As the European Union moves forward with the new Packaging and Packaging Waste Regulation (PPWR), the rules of the game are changing significantly for companies operating in – or planning to enter – the EU market.
To better understand the real implications of this regulatory shift, especially for non-EU companies, we spoke with Roberth Jonsson, Chief Compliance Officer at 24hour-AR, a Netherlands-based compliance agency specialized in regulatory compliance and market access support. In this interview, Jonsson shares practical insights on what companies should really expect—from documentation and costs to supply chain challenges—and how to approach compliance strategically rather than reactively.
Understanding PPWR: What Changes for Non-EU Packaging Companies
For an international company approaching the EU market, what is the most common misunderstanding about the PPWR?
“The most common misunderstanding is failing to realize how fundamentally the role of packaging has changed. In the past, under the previous directive, packaging was primarily treated as waste, something to be managed at the end of its life. With the PPWR, however, packaging is also treated as a product, which means it must comply with requirements very similar to those applied to goods themselves. This shift forces companies to rethink their approach entirely. It is no longer enough to consider recycling or disposal: packaging now needs to meet technical, legal and chemical compliance standards from the very beginning.”
What are the key practical steps a non-EU company should take to assess PPWR compliance?
“When approaching the PPWR, companies need to understand that compliance operates on two parallel levels. On one side, there is Extended Producer Responsibility (EPR), which requires companies to ensure proper registration in each country where they place packaging on the market. In most cases, this also means appointing an authorized representative locally to manage these obligations.
On the other side, there is the product-related dimension of packaging compliance. Here, companies are expected to prepare detailed technical documentation, issue a declaration of conformity, and, if they are based outside the EU, appoint a responsible person within the Union. In addition, they must verify that their packaging complies with chemical restrictions, often through audits and testing.”
What are the main economic and organizational impacts of the PPWR?
“The PPWR inevitably raises the threshold for entering the European market. Companies are now facing not only direct costs, such as registration fees, legal representation, and testing, but also a range of indirect costs that are often underestimated.
A significant part of the effort lies in building and maintaining technical documentation, auditing the supply chain, and ensuring that suppliers – often located outside the EU – understand and comply with European requirements. This adds both complexity and time pressure, especially considering the regulatory deadlines. In many cases, companies find themselves having to educate their own suppliers, which further slows down the process and increases internal workload”.
Why is defining the “producer” under EPR so complex?
“The complexity stems from the fact that the definition of “producer” changes depending on the regulatory context. Under product legislation, the manufacturer is clearly identified and remains consistent across all EU member states. However, under EPR rules, the situation is different.
In this case, the “producer” is defined as the entity that places packaging on the market for the first time within a specific country. This means that the same company may be considered a producer in one country but not in another, depending on how it distributes its products. As a result, companies often need to register in multiple national systems, and their legal responsibilities can shift across borders”.
PPWR Compliance Strategy: Costs, Risks and Market Entry Approach
Who will face the biggest challenges: new entrants or established companies?
“Both types of companies face challenges, but for different reasons. Established companies often struggle with the sheer complexity of their operations. They typically manage large portfolios with multiple packaging formats and a wide network of suppliers, which makes the compliance assessment process significantly more demanding.
At the same time, non-EU companies, even those with simpler product ranges, face structural challenges related to entering the European regulatory framework. They need to appoint representatives, understand unfamiliar legal requirements, and build compliance processes from scratch. In practice, the level of difficulty depends more on the company’s structure and preparedness than on its size or location.”
What is your main advice for non-EU companies entering Europe?
“The most important advice is to prioritize product compliance first. Before entering the market, companies need to ensure that all documentation is in place, that packaging meets all regulatory requirements, and that declarations of conformity are properly prepared.
EPR obligations, while essential, follow a different timeline. Companies only need to register in the countries where they actually sell their products, which allows for a more gradual and manageable approach. For example, a company starting in Spain does not need to immediately register across all EU markets but can expand its compliance activities as its commercial presence grows”.
Can you share a practical example?
“Let’s take a Polish company producing socks and packaging them in plastic bags. If these products are sold through a German distributor, then the distributor becomes the producer for EPR purposes in Germany, as it is the entity placing the product on that market for the first time.
However, if the same Polish company sells directly to Italian consumers through an online channel, the situation changes completely. In that case, the company itself becomes the producer in Italy and must appoint a local representative, register for EPR, and ensure full compliance of its packaging, including documentation and chemical requirements. This example clearly illustrates how responsibilities can shift depending on the sales model”.
How does 24hour-AR support companies in this process?
“24hour-AR positions itself as a partner in compliance and a facilitator of market access. The company supports non-EU businesses by acting as an authorized representative within the EU and by helping them prepare the necessary technical documentation and declarations of conformity.
When it comes to EPR, the company works through a network of specialized partners, ensuring that clients can access the right expertise in each market. The goal is not simply to provide a service, but to guide companies through the entire compliance journey, helping them navigate complexity and reduce risk”.
Are companies becoming more aware of compliance?
“There is definitely a shift in mindset. While opportunistic approaches still exist, more companies are starting to see compliance not as a bureaucratic burden, but as a strategic necessity.
Increased market surveillance and the risk of costly product recalls are pushing businesses to take compliance seriously. In this context, packaging companies should not see compliance as mere expense but as an investment: it’s not just about entering the market but to ensure we stay in the market, ensuring long-term stability and the ability to remain competitive within it”.
Is there a strategic approach companies should adopt to navigate compliance more effectively over time?
“We believe that successful market entry is not just about meeting initial requirements, but about building a long-term compliance strategy. This is what we call “Market Access Thinking”, and it is structured around three key phases.
The first phase is access, which focuses on entering the market by ensuring that both products and packaging are fully compliant with applicable regulations. This is the foundation, and without it, market entry is simply not possible.
The second phase is continuity. Compliance is not a one-time effort, as legislation continues to evolve. Companies need to monitor regulatory changes and adapt their products, packaging, and documentation accordingly to remain compliant over time.
The third phase is protection and support. Even with the right processes in place, issues can arise, such as market surveillance actions or product recalls. Being prepared to handle these situations effectively is essential to protect both the business and its reputation.
This three-step approach is central to how we support our clients. We do not only help them enter the market, but we act as a long-term compliance partner to ensure they can operate safely and sustainably within it”.
The PPWR represents a significant turning point for the packaging industry, redefining how packaging is regulated and managed across the European Union.
One thing, seems clear: in an increasingly stringent regulatory environment, those who view compliance as a strategic investment rather than a last-minute obligation will come out on top in the long run. For international companies, the path may seem complex, but it is far from inaccessible. The key lies in preparation, awareness, and a proactive approach to compliance.
