Frequently asked questions

No. Extended producer responsibility (EPR) is only one part of the PPWR. The Regulation also sets requirements for packaging design, labelling, recyclability, reusability and the use of recycled content, among other things. A company may be subject to PPWR requirements even if it has no EPR obligations.

The first step is to identify the company’s role in the supply chain and determine what types of packaging it uses, manufactures, has designed or manufactured under its own name or trademark, imports or places on the market. This information can then be used to assess which PPWR requirements and EPR obligations apply to the company.

The producer of packaging is not necessarily the same as the seller or importer of the packaged product. Depending on the circumstances, the producer may be, for example, a packer, an importer, a foreign distance seller or a company that has packaging designed or manufactured under its own name or trademark.

The allocation of EPR obligations depends on the company’s role in the supply chain, the type of packaging and who the end user is.

A company may qualify as a producer of packaging, for example, when it packs products, imports packaged products, has service packaging or transport packaging designed or manufactured under its own name or trademark, or sells products directly to end users in another Member State through distance sales.

The definition of a producer depends on the company’s role and the type of packaging involved. If the position is unclear, the company should assess its role against the applicable producer definitions or contact Finnish Packaging Recycling RINKI Ltd, the service company of the Finnish Packaging Producers Ltd.

Under the PPWR, an end user is a person or company to whom a product is made available and who does not make that product further available on the market in the form in which it was supplied.

For example, if a company uses purchased products in its own production processes or to provide its services, it will generally be the end user. If the company resells the products in the same form, it will generally not be the end user.

Identifying the end user is important because it can affect who qualifies as the producer of the packaging.

Yes. The same company may be the producer of some packaging, the end user of other packaging and, in certain circumstances, the manufacturer of packaging designed or manufactured under its own name or trademark.

EPR obligations must therefore be assessed separately for each type of packaging and each relevant situation.

There is no single EU-wide producer register. EPR obligations must be fulfilled in each Member State where the company qualifies as the producer of packaging or packaged products under the applicable rules.

If a company places packaging or packaged products on the market in several Member States, it may need to register with the relevant national systems in several countries.

Yes. If a company sells packaged products directly to end users in another EU Member State through distance sales, it must appoint an authorised representative for extended producer responsibility established in the destination Member State to fulfil its EPR obligations. The end user may be a consumer or a business that does not make the product further available on the market in the form in which it was supplied.

A Finnish distance seller must appoint an authorised representative in the destination country. Likewise, a foreign distance seller must appoint an authorised representative in Finland. A foreign distance seller may enter into an agreement with Finnish Packaging Producers Ltd for FPP to act as its authorised representative in Finland.

Requirements and practical arrangements may vary between countries. Companies should always confirm the applicable requirements with the relevant national producer responsibility organisation. Further information is available on the website of Finnish Packaging Recycling RINKI Ltd.

A foreign company may qualify as a producer of packaging in Finland, for example, when it sells packaged products directly to Finnish end users through distance sales.

The decisive factors are not simply the country in which the company is established, but how the products are sold and to whom they are supplied.

Yes. Generally, the PPWR applies to all packaging placed on the EU market, regardless of whether it is used in consumer or business-to-business markets.

The PPWR requires EPR fees to take the environmental performance of packaging into account. The detailed criteria for eco-modulation will be specified in subsequent EU implementing acts.

To fulfil its EPR obligations, a producer must collect the information required about the packaging it places on the market. This may include packaging materials, weights, packaging types and quantities placed on the market.

Some PPWR requirements will also require information on matters such as recyclability, reusability and recycled content. Reporting requirements will be further specified through supplementary EU legislation.

Under the PPWR, the manufacturer is responsible for ensuring that the packaging complies with the applicable requirements of the Regulation. The manufacturer must prepare the required technical documentation, carry out the conformity assessment and draw up the EU declaration of conformity.

Companies should nevertheless check with their packaging suppliers how conformity is demonstrated in practice. However, being the manufacturer does not automatically mean that a company is also the producer for EPR purposes.

Fulfilling EPR obligations is mandatory. In Finland, compliance is supervised by the Finnish Supervisory Agency.

If a company subject to EPR fails to fulfil its obligations, the agency may impose a negligence fee. The fee amounts to 1% of the company’s turnover for the previous financial year, subject to a minimum of EUR 500 and a maximum of EUR 500,000.

Companies that have fulfilled their EPR obligations in Finland can be checked in the producer responsibility register on the website Jatehuoltokompassi.fi (Waste Management Compass).

Not necessarily. Under the PPWR, the manufacturer is responsible for the packaging’s conformity, technical documentation and EU declaration of conformity. The producer, in turn, is responsible for EPR obligations, reporting and the costs of waste management in the relevant Member State.

In some cases, the manufacturer and the producer are the same company, but this is not always the case.

For service packaging, primary production packaging and transport packaging, a key factor is who determines the packaging specifications.

If a company has packaging designed or manufactured according to its own specifications, for example by defining its dimensions, structure, materials or appearance, it may be considered the manufacturer under the PPWR and may therefore be the producer for EPR purposes, depending on the circumstances.

A company will generally be responsible for EPR for packaging placed on the market under its own name or trademark. This is particularly relevant for sales packaging and consumer packaging.

For service packaging, transport packaging and primary production packaging, the allocation of EPR obligations may also depend on who determines the packaging specifications and has the packaging designed or manufactured. In these cases, the company that determines the packaging specifications may be considered the manufacturer.

The decisive factor is therefore not always just the name or logo on the packaging. The company’s role in placing the packaging on the market and determining its design and manufacturing specifications must also be considered.

Yes. Certain specific rules apply to micro-enterprises in some circumstances, but a micro-enterprise may still qualify as a producer, for example, in its role as a packer, importer or distance seller.

A farmer may be responsible for EPR for packaging, for example, when it packs products under its own name or trademark, acts as an importer or sells products directly to end users through distance sales.

However, specific rules for micro-enterprises may mean that responsibility falls on the packaging supplier in certain circumstances.

No. The PPWR entered into force in 2025 and applies from 12 August 2026, but individual requirements are being introduced in stages. Some requirements will become applicable only after further EU implementing acts have been adopted.

For example, the Regulation introduces restrictions on PFAS in food-contact packaging that apply from 12 August 2026.

Possibly. The PPWR introduces new requirements concerning, among other things, packaging minimisation, recyclability, reusability and recycled content. Whether changes are necessary depends on the types of packaging the company uses and when the relevant requirements become applicable.

For example, from 2030, packaging placed on the market must meet the PPWR’s recyclability requirements. The detailed criteria for assessing recyclability will be specified in subsequent EU legislation.

Companies should therefore assess the recyclability of their packaging now, as recyclability will become one of the conditions for placing packaging on the market from 2030.

The PPWR requirements are being introduced in stages, and some details will only be clarified through subsequent EU implementing acts and guidance. Companies should therefore actively monitor developments in the legislation.

Useful sources of information include the PPWR itself, publications and guidance from the European Commission, the websites of the Finnish Supervisory Agency and Tukes, and up-to-date guidance from Finnish Packaging Producers Ltd and Finnish Packaging Recycling RINKI Ltd.

Companies are also encouraged to take part in PPWR-related training sessions and webinars. The regulatory framework continues to develop, and keeping up to date helps companies prepare for upcoming requirements well in advance.