Changes to extended producer responsibility introduced by PPWR from 12 August 2026

Transport packaging

The producer of transport packaging is generally the manufacturer or importer of empty transport packaging. A distance seller established outside Finland may also be considered the producer of transport packaging if it makes the transport packaging directly available to an end-user in Finland.

• Typical examples of transport packaging include pallets, roll cages and e-commerce packaging, as well as pallet covers, layer pads, corner protectors and stretch film.
• Sales packaging and grouped packaging, large bags and, for example, IBC containers are not considered transport packaging. FIBCs, IBCs and other similar packaging in which the product is packaged as such are, as a rule, sales packaging rather than transport packaging.
• The company that manufactures the packaging is responsible for all packaging that can independently function as transport packaging. For example, a roll of stretch film is considered transport packaging, and the responsible producer is its Finnish manufacturer or importer into Finland. Stretch film used for packing deliveries arriving in Finland from abroad is the responsibility of the importer or distance seller of the product.
• If transport, service or primary production packaging consists of components that are only combined into a packaging unit by the packer, responsibility still lies with the manufacturer or importer.
  Example:
  A Finnish café purchases unbranded cups from a Finnish manufacturer and lids imported by a Finnish importer. The café combines the cup and lid into one packaging unit. The manufacturer is responsible for the cups and the importer is responsible for the lids.

Branded packaging

A company that commissions the manufacture or design of packaging or a packaged product under its own name or trademark and places it on the market for the first time is considered the manufacturer of the packaging.

• If the company commissioning the manufacture is a micro-enterprise (fewer than 10 employees and an annual turnover or balance sheet total of no more than EUR 2 million), the obligations of the company commissioning the manufacture are transferred to the packaging supplier under certain conditions. However, a micro-enterprise may still be subject to extended producer responsibility, for example in the role of an importer or distance seller.

Examples:

When a retail chain commissions private label products under its own trademark, it is responsible for the packaging of those products.

When a café orders service packaging, such as cups bearing its own logo, it is responsible for these packaging items.

• Custom-made packaging may also fall under the responsibility of the company commissioning the manufacture, even if the name or trademark of the customer has not been marked on the packaging. The decisive factor is whether the customer has specified characteristics of the packaging, such as its dimensions, structure, materials or appearance.
  Example:
  A company manufacturing small machinery commissions custom-sized wooden pallets for its own use without the company’s name or trademark. The manufacturer of the pallets is responsible for them.
• The company commissioning the design or manufacture of a packaged product is responsible for all sales packaging and grouped packaging into which the supplier packs the product, even if only some of the packaging bears the customer’s name or trademark.
  Example:
  A retail chain commissions private label food products from a food manufacturer. The manufacturer packs them both in sales packaging branded for the retail chain and in unbranded grouped packaging. The retail chain is responsible for both types of packaging.
• If a packaging manufacturer produces unbranded service, transport or primary production packaging to order, the packaging manufacturer is responsible for the packaging even if the customer later adds its own name or trademark.

Restrictions on heavy metals

The heavy metals Pb, Cr6, Cd and Hg are prohibited in all packaging. For food contact packaging manufactured after 12 August 2026, PFAS compounds must comply with the specified limit values. However, food contact packaging already placed on the market may continue to be made available.