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Regulation · 27 September 2026

PPWR: What Swiss SMEs need to do when exporting to the EU

The EU Packaging Regulation has applied since 12.08.2026. Who is affected and how to check it.

Since 12 August 2026, the EU Packaging and Packaging Waste Regulation (PPWR) has applied directly in all EU member states. It affects every Swiss company whose packaged goods end up in the EU, whether directly or via a customer. The deciding question is one that many underestimate: is your product sold under your own brand or under your customer's brand?

Status at a glance

Status: in force and applicable since 12 August 2026: Regulation (EU) 2025/40
  • since 12.08.2026limit values for PFAS in food packaging and for heavy metals; technical documentation and EU declaration of conformity
  • from 12.08.2028 (earliest)harmonised labelling of material composition
  • from 01.01.2030 (earliest)recyclability (levels A to C), minimum recycled content for plastics, empty space of no more than 50%
  • from 01.01.2038only recyclability at level A or B

"Earliest": several deadlines are pushed back for as long as the European Commission has not adopted the necessary implementing rules. The labelling requirements were due on 12 August 2026 and are still missing.

As of: 27 September 2026

Timeline for the PPWR: applies since 12.08.2026 (PFAS, heavy metals, documentation); new Swiss Packaging Ordinance from 01.01.2027; harmonised labelling from 12.08.2028 at the earliest; recyclability, recycled content and empty space from 01.01.2030 at the earliest; from 01.01.2038 only recycling levels A or B.

What it is about

The PPWR replaces the existing EU Packaging Directive from 1994. Unlike a directive, a regulation does not first have to be transposed into national law. It applies in the same way in all 27 member states. It covers all packaging: sales, outer and transport packaging, as well as shipping boxes used in online retail.

The aim is less packaging that is easier to recycle. To that end, the regulation addresses design (recyclability, recycled content, no unnecessary empty space), substances (PFAS, heavy metals) and information (labelling, documentation).

Who is affected and in which role

For the PPWR, what counts is where the packaging is placed on the market, not where the company is based. Your obligations as a Swiss company depend on your role:

  • Goods under your own brand: You are then the "manufacturer" under the PPWR, even if you are based in Switzerland (Art. 3 No. 13). You must carry out the conformity assessment, prepare the technical documentation and issue the EU declaration of conformity. Your EU buyer is the importer and checks before the packaging is placed on the market whether these documents are in place (Art. 18).
  • Goods under your customer's brand, or components that your customer processes further: then the manufacturer obligations usually lie with your customer. To meet them, though, the customer needs your data and evidence.

Important: you can appoint an authorised representative in the EU. However, you cannot expressly delegate the conformity assessment and the technical documentation to that representative (Art. 17). This work stays with the manufacturer.

In addition comes extended producer responsibility: the obligation to register in every target country and to pay fees for collection and recycling. As a rule it falls on whoever first makes the packaging available in the relevant EU member state, usually your importer. If you sell directly to end customers in the EU, for example via an online shop, it may apply to you directly.

Decision chart for the PPWR: for goods under your own brand, the Swiss company is the manufacturer and prepares the conformity assessment, technical documentation and EU declaration of conformity; the EU buyer is the importer. For goods under the customer's brand, the customer is usually the manufacturer, and the Swiss company supplies packaging data and evidence.

The challenge for SMEs

The PPWR requires evidence on things that many SMEs do not control themselves: which materials make up the carton, the film, the label? Does the coating contain PFAS? What is the recycled content? This information sits with the packaging supplier, often even with its own upstream suppliers.

At the same time, the first questionnaires are arriving from EU customers who need to secure their own conformity assessment. Authorities can also request documents. An authorised representative, for example, must produce them within ten days (Art. 17). Anyone who only starts looking then has a problem.

This matches our 2026 study: 57% of respondents name a lack of supply chain transparency as the biggest hurdle in ESG management. (n = 74, not representative; 30% of the responses from companies with more than 5,000 employees.)

Data flow under the PPWR: the packaging supplier provides evidence on materials, PFAS, heavy metals and recycled content to the Swiss SME; the SME prepares a data sheet or the technical documentation for the EU customer or importer.

The opportunity

EU customers will choose their suppliers based on who delivers the required packaging data completely and without follow-up questions. Those who can do this stay in the range. Those who cannot become a risk for the customer. Many deadlines only fall in 2028 and 2030, but new packaging needs lead time, and contracts are being negotiated today.

Looking across the border: the new Swiss Packaging Ordinance

Switzerland is following suit too: on 24 June 2026 the Federal Council adopted a new Packaging Ordinance, which applies from 1 January 2027; individual provisions take effect in stages up to 2032. It covers all packaging for the first time and replaces the 2000 ordinance on beverage packaging. It sets requirements for placing packaging on the market, regulates take-back and disposal, and sets recovery targets: plastic packaging is to be recycled to at least 55 per cent, and beverage cartons to at least 70 per cent. According to the Federal Office for the Environment (FOEN), this brings Switzerland closer to the EU. It is not a takeover of the PPWR. Anyone supplying both markets should keep both sets of requirements in view.

PPWR and the Digital Product Passport: related, but not the same

The PPWR and the Digital Product Passport are often mentioned in the same breath. But they are two separate regulations: the PPWR governs packaging, while the product passport stems from the Ecodesign Regulation (ESPR) and concerns the product itself. There is currently no obligation for a product passport for packaging.

The overlap lies in the data: materials, weight, recyclability, recycled content, substances. And in the technology: a clear identifier and a data carrier such as a QR code. If you record your packaging data in a structured way for each item today, you can answer today's PPWR requests and have a basis for tomorrow's product passport. More on this in our article on the Digital Product Passport (in preparation).

Prepared in five steps

Five-step model: clarify role, record packaging, obtain evidence, document, track deadlines.
  1. Clarify your role, per market and product: Your own brand or your customer's brand? Delivery to an importer or directly to end customers?
  2. Record packaging: Which items go to the EU, and which packaging parts do they consist of (material, weight)?
  3. Obtain evidence: Ask the packaging supplier for information on PFAS, heavy metals and recycled content (bundled, not per customer request).
  4. Document and provide: As manufacturer, prepare the technical documentation and declaration of conformity; as supplier, provide a packaging data sheet for your customers.
  5. Track deadlines: Plan labelling (from 2028) and recyclability (from 2030) early for new packaging.

Checklist to get started

  • List of the items delivered to the EU
  • Role clarified for each item (own brand or customer's brand)
  • Packaging parts recorded with material and weight
  • PFAS evidence available for packaging with food contact
  • Packaging suppliers asked about recycled content and recyclability
  • Responsibility set internally and documents findable within ten days

How ZEROvia helps

In preparation: the PPWR data sheet (expected 2027). Record packaging data for each item, including from an ERP export. Request missing evidence from the packaging supplier in bundles. Share the versioned data sheet with your EU customers and update it automatically when things change. A role check shows which obligations apply to you.

Insight into development: the PPWR data sheet in the ZEROvia request hub, with obligations check, deadlines and packaging data for each item (prototype with sample data).
Insight into development: the PPWR data sheet in the ZEROvia request hub (prototype with sample data)

Available today for your other sustainability data: from the baseline assessment to the VSME report, AI-supported answers to customer requests based on your own data, and document templates for missing policies.

Already have PPWR requests from EU customers on your desk? Get in touch.

Next steps

Download PPWR factsheet (PDF)

PDF, 1 page · all the facts at a glance

Sources

This article provides orientation and does not replace legal advice. Last updated: 27 September 2026.

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