PPWR Producers Requirements in 3 Steps

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PPWR Producers

Companies that first introduce packaging or packaged products in an EU member state are generally considered to be producers under the Packaging and Packaging Waste Regulation (PPWR) 2025/40. This can also be the case for companies selling directly to end users in other EU member states.

The entity defined as a producer is generally responsible for extended producer responsibility tasks. This includes reporting packaging materials and volumes, and paying corresponding fees.

This guide explains how you can determine which company is the PPWR producer. I also share several practical examples of supply chains involving both EU and non-EU-based companies.

  • Manufacturers, importers, and distributors can be defined as producers
  • The producer is often the first entity that introduces packaging in a particular EU member state
  • The producer must comply with EPR obligations

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How to Comply with the EU Replaceable Battery Rules

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Article 11 of the Batteries Regulation (EU) 2023/1542 introduces new requirements that will make it mandatory to sell many electronic devices with batteries that can be removed and replaced by the end-user.

This means that many brands must redesign their hardware to incorporate batteries and battery compartments that make this possible, while also complying with requirements concerning spare part availability.

This guide breaks down key requirements under Article 11 of the Batteries Regulation (EU) 2023/1542. I also explain which devices are exempt (to some extent) and why.

  • The new rules under Article 11 apply from 18 February 2027
  • End-user replaceable batteries will be required for many electronic devices
  • Many brands will be required to redesign their hardware before 18 February 2027
  • Some devices subject to ecodesign requirements are exempt (to a certain extent)

Note: This is still an evolving area of product compliance. The EU received inputs from the industry earlier this year, and it is possible that exemptions will be extended to additional products.

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USB Type-C Requirements in the European Union

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Certain electronic devices can only be sold in the European Union if they are USB-Type C compatible. Further, compliance with EN IEC 62680-1-3:2022 and EN IEC 62680-1-2:2022 is required.

This guide provides a summary of the USB Type-C requirements outlined in Annex Ia of the Radio Equipment Directive 2014/53/EU.

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Undergarment Regulations in the European Union

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EU undergaments

Undergarments sold in the European Union are subject to various chemical restrictions and labelling requirements. Some of these requirements apply due to the fact that undergarments are in direct contact with the skin, while others are relevant to specific types of undergarments, such as menstrual underwear.

Related products

This guide is relevant to the following types of products:

  • Women’s underwear
  • Men’s underwear
  • Children’s underwear and socks
  • Socks
  • Bras
  • Corsets
  • Period underwear
  • Hosiery and stockings
  • Tops

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RoHS Product Lab Testing: A Complete Guide

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The Restriction of Hazardous Substances (RoHS) Directive restricts chemicals and heavy metals in electronic products imported or manufactured for sales in the European Union. In some cases, you can obtain RoHS test reports from your component suppliers.

That said, not all suppliers can provide RoHS test reports that can be traced and validated for a particular component. In such cases, RoHS testing is often necessary.
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How much does CE marking cost?

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You do not need to pay any license or other fees to use the CE mark. That said, the purpose of the CE marking is to demonstrate that your product complies with all applicable EU regulations and directives that require it.

Delivering a product to the point where the CE mark can be affixed requires access to standards, design adjustments, documentation, labelling, and testing. These are also the things that can cost money.

This guide serves as a breakdown of the various costs associated with the CE marking process.
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Who is Responsible for EU PPWR Compliance?

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The Packaging and Packaging Waste Regulation (PPWR) 2025/40 sets requirements applicable only to certain types of entities. In plain language, this means that what you must do to comply with the PPWR differs depending on whether your company is defined as a:

a. Manufacturer
b. Importer
c. Supplier
d. Distributor

It is therefore critical that you understand their respective definitions and can accurately find your place in the PPWR supply chain.

Further, companies can also be defined as producers (in addition to their primary definition), which results in additional extended producer responsibility (EPR) obligations applying.

Why should I read this guide?

Read this guide if you want to understand whether you are defined as a producer, manufacturer, importer, distributor, supplier, or other entity. You can read this guide to learn more about PPWR requirements:

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CE Marking and Product Lab Testing: A Practical Guide

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Product lab testing is generally required for electronics, batteries, toys, PPE, machinery, and other products which require CE marking. This guide serves as an introduction to testing requirements, processes, and costs relevant to CE-marked products.

  • You can only CE mark products that comply with harmonised standards
  • Testing is necessary to validate compliance with said harmonised standards
  • CE marking testing often starts from around 1000 USD or EUR

Note: Are you trying to determine if an existing product which requires CE marking has valid test reports? Then I suggest that you read this guide as well.

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Children’s Clothing Regulations & Standards in the EU

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Children’s clothing imported or manufactured for sale in the EU is subject to strict safety, chemical, labelling, and documentation requirements. In this guide, I explain how the GPSR, EN standards, REACH and other compliance requirements relate to children’s clothing.

  • Children’s clothing must be safe by design
  • Chemical restrictions apply to fabrics, zippers, and other materials
  • Labelling requirements apply to children’s clothing

Product examples

  • Baby rompers
  • Bodysuits
  • Sleepsuits
  • Swaddles and wearable blankets
  • Children’s swimwear
  • Children’s t-shirts
  • Children’s hats and caps
  • Children’s pants
  • Children’s outerwear

Note: The video was recorded a few years ago. The written article has since been updated and is more relevant to current requirements.

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EU Packaging Regulation (PPWR) Timeline: 2026 to 2040

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The Packaging and Packaging Waste Regulation (PPWR) 2025/40 is applicable from 12 August 2026. That said, the PPWR contains many requirements concerning labelling, documentation, EPR, and other aspects that only start to apply years later.

This guide serves as a timeline for PPWR requirements and their respective dates.

Methodology

Step 1: I mapped out all the articles mentioning a date*

Step 2: I determined if the requirement is relevant to either:

  • Manufacturers, importers, distributors, and other economic operators, or
  • EU Commission or Member States

Step 3: The respective PPWR requirements tied to a particular date were added to one of the two tables below

*Note that the table contains the dates identified during this stage. I cannot guarantee that I identified every single article or requirement tied to a specific date.

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