Current as of 13 August 2026
A beverage can is no longer just packaging that needs to look good, protect the drink and reach the customer safely. It is also part of a system in which it must be clear what the packaging is made of, who is responsible for it, how it can be traced and what happens to it after use.
This is precisely what the European PPWR, the Packaging and Packaging Waste Regulation, addresses. It entered into force on 11 February 2025 and, following an 18-month transition period, has applied generally since 12 August 2026. Not all requirements apply at once, however. Further rules will be phased in during 2028, 2030 and 2035.
PPWR is about more than the can
For a canned beverage, the entire packaging system must be considered:
- the can and its lid,
- the paper or cardboard tray,
- shrink film or multipack,
- pallet wrap, straps, layer pads and the pallet.
The can is generally sales packaging – the packaging in which the customer buys the drink. A tray or multipack may be grouped packaging, because it combines several cans into one unit. Pallet wrap and securing straps will usually be considered transport packaging.
Why does this classification matter? Different requirements may apply to different types of packaging. A general declaration from the can manufacturer is therefore not enough to cover the complete packaging system. The material, weight, function and supplier of the tray, film and other packaging components must also be known.
What does PPWR introduce?
The aim of the Regulation is to ensure that packaging placed on the European market becomes safe, material-efficient and genuinely recyclable. In practice, PPWR introduces or clarifies requirements concerning:
- restrictions on certain unwanted substances,
- recyclability,
- the reduction of unnecessary packaging weight and empty space,
- more harmonised labelling of material composition and waste sorting,
- technical documentation and an EU declaration of conformity,
- better traceability,
- reuse and responsibility for packaging waste.
Aluminium beverage cans are in a strong starting position: aluminium has an established recycling stream and retains a high value as a secondary raw material. However, the complete packaging is assessed, including the lid, coatings, printing inks and combinations with other materials.
Who is the “manufacturer” when somebody else fills the beverage?
This is where misunderstandings most often arise. Under PPWR, the manufacturer does not necessarily mean the factory that physically produced the empty can or the company that filled the beverage.
If a company has a beverage manufactured under its own brand and determines the packaging specification, that company will generally be the manufacturer for PPWR purposes – in other words, the brand owner. This remains the case even when physical production and filling are handled by a contract manufacturer such as Bofillex.
A simple example:
Company ABC orders a beverage from Bofillex in a can carrying the ABC logo. ABC approves the design, selects the packaging specification and sells the product under its own brand. Company ABC will generally be the manufacturer under PPWR – not automatically Bofillex.
If Bofillex manufactured and placed a beverage on the market under its own brand, Bofillex would be the manufacturer. An importer or distributor may also become the manufacturer if it places the product on the market under its own name or trademark, or modifies the packaging in a way that could affect compliance.
The decisive question is therefore not only “Who physically produced the beverage?”, but above all “Under whose brand was it produced and who controls the packaging specification?”
What is a micro-enterprise, and why does it matter?
PPWR contains a special rule for micro-enterprises. This does not automatically mean every start-up or small business. Under the EU definition, a micro-enterprise must:
- employ fewer than 10 people, and
- have an annual turnover or annual balance sheet total not exceeding EUR 2 million.
Figures from partner or linked enterprises may also have to be included in this assessment. Setting up a small subsidiary therefore does not automatically make it an independent micro-enterprise.
A micro-enterprise may benefit from an exception to the usual manufacturer rule. If it has packaging or a packaged product manufactured under its own name or trademark and the packaging supplier is located in the same Member State, that supplier may be considered the manufacturer under PPWR.
In practice:
- A Czech micro-enterprise and a Czech packaging supplier may be able to use this special rule if all conditions are met.
- If a German micro-enterprise orders production from a Czech supplier, the “same Member State” condition is not met.
- The exception does not automatically apply to every small brand. The specific contractual and supply arrangement must be assessed.
A micro-enterprise is therefore not generally exempt from PPWR. The special rule may merely change who is considered the manufacturer in a particular situation.
Manufacturer and producer are not the same role
PPWR also uses the term producer. The two roles may overlap, but they do not mean the same thing:
- The manufacturer is primarily responsible for packaging compliance: its characteristics, technical documentation, identification and conformity with the applicable requirements.
- The producer is mainly connected with extended producer responsibility, or EPR. It is generally the economic operator that makes packaging or a packaged product available for the first time in a particular Member State.
One company may perform both roles, but this is not always the case. In cross-border sales, the EPR registration, reporting and financing obligations therefore need to be assessed separately for every target market.
What is the manufacturer responsible for in practice?
The manufacturer must be able to demonstrate that the packaging complies with the requirements applicable to it. This primarily involves:
- collecting information from suppliers of cans, lids, trays, films and other materials,
- assessing the conformity of the complete packaging system,
- preparing the technical documentation and EU declaration of conformity,
- ensuring identification by means of a type, batch, serial number or another traceable element,
- providing the manufacturer’s name or trademark, postal address and available electronic contact details,
- taking appropriate action if the packaging is found not to comply.
Under the conditions set by the Regulation, manufacturer information may also be provided through a QR code or another data carrier. A production code printed on a can may support traceability, but it must genuinely link back to the relevant packaging specification and documentation.
What applies now, and what comes later?
PPWR is being introduced in phases:
- From 12 August 2026, the Regulation applies generally. This includes limits on PFAS in food-contact packaging.
- From 2028, harmonised European labelling of material composition and waste sorting is expected to be introduced progressively.
- From 2030, further requirements will apply to recyclability, unnecessary packaging, recycled content in certain plastic packaging and reuse.
- From 2035, the assessment will also consider whether packaging is actually recycled at scale.
The transition period does not mean that companies can ignore PPWR for several more years. It means that individual obligations apply from different dates and need to be prepared for progressively.
Bofillex is ready
Successful PPWR implementation depends above all on effective cooperation. Brand owners, contract fillers and packaging suppliers need to understand what information they must provide and where each responsibility sits.
Bofillex is prepared for the new requirements. We maintain traceability of the packaging materials used, collect relevant documentation from our suppliers and adapt our processes so that we can provide customers with the information required for their documentation and conformity assessment.
We recommend agreeing the allocation of roles at the project preparation stage, together with the packaging design, target markets and technical packaging specification. This helps prevent later artwork changes, missing documents and uncertainty about responsibility.
PPWR is more than another abbreviation from European legislation. It represents a new way of thinking about packaging: less waste, better traceability and clearer responsibility throughout the supply chain.
This article provides general information and does not replace a legal assessment of a specific product, supply model or target market.
