steps turn an unwieldy body of rules into a manageable project.
3. A suitable tool. Manage packaging as separate objects, link it to products, and generate technical documentation and the Declaration of Conformity from it.
4. Suppliers who cooperate. The PPWR obliges them to do so – the key is ensuring that the information also reaches you from upstream suppliers.

trinasco GmbH supports you – from the packaging inventory to the signed Declaration of Conformity.

Contact us

trinasco GmbH | produkt-compliance.de
Telephone: +49 (0) 40 46 86 80 00
Email: anfrage@trinasco.com

This article reflects the experience of trinasco GmbH and does not constitute legal advice. Legal basis: Regulation (EU) 2025/40. Status: October 2026.

trinasco GmbH

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20457 Hamburg
040 46 86 80 00

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