PPWR & packaging obligations: What Swiss exporters to the EU need to know now

The new EU Packaging Regulation (PPWR, Regulation (EU) 2025/40) will bring uniform rules for packaging in Europe from August 2026. The aim is to reduce packaging waste and strengthen the circular economy.

This has far-reaching consequences for Swiss companies - especially when products are exported to the EU.

Who is affected?

Many companies assume that only packaging manufacturers are affected.

That is not correct.

The PPWR defines the so-called „producer“ (distributor) as:

- the person who makes packaging or packaged products available for the first time in an EU Member State 

The decisive factor here is: In which country does the packaging become waste?

According to the principle of „domestic precedence“, the company at the beginning of the supply chain in the respective country is always responsible 

Typical case: Export from Switzerland

A Swiss company:

• packaged products in Switzerland
• delivers these to Germany, France or Italy

Result:
The company is considered a „producer“ in these countries“

What obligations arise?

The obligations under the extended producer responsibility (EPR) include:

• Registration with national authorities/systems
• Notification of packaging quantities
• Payment of license fees
• Compliance with recycling and design requirements

These obligations already exist today and will be further standardized by the PPWR.

Authorized Representative: When is it necessary?

Companies without an establishment in an EU country often have to „Authorized Representative“ in the respective country. Among other things, this person takes over

• Registration and communication with authorities
• Reporting and deadline management
• Coordination with take-back systems

Why many companies are not yet compliant

In practice:

• Packaging is often seen as a „by-product“
• Responsibilities are unclear
• National differences make the overview difficult

The following clearly applies: The responsibility lies with the distributor - not the packaging supplier

Conclusion

For Swiss companies with EU exports, the PPWR is not a future issue, but is already relevant today. Anyone supplying products to the EU should check:

• In which countries packaging is placed on the market
• Whether registrations exist
• Whether an Authorized Representative is required

Further sources

• EU Commission (PPWR Overview):
  https://echa.europa.eu/packaging-and-packaging-waste-regulation
• Regulation (EU) 2025/40 (original text):
  https://eur-lex.europa.eu
• Producer definition (practice explained):
  https://www.verpackungsregister.org/en/ppwr/producer-definition

Note: This article is intended as an initial guide and does not replace legal advice.