Packaging supports every stage of the beverage supply chain. Bottles, closures and cartons protect wine, beer and spirits. Pallets and protective materials help beverages and ingredients move between producers, warehouses and destination markets. For bulk wine, flexitanks provide another packaging format to consider.

The EU Packaging and Packaging Waste Regulation, known as PPWR, brings these different formats into a common regulatory framework. Its general application date was 12 August 2026, with requirements introduced in phases.

For producers, importers and distributors, understanding the regulation can support informed packaging decisions and clear supplier conversations. A useful starting point is identifying which packaging is used, which requirements apply today and which business holds each responsibility.

What is the PPWR regulation?

PPWR is Regulation (EU) 2025/40. It establishes harmonised EU rules for packaging and packaging waste, covering design, composition, recyclability, reuse and labelling. It applies to packaging placed on the EU market, whether manufactured within the EU or imported.

The scope includes glass, plastic, paper, cardboard, metals, wood and composite materials. For beverage businesses, this means considering both the packaging around individual beverages and the packaging supporting transport. Requirements vary according to the material, format and intended use.

The European Commission’s packaging waste overview explains the framework and its objectives. It reports that EU packaging waste reached 186.5 kilograms per person in 2022. PPWR aims to support more efficient material use and a circular economy. 

Which requirements apply now, and which come later?

PPWR entered into force on 11 February 2025 and generally began applying on 12 August 2026. Current priorities include demonstrating compliance with applicable requirements, identifying packaging and its manufacturer, and meeting PFAS limits for food-contact packaging. Businesses can start by confirming that relevant supplier documentation is available and corresponds to the packaging used.

Later measures follow separate timelines. Harmonised sorting labels are scheduled from 12 August 2028, or later where linked implementing legislation determines the deadline. Recyclability, recycled plastic content and several reuse measures have milestones from 2030, subject to their detailed conditions and exemptions.

A phased approach can help beverage businesses align current documentation with longer-term packaging planning.

Who is responsible for PPWR compliance?

Responsibilities depend on the business’s role. Manufacturers assess packaging conformity, prepare technical documentation and issue an EU Declaration of Conformity. Suppliers provide information needed to support that assessment.

EU importers have their own verification and document obligations before placing packaging on the market. The customs Importer of Record can be a useful starting point for discussions, but PPWR responsibility follows the regulation’s definitions. Purchasing packaging does not, by itself, describe every obligation.

The PPWR legal text sets out these roles. Beverage businesses can map responsibilities with suppliers and advisers, including any separate extended producer responsibility obligations.

For example, an EU wine importer can confirm who supplies the bottles, closures and transport packaging. Each relevant supplier can then provide the documentation associated with its packaging.

What packaging documentation should beverage businesses request?

A Declaration of Conformity, often shortened to DoC, records conformity with applicable requirements. Supporting packaging data can help businesses understand what the declaration covers and respond to customer or authority requests.

A practical supplier review can include:

• The relevant EU Declaration of Conformity and packaging identification.
• Material composition and specifications for each packaging format.
• Supporting evidence for applicable substance limits, including PFAS where relevant.
• Confirmation of who holds technical documentation and how it can be obtained.
• A process for communicating changes to packaging materials or design.

Records can be organised by supplier, packaging format and version. This can make records easier to retrieve.

For businesses sourcing bottles, cans or closures, beverage packaging logistics planning can provide a useful opportunity to coordinate supplier information alongside transport arrangements.

How do PFAS requirements apply to beverage packaging?

PFAS, or per- and polyfluoroalkyl substances, are chemicals used in some materials for properties such as water or grease resistance. PPWR sets concentration limits for PFAS in food-contact packaging placed on the EU market from 12 August 2026.

Beverage bottles, food-contact closures, bag-in-box inner bags and flexitanks are relevant formats to assess. Suppliers can confirm the applicable classification and provide supporting evidence for the particular packaging supplied.

Outer cartons, pallets and transport stretch film generally serve a different function from food-contact packaging. Their intended use matters when assessing PFAS scope. These materials remain relevant to wider PPWR requirements.

For bulk wine, flexitank transport discussions can include documentation for the specific tank supplied. Hillebrand Gori can make relevant compliance documentation available for flexitanks supplied as meeting the applicable PFAS limits.

How can beverage businesses plan their next steps?

A packaging review can connect purchasing, compliance and logistics teams. Starting with the formats currently used gives each team a shared reference for supplier discussions.

For bottled wine, that review might cover the bottle, closure, label, carton, pallet and protective materials. For bulk wine, it might cover the flexitank and associated transport packaging. Alcoholic and non-alcoholic beverage ranges can be reviewed together where packaging arrangements overlap.

The next step is matching available documentation to each format and identifying the relevant economic operator. Businesses can also incorporate later PPWR milestones into packaging development discussions.

National competent authorities can clarify local enforcement and administrative arrangements. Regular supplier conversations can help keep packaging records current as implementation guidance develops.

How can Hillebrand Gori help?

Hillebrand Gori supports producers, importers and distributors with beverage transport and packaging solutions. For packaging supplied by Hillebrand Gori, relevant Declarations of Conformity, material composition data and supporting documentation can be provided where applicable.

Local teams can help coordinate packaging information alongside transport planning and share relevant implementation updates. This support can make logistics easier while customers manage their own regulatory responsibilities.

Beverage businesses can contact a local Hillebrand Gori specialist to discuss packaging documentation and upcoming transport requirements.