PPWR and ROP
Extended Producer Responsibility:
differences and similarities

The PPWR and the ROP are two related but distinct mechanisms under packaging law. PPWR, or Regulation (EU) 2025/40, sets out EU requirements concerning the design, composition, recyclability, labelling, reuse and reduction of packaging waste. The EPR, or Extended Producer Responsibility, on the other hand, specifies who is responsible for financing and organising the management of packaging waste after it has been used.

To put it simply: The PPWR specifies what the packaging should be like, whilst the ROP specifies who is responsible for paying for its subsequent management as waste.

The European Commission states that the PPWR came into force on 11 February 2025, is generally to apply from 12 August 2026, and covers all packaging and packaging waste, regardless of material or origin. The Regulation sets out requirements regarding the production, composition and nature of packaging, specifying whether it must be reusable or recoverable.

The ROP does not disappear following the PPWR. On the contrary, the PPWR reinforces the importance of the ROP, as it requires national producer responsibility schemes to be linked to the actual costs of waste management, data, reporting and packaging characteristics.

What is PPWR?

The PPWR, or Packaging and Packaging Waste Regulation, is an EU regulation concerning packaging and packaging waste. As a regulation, it is directly applicable in EU Member States, although some aspects of its practical application require further clarification in national legislation.

The PPWR includes, amongst other things:

– the recyclability of packaging,
– designing packaging in accordance with the principles of Design for Recycling,
– the minimum recycled content in plastic packaging,
– reducing excessive packaging,
– limits on empty space in e-commerce and transport packaging,
– prohibited packaging formats,
– labelling and sorting pictograms,
– reusable packaging and reuse schemes,
– the obligations of manufacturers, importers and distributors,
– reporting and packaging data.

The European Commission points out that one of the objectives of the PPWR is to ensure that all packaging on the EU market is recyclable in an economically viable manner by 2030.

From a business owner’s perspective, the PPWR is, first and foremost, a regulation governing products and packaging. It affects the packaging design, materials, labelling, documentation, suppliers and the ability to place packaging on the market.

What is ROP?

EPR, or Extended Producer Responsibility, is a mechanism whereby a producer or other entity placing packaged products on the market bears financial or organisational responsibility for the post-use stage of the product — that is, for the collection, transport, sorting, recycling and other forms of packaging waste management.

EUROPEN defines EPR/ROP as a policy tool that extends the producer’s financial or operational responsibility to the post-consumer stage of a product, in order to support the achievement of recycling and recovery targets. In practice, this shifts the costs of waste management, either partially or in full, from local authorities to producers.

In Poland, the ROP is linked to the packaging system, BDO, fees, recycling targets and the obligations of those placing packaged products on the market. The proposed national changes are intended to bring the system into line with the PPWR and to amend the current model of producer responsibility for packaging. According to information from the Ministry of Climate and Environment, the UC100 draft bill provides for producers to bear actual financial responsibility for waste generated from their packaging, in accordance with the „polluter pays” principle.

PPWR v ROP — a brief comparison

Area	PPWR	ROP
Regulation level	The European Union	National systems in the Member States, based on the EU framework
The main question	What types of packaging can be placed on the market?	Who funds and organises the management of packaging waste?
Scope	Design, material, recyclability, recycled material, labelling, reuse, bans	Charges, registers, reporting, collection, recycling, system costs
The main impact on the company	The need to adapt the packaging	The need for funding and reporting on packaging
Information required by the company	composition, weight, material, recyclability, recycled content, labelling	weight, material, market, number of packages, EPR, BDO, fees
Risk	Non-compliant packaging may be challenged	Incorrect reporting or charges may result in penalties and arrears

The PPWR and the ROP do not compete with one another. The PPWR sets the standard for packaging, whilst the ROP transfers the cost of its subsequent management to the entities placing packaged products on the market.

Does the PPWR replace the ROP?

No. The PPWR does not replace the ROP. Instead, it introduces a more uniform framework for ROP systems across the EU and means that national legislation must be brought into line with the new rules.

Documents from the Chancellery of the Prime Minister concerning the draft Act on Packaging and Packaging Waste indicate that the PPWR directly regulates many areas, but some of the provisions and their practical application require the adaptation of national legislation. The need to align Polish ROP regulations with the PPWR and with Articles 8 and 8a of the Waste Directive 2008/98/EC was also explicitly highlighted.

This means that a company cannot think: „PPWR is coming into force, so the old ROP obligations no longer apply”. The correct interpretation is the opposite: The PPWR will ensure that the ROP is more closely linked to the quality, weight and recyclability of packaging.

Where do the PPWR and ROP overlap?

The PPWR and the ROP intersect at several key points.

1. Weight of the packaging

Packaging weight is important for both the PPWR and the ROP. The PPWR requires that packaging be minimised and unnecessary weight reduced. Under the ROP, weight forms the basis for calculating obligations, fees and reporting.

If a company reduces the weight of its packaging, it can simultaneously reduce the risk of PPWR and potentially lower its cost base within ROP schemes.

2. Recyclability

The PPWR requires packaging to be designed with recycling in mind. The ROP may provide financial incentives or impose charges on packaging, depending on how difficult it is to collect, sort and process.

The Chancellery of the Prime Minister points out that the current system does not provide sufficient incentives for producers of packaged goods to adopt eco-design, and that the proposed solutions are intended to ensure a fair distribution of costs in accordance with the „polluter pays” principle.

3. Ecomodulation

Eco-modulation refers to the differentiation of charges based on the characteristics of the packaging. In practice, packaging that is easier to recycle, lighter, reusable or better designed may be more cost-effective than packaging that is heavy, made of multiple materials and difficult to manage.

The proposed Polish measures suggest that the charges are intended to encourage those who place larger quantities of packaging on the market to reduce its weight and adopt more environmentally friendly solutions.

4. Data and reporting

The same data will be required for the PPWR and the ROP:

– weight of the package,
– material,
– type of packaging,
– launch market,
– a manufacturer or importer,
– recyclability,
– recycled material,
– signage,
– the number of packs or sales volume.

The difference is that PPWR needs this data to demonstrate the packaging’s compliance, whilst ROP needs it for the financing and accounting of the waste management system.

5. Signage and education

The PPWR introduces harmonised labelling for packaging and waste containers. The ROP funds or co-funds collection, information and user education schemes. The Chancellery of the Prime Minister states that producers’ financial contributions should cover, amongst other things, the costs of informing waste holders, data collection, reporting and the labelling of waste containers.

The packaging charge and the PPWR

The packaging levy is a practical point of convergence between the PPWR and the ROP. The PPWR exerts regulatory pressure to improve packaging design, whilst the ROP and the packaging levy translate this pressure into a financial cost.

The Polish draft ROP guidelines stated that, during the transitional period, the packaging levy was to be calculated as a percentage of the product levy rate: 8% in the first year and 20% in the following year, according to information from the Ministry of Climate and Environment (MKiŚ) from 2025. Subsequent industry documents concerning the update to the draft from March 2026 indicated a postponement of the scheme’s commencement to 1 January 2027 and that the main principles of the centralised ROP model would be retained, including a transitional packaging fee of 8% in 2027 and 20% in 2028.

For businesses, the most important takeaway is a practical one: the packaging charge should not be viewed solely as a „new cost”. It is a sign that the weight, material and recyclability of packaging will become increasingly important from a financial perspective.

ROP eco-design — why will packaging design start to affect costs?

Eco-design at ROP means that packaging should be assessed not only on the basis of its purchase price, but also on the costs it generates within the waste management system. Packaging that is difficult to recycle, excessively heavy, made of multiple materials or poorly labelled may be cheaper at the point of purchase, but more expensive over its entire life cycle.

The PPWR reinforces this logic, as it introduces requirements concerning:

– recyclability,
– Design for Recycling,
– recycled content,
– minimising empty space,
– minimising packaging,
– reuse,
– labelling and sorting.

The ROP translates these characteristics into a cost system. If the national charging system is differentiated according to packaging characteristics, design decisions made by the R&D, procurement and marketing departments will begin to have a direct impact on environmental charges.

Under the old approach, packaging was a cost of purchase. Under the new approach, packaging becomes a cost across the entire system: purchasing, logistics, reporting, fees, recycling and regulatory risk.

How is PPWR changing the way we think about ROP?

Until now, many companies have treated the Packaging and Packaging Waste Act (ROP) as an administrative obligation: registration, reporting, fees and organising recovery. The PPWR shifts the focus to an earlier stage — packaging design.

This means changing the order of the steps.

The old approach:

1. We’re buying a packet.
2. We are packing the product.
3. We are reporting the weight.
4. We pay a fee or settle an obligation.

A new approach:

1. We design packaging for PPWR.
2. We check recyclability, recycled content and labelling.
3. We are assessing the impact on the ROP, BDO and EPR.
4. We select a supplier and the relevant documentation.
5. We report data that matches the actual packaging.

That is precisely why PPWR audit It should be combined with an analysis of BDO, EPR and packaging obligations. Treating these areas separately leads to inconsistencies in the data.

Who is the manufacturer in PPWR and ROP?

This is one of the most difficult practical questions. In everyday language, the producer is often the manufacturer of the goods. In packaging schemes, however, responsibility may also lie with the importer, the brand owner, the distributor, an e-commerce operator or the entity that is the first to make the packaged product available on a given market.

The guidance on PPWR and EPR for e-commerce states that a business may be regarded as a producer for the purposes of EPR when it first makes packaging or a packaged product available in a given Member State. In the case of online sales, obligations may depend on the market of delivery and the role the company plays in the supply chain.

For companies, this means they need to analyse the following roles:

– packaging manufacturer,
– the manufacturer of the product in the packaging,
– importer,
– owner of a private-label brand,
– distributor,
– online shop,
– marketplace seller,
– the entity responsible for packing orders for dispatch,
– an entity that unpacks packaging but is not the end user.

It is not always the case that a single company is responsible for everything. However, the mistaken assumption that „it’s not our problem” is one of the most common risks.

PPWR and ROP in e-commerce

E-commerce is an example of a sector in which the PPWR and ROP overlap particularly significantly. An online shop may use product packaging, shipping boxes, envelopes, plastic film, tape, labels, packing material and return packaging.

PPWR affects:

– limit on empty space,
– minimising packaging,
– the recyclability of cardboard, film and packing material,
– signage,
– material data,
– reusable and returnable packaging.

ROP affects:

– registrations,
– reporting of packaging weights,
– charges,
– EPR in the countries where the product is sold,
– LUCID when selling to Germany,
– the marketplace’s obligations.

Studies on the PPWR for e-commerce indicate that the regulation strengthens companies’ responsibility for the disposal and recycling of packaging waste in accordance with EPR principles, and that online retailers must analyse their roles as manufacturers and producers.

For online shops, a good place to start is e-commerce audit and analysis Packaging in e-commerce: BDO and LUCID.

PPWR and ROP in a manufacturing company

In a manufacturing company, PPWR and ROP should be managed together. The production and technology departments are responsible for packaging, the procurement department for suppliers, the compliance department for regulations, and the finance department for costs. The problem arises when each department keeps different data.

Example: Purchasing has a specification from the supplier, the warehouse knows the actual weight of the packaging, the accounts department reports data to BDO, marketing is changing the label, and R&D is considering a new material. If this data is not consistent, the company is not prepared for either PPWR or ROP.

The manufacturer should have a single package insert covering:

– material,
– mass,
– components,
– a supplier,
– recyclability,
– recycled material,
– signage,
– sales market,
– data for BDO,
– data for the EPR,
– PPWR documentation,
– the date of the update.

In this area, it is worth combining PPWR audit z environmental audit i comprehensive environmental consultancy.

Differences between PPWR and ROP in practice

PPWR is more „product-oriented”

The PPWR assesses packaging as a product placed on the market. What counts are its design, material, composition, labelling, recyclability and compliance with EU requirements.

The ROP is more „systemic”

The ROP assesses responsibility for post-use packaging waste. What matters is who places the packaging on the market, how much of it is placed on the market, where, what material it is made of, and how the waste management system is funded.

The PPWR operates in a more harmonised manner

The PPWR is intended to reduce discrepancies between EU Member States regarding packaging requirements. The Commission points out that the regulation covers all packaging and sets out common requirements for the production, composition and recovery of packaging.

The ROP remains firmly national

The EPR/ROP is still organised by the Member States. A company selling in several EU countries must analyse its obligations separately for each market. When exporting to Germany, it is still important to LUCID audit, and in many markets — EU services.

Similarities between PPWR and ROP

The PPWR and ROP share a common objective: to reduce packaging waste and improve the efficiency of its management.

They have the following in common:

– the need for data on mass and material,
– a focus on recyclability,
– rewarding eco-design,
– the growing importance of labelling,
– the need for reporting,
– the responsibility of operators placing prepackaged products on the market,
– links to the circular economy,
– the growing importance of the total life-cycle cost of packaging.

The key similarity is that both mechanisms force companies to gain a better understanding of their own packaging.

How can a company prepare for both the PPWR and the ROP at the same time?

The best approach is to have a single data system and a single packaging procedure.

1. Carry out an inventory of packaging

The list should include individual, bulk, transport, e-commerce, promotional and reusable packaging. For each type of packaging, the material, weight, supplier and sales market must be specified.

2. Link the PPWR data with the BDO and EPR

The same information should be used to populate the PPWR, BDO, LUCID and EPR documentation, as well as the cost analyses. Avoid using separate, inconsistent tables.

3. Assess recyclability and eco-design

Check which packaging is difficult to recycle, heavy, made of multiple materials or contains problematic components. In such cases, it is worth carrying out an analysis multi-material packaging.

4. Calculate the cost of packaging over its entire life cycle

Don’t just look at the purchase price. Take into account weight, charges, EPR, transport, recyclability, changing suppliers, the risk of penalties and B2B customer requirements.

5. Update your procurement procedures

The supplier should provide information on composition, weight, recycled content, recyclability, substances of concern and material compliance.

6. Establish internal accountability

PPWR and ROP should not be the sole responsibility of the environmental department. Procurement, production, marketing, logistics, quality, finance and compliance must all be involved in the process.

7. Carry out an audit

An audit enables you to identify which packaging poses legal, cost and reporting risks. This is a good time to combine PPWR audit z environmental audit.

The most common mistakes made by companies

The first mistake is to assume that PPWR will replace ROP. It will not — both mechanisms will operate in parallel.

The second mistake is to treat the ROP solely as a charge. The ROP will become increasingly linked to weight, materials, recyclability and eco-design.

The third error is keeping separate records for PPWR, BDO and EPR. This leads to inconsistencies and the risk of an audit.

The fourth mistake is to focus solely on the product rather than the packaging. Under the PPWR, packaging becomes a separate item subject to compliance requirements.

The fifth mistake is a failure to analyse overseas sales. A single product may give rise to different EPR obligations in different EU countries.

The sixth mistake is to put off the audit until the new charges come into effect. By then, the company will be changing its packaging under cost pressure.

FAQ - Frequently asked questions

Does the PPWR replace the ROP?

No. The PPWR does not replace the ROP. The PPWR sets out EU requirements for packaging, whilst the ROP remains the mechanism for financing and organising the management of packaging waste in Member States. National legislation must be brought into line with the PPWR.

How does PPWR differ from ROP?

The PPWR mainly concerns requirements for packaging: design, composition, recyclability, recycled content, labelling and reuse. The ROP concerns financial or organisational responsibility for packaging waste following the use of the product.

Is the packaging charge based on the PPWR?

The packaging charge forms part of the national ROP model, but its design is linked to the requirements of the PPWR. The Polish draft guidelines state that the charges are intended to encourage a reduction in packaging weight and the use of more environmentally friendly solutions.

What does eco-design mean in the ROP?

Eco-design under the ROP means that the characteristics of packaging — weight, material, recyclability, reusability and impact on the waste management system — can affect the costs incurred by the manufacturer. The PPWR reinforces this approach through its ‘Design for Recycling’ requirements.

Does a company that sells abroad need to analyse the EPR separately?

Yes. The PPWR harmonises many requirements, but the EPR/ROP still operates within national systems. A company selling to several EU countries should check the obligations in each country, including registration, reporting and any required representatives.

How do you go about organising the PPWR and ROP within a company?

It is best to start with a single packaging map: material, weight, supplier, sales market, recyclability, recycled content, labelling, BDO and EPR. Next, it is worth carrying out a PPWR audit and an environmental audit to link product compliance with reporting and financial obligations.

Get your company’s environmental affairs in order – from start to finish

PPWR and ROP will become increasingly intertwined in practice. A company that knows the composition, weight, recyclability and sales markets for its packaging will find it easier to prepare for both new EU requirements and national levies, BDO, EPR and LUCID.

Get your company’s environmental affairs in order — find out more PPWR audit, compliance with packaging obligations in EU markets, environmental audit and a full our business offering. You can also go to the tab Contact Eko-Pro and describe their packaging, sales markets and current BDO/EPR obligations.