A comparison for teams separating packaging obligations from product-compliance work.
PPWR controls the package. controls in-scope electrical and electronic equipment, including its materials, components, cables, and covered spare parts. Packaging is not tested against RoHS merely because it contains EEE.
Use PPWR for the box, tray, film, label, and other packaging. Use for electrical and electronic equipment (EEE) that depends on electric currents or electromagnetic fields for at least one intended function and is designed within the Directive's voltage limits, unless an exclusion applies. RoHS limits are assessed in each homogeneous material, not against the weight of the finished device or its package. A hardware shipment commonly needs both files, but one declaration does not prove the other.
Comparison matrix
PPWR vs RoHS: packaging obligations and RoHS workstream limits
Use these rows to keep EU packaging duties separate from assumptions, assign owners, and avoid reusing evidence beyond what the sources actually support.
PPWR controls the packaging analysis: packaging placed on the EU market, packaging waste, recyclability, recycled content, minimisation, labelling, EPR, conformity documentation, and market-surveillance risk.
Second framework
RoHS
restricts hazardous substances in EEE, applies to equipment in Annex I categories unless excluded, and covers ten restricted substances with technical documentation, EU declaration of conformity, and CE marking obligations.
PPWR vs RoHS: packaging obligations and RoHS workstream limits
PPWR applies to all packaging placed on the EU market and to all packaging waste, regardless of packaging type or material. Start with the packaging unit, packaging category, function, material, and waste stream.
Official PPWR text used for packaging scope, economic-operator duties, conformity documentation, market surveillance, penalties, and application dates.
Commission overview used for the practical policy summary, including mid-2026 application, recyclability by 2030, 2030 and 2040 recycled-content targets, and PFAS timing.
All Packaging must be recyclable by 2030
applies to EEE in the Annex I categories unless Article 2(4) excludes it. EEE must depend on electric currents or electromagnetic fields for at least one intended function and be designed for no more than 1,000 V AC or 1,500 V DC. The Directive also covers cables and spare parts in the circumstances stated in Article 4.
RoHS scope, exclusions, restricted substances, and compliance duties come from the Directive itself.
apply to EEE falling within the categories set out in Annex I
Classify the package under PPWR and the device under . Do not apply RoHS concentration limits to ordinary transport or sales packaging unless that packaging is itself EEE.
Official PPWR text used for packaging scope, economic-operator duties, conformity documentation, market surveillance, penalties, and application dates.
PPWR assigns duties across packaging economic operators, including manufacturers, importers, distributors, final distributors, producers, producer responsibility organisations, and system operators depending on the obligation.
Official PPWR text used for packaging scope, economic-operator duties, conformity documentation, market surveillance, penalties, and application dates.
rules covering the entire life-cycle of packaging
places obligations on manufacturers, authorised representatives, importers, and distributors. Manufacturers must ensure compliance before placing EEE on the market and prepare the technical documentation and EU declaration of conformity.
RoHS defines manufacturers, authorised representatives, importers, distributors, and economic operators in Articles 3 and 7-10.
manufacturers draw up the required technical documentation
Name the PPWR packaging owner separately from the product-compliance owner, then record who controls packaging design, supplier data, EPR registration, declarations, and market placement.
Official PPWR text used for packaging scope, economic-operator duties, conformity documentation, market surveillance, penalties, and application dates.
PPWR is triggered by packaging being placed or made available on the EU market and by packaging-waste obligations. Specific duties depend on facts such as plastic content, food-contact use, reuse format, packaging category, and whether packaging is single-use or reusable.
Official PPWR text used for packaging scope, economic-operator duties, conformity documentation, market surveillance, penalties, and application dates.
Commission overview used for the practical policy summary, including mid-2026 application, recyclability by 2030, 2030 and 2040 recycled-content targets, and PFAS timing.
All Packaging must be recyclable by 2030
is triggered when in-scope EEE is placed on the EU market. Annex II permits no more than 0.1% by weight in each homogeneous material for lead, mercury, hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP, and DIBP, and 0.01% for cadmium, unless an applicable Annex III or IV exemption covers the specific use.
RoHS applies to EEE categories in Annex I and restricts substances in Article 4 and Annex II.
does not contain the substances listed in Annex II
Break the EEE into homogeneous materials that cannot be mechanically separated further, then map each restricted substance result and exemption to that material. A whole-product average can hide a failing material.
Official PPWR text used for packaging scope, economic-operator duties, conformity documentation, market surveillance, penalties, and application dates.
PPWR work can include packaging minimisation, recyclability on the phased Article 6 dates, recycled-content targets for plastic packaging, reuse and refill measures, clearer labels, restrictions on some single-use formats, PFAS restrictions for food-contact packaging, EPR, and conformity assessment.
Official PPWR text used for packaging scope, economic-operator duties, conformity documentation, market surveillance, penalties, and application dates.
Commission overview used for the practical policy summary, including mid-2026 application, recyclability by 2030, 2030 and 2040 recycled-content targets, and PFAS timing.
JRC report used for design-for-recycling and recyclability-assessment methodology context under the PPWR proposal.
methodology to assess recyclability of packaging
requires the manufacturer to ensure Article 4 substance compliance, draw up technical documentation, complete internal production control, issue an EU declaration of conformity, affix CE marking to the finished EEE, and retain the documentation and declaration for 10 years. Exemptions must match the material, application, category, and validity conditions.
RoHS bans or limits ten substances and requires technical documentation and an EU declaration of conformity.
does not contain the substances listed in Annex II
Do not label PPWR packaging controls as controls. A shared compliance roadmap can contain both, but each obligation needs its own source, owner, and evidence record.
Official PPWR text used for packaging scope, economic-operator duties, conformity documentation, market surveillance, penalties, and application dates.
PPWR evidence should connect the packaging specification to technical documentation, recyclability assessment, recycled-content calculations where relevant, labels, reuse or refill decisions, EPR data, and the EU declaration of conformity where required.
Official PPWR text used for packaging scope, economic-operator duties, conformity documentation, market surveillance, penalties, and application dates.
JRC report used for design-for-recycling and recyclability-assessment methodology context under the PPWR proposal.
methodology to assess recyclability of packaging
evidence should identify the EEE category and exclusions considered, the bill of materials and homogeneous-material breakdown, supplier and test evidence, every exemption relied on and its validity, the conformity procedure, technical documentation, EU declaration of conformity, and CE-marking support. The manufacturer keeps the technical documentation and declaration for 10 years after market placement.
Official PPWR text used for packaging scope, economic-operator duties, conformity documentation, market surveillance, penalties, and application dates.
PPWR generally applies from 12 August 2026; Article 67(5) applies from 12 February 2029. Packaging teams must track each duty separately: the food-contact PFAS limits start on the general application date, while the Article 6 design-for-recycling condition starts on 1 January 2030 or 24 months after the relevant delegated acts enter into force, whichever is later. Recycled-content targets have their own Article 7 dates, rather than a exemption expiry date.
Official PPWR text used for packaging scope, economic-operator duties, conformity documentation, market surveillance, penalties, and application dates.
Commission overview used for the practical policy summary, including mid-2026 application, recyclability by 2030, 2030 and 2040 recycled-content targets, and PFAS timing.
All Packaging must be recyclable by 2030
already applies across its open scope. Its category phase-in dates are historical, while Annex III and IV exemptions can expire, be renewed, or be narrowed. Check the consolidated Directive and the exact exemption entry on the release date; a historical supplier declaration can rely on an exemption that no longer covers the product.
Official PPWR text used for packaging scope, economic-operator duties, conformity documentation, market surveillance, penalties, and application dates.
PPWR non-compliance can reach market surveillance: authorities may evaluate packaging that presents environmental or health risk, require corrective measures, and restrict, withdraw, or recall non-compliant packaging. Member States must set effective, proportionate, and dissuasive penalties.
Official PPWR text used for packaging scope, economic-operator duties, conformity documentation, market surveillance, penalties, and application dates.
rules covering the entire life-cycle of packaging
enforcement runs through national market surveillance authorities. The Directive requires market surveillance for EEE entering the Union market, corrective measures for non-conforming products, and penalties that are effective, proportionate, and dissuasive.
RoHS market surveillance, corrective measures, and penalties are addressed in Articles 18, 7, 9, 10, and 23.
Member States shall carry out market surveillance
Before launch, claims approval, authority response, or corrective action, check whether the issue is packaging non-compliance under PPWR, product hazardous-substance compliance under , or both.
Official PPWR text used for packaging scope, economic-operator duties, conformity documentation, market surveillance, penalties, and application dates.
PPWR can share operational inputs with , especially supplier records, material descriptions, product identifiers, and release gates. PPWR still controls the packaging-specific conclusions on recyclability, labelling, EPR, minimisation, and conformity documentation.
Official PPWR text used for packaging scope, economic-operator duties, conformity documentation, market surveillance, penalties, and application dates.
JRC report used for design-for-recycling and recyclability-assessment methodology context under the PPWR proposal.
methodology to assess recyclability of packaging
A supplier composition record can support both workstreams, but conclusions must stay tied to the EEE's homogeneous materials and exemptions. PPWR conclusions stay tied to the packaging unit, packaging-specific substance rules, and packaging conformity assessment.
RoHS substance restrictions, exemptions, and conformity evidence must be assessed separately from PPWR packaging evidence.
does not contain the substances listed in Annex II
Reuse supplier and material data where the fact is identical, but keep legal conclusions, public wording, deadlines, declarations, and retained evidence mapped to the framework that actually requires them.
Official PPWR text used for packaging scope, economic-operator duties, conformity documentation, market surveillance, penalties, and application dates.
Use PPWR when the decision is about packaging or packaging waste: whether packaging may be placed on the EU market, how it is designed, labelled, reused, recycled, documented, reported, or handled through EPR.
Official PPWR text used for packaging scope, economic-operator duties, conformity documentation, market surveillance, penalties, and application dates.
Commission overview used for the practical policy summary, including mid-2026 application, recyclability by 2030, 2030 and 2040 recycled-content targets, and PFAS timing.
All Packaging must be recyclable by 2030
Use when the decision is about the electrical or electronic product and whether its materials, components, or spare parts comply with the RoHS substance restrictions, exemptions, technical documentation, and CE-marking rules.
RoHS decision-making turns on EEE scope, Annex II substances, exemptions, documentation, and CE marking.
the requirements set out in Article 4
If both frameworks may apply, publish a short crosswalk: PPWR statement, statement, source URL, accountable owner, evidence record, next review date, and any blocked RoHS assumptions.
Official PPWR text used for packaging scope, economic-operator duties, conformity documentation, market surveillance, penalties, and application dates.
RoHS decision-making turns on scope, substance restrictions, exemptions, documentation, and CE marking.
draw up an EU declaration of conformity and affix the CE marking
Scope and covered activity
PPWR
PPWR applies to all packaging placed on the EU market and to all packaging waste, regardless of packaging type or material. Start with the packaging unit, packaging category, function, material, and waste stream.
Official PPWR text used for packaging scope, economic-operator duties, conformity documentation, market surveillance, penalties, and application dates.
Commission overview used for the practical policy summary, including mid-2026 application, recyclability by 2030, 2030 and 2040 recycled-content targets, and PFAS timing.
All Packaging must be recyclable by 2030
RoHS
applies to EEE in the Annex I categories unless Article 2(4) excludes it. EEE must depend on electric currents or electromagnetic fields for at least one intended function and be designed for no more than 1,000 V AC or 1,500 V DC. The Directive also covers cables and spare parts in the circumstances stated in Article 4.
RoHS scope, exclusions, restricted substances, and compliance duties come from the Directive itself.
apply to EEE falling within the categories set out in Annex I
Operational implication
Classify the package under PPWR and the device under . Do not apply RoHS concentration limits to ordinary transport or sales packaging unless that packaging is itself EEE.
Official PPWR text used for packaging scope, economic-operator duties, conformity documentation, market surveillance, penalties, and application dates.
RoHS scope and exclusions are defined in the Directive, including Annex I categories and Article 2(4) exclusions.
This Directive shall, subject to paragraph 2, apply to EEE falling within the categories set out in Annex I
Who must act
PPWR
PPWR assigns duties across packaging economic operators, including manufacturers, importers, distributors, final distributors, producers, producer responsibility organisations, and system operators depending on the obligation.
Official PPWR text used for packaging scope, economic-operator duties, conformity documentation, market surveillance, penalties, and application dates.
rules covering the entire life-cycle of packaging
RoHS
places obligations on manufacturers, authorised representatives, importers, and distributors. Manufacturers must ensure compliance before placing EEE on the market and prepare the technical documentation and EU declaration of conformity.
RoHS defines manufacturers, authorised representatives, importers, distributors, and economic operators in Articles 3 and 7-10.
manufacturers draw up the required technical documentation
Operational implication
Name the PPWR packaging owner separately from the product-compliance owner, then record who controls packaging design, supplier data, EPR registration, declarations, and market placement.
Official PPWR text used for packaging scope, economic-operator duties, conformity documentation, market surveillance, penalties, and application dates.
RoHS defines manufacturers, authorised representatives, importers, and distributors and their duties in Articles 7-10.
economic operators
Trigger or threshold
PPWR
PPWR is triggered by packaging being placed or made available on the EU market and by packaging-waste obligations. Specific duties depend on facts such as plastic content, food-contact use, reuse format, packaging category, and whether packaging is single-use or reusable.
Official PPWR text used for packaging scope, economic-operator duties, conformity documentation, market surveillance, penalties, and application dates.
Commission overview used for the practical policy summary, including mid-2026 application, recyclability by 2030, 2030 and 2040 recycled-content targets, and PFAS timing.
All Packaging must be recyclable by 2030
RoHS
is triggered when in-scope EEE is placed on the EU market. Annex II permits no more than 0.1% by weight in each homogeneous material for lead, mercury, hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP, and DIBP, and 0.01% for cadmium, unless an applicable Annex III or IV exemption covers the specific use.
RoHS applies to EEE categories in Annex I and restricts substances in Article 4 and Annex II.
does not contain the substances listed in Annex II
Operational implication
Break the EEE into homogeneous materials that cannot be mechanically separated further, then map each restricted substance result and exemption to that material. A whole-product average can hide a failing material.
Official PPWR text used for packaging scope, economic-operator duties, conformity documentation, market surveillance, penalties, and application dates.
RoHS restrictions apply when EEE is placed on the market, subject to Article 2 exclusions and Article 4 substance limits.
when placing EEE on the market
Core obligations
PPWR
PPWR work can include packaging minimisation, recyclability on the phased Article 6 dates, recycled-content targets for plastic packaging, reuse and refill measures, clearer labels, restrictions on some single-use formats, PFAS restrictions for food-contact packaging, EPR, and conformity assessment.
Official PPWR text used for packaging scope, economic-operator duties, conformity documentation, market surveillance, penalties, and application dates.
Commission overview used for the practical policy summary, including mid-2026 application, recyclability by 2030, 2030 and 2040 recycled-content targets, and PFAS timing.
JRC report used for design-for-recycling and recyclability-assessment methodology context under the PPWR proposal.
methodology to assess recyclability of packaging
RoHS
requires the manufacturer to ensure Article 4 substance compliance, draw up technical documentation, complete internal production control, issue an EU declaration of conformity, affix CE marking to the finished EEE, and retain the documentation and declaration for 10 years. Exemptions must match the material, application, category, and validity conditions.
RoHS bans or limits ten substances and requires technical documentation and an EU declaration of conformity.
does not contain the substances listed in Annex II
Operational implication
Do not label PPWR packaging controls as controls. A shared compliance roadmap can contain both, but each obligation needs its own source, owner, and evidence record.
Official PPWR text used for packaging scope, economic-operator duties, conformity documentation, market surveillance, penalties, and application dates.
RoHS obligations include technical documentation, EU declaration of conformity, and CE marking in Articles 7, 13, and 15.
draw up an EU declaration of conformity and affix the CE marking
Evidence and records
PPWR
PPWR evidence should connect the packaging specification to technical documentation, recyclability assessment, recycled-content calculations where relevant, labels, reuse or refill decisions, EPR data, and the EU declaration of conformity where required.
Official PPWR text used for packaging scope, economic-operator duties, conformity documentation, market surveillance, penalties, and application dates.
JRC report used for design-for-recycling and recyclability-assessment methodology context under the PPWR proposal.
methodology to assess recyclability of packaging
RoHS
evidence should identify the EEE category and exclusions considered, the bill of materials and homogeneous-material breakdown, supplier and test evidence, every exemption relied on and its validity, the conformity procedure, technical documentation, EU declaration of conformity, and CE-marking support. The manufacturer keeps the technical documentation and declaration for 10 years after market placement.
Official PPWR text used for packaging scope, economic-operator duties, conformity documentation, market surveillance, penalties, and application dates.
RoHS technical documentation and EU declaration of conformity are set out in Articles 7 and 13.
EU declaration of conformity
Timing and cadence
PPWR
PPWR generally applies from 12 August 2026; Article 67(5) applies from 12 February 2029. Packaging teams must track each duty separately: the food-contact PFAS limits start on the general application date, while the Article 6 design-for-recycling condition starts on 1 January 2030 or 24 months after the relevant delegated acts enter into force, whichever is later. Recycled-content targets have their own Article 7 dates, rather than a exemption expiry date.
Official PPWR text used for packaging scope, economic-operator duties, conformity documentation, market surveillance, penalties, and application dates.
Commission overview used for the practical policy summary, including mid-2026 application, recyclability by 2030, 2030 and 2040 recycled-content targets, and PFAS timing.
All Packaging must be recyclable by 2030
RoHS
already applies across its open scope. Its category phase-in dates are historical, while Annex III and IV exemptions can expire, be renewed, or be narrowed. Check the consolidated Directive and the exact exemption entry on the release date; a historical supplier declaration can rely on an exemption that no longer covers the product.
Official PPWR text used for packaging scope, economic-operator duties, conformity documentation, market surveillance, penalties, and application dates.
RoHS application dates differ by category and exempted applications, and exemption renewals have their own timing rules.
The existing exemption shall remain valid until a decision on the renewal application is taken by the Commission
Enforcement or assurance route
PPWR
PPWR non-compliance can reach market surveillance: authorities may evaluate packaging that presents environmental or health risk, require corrective measures, and restrict, withdraw, or recall non-compliant packaging. Member States must set effective, proportionate, and dissuasive penalties.
Official PPWR text used for packaging scope, economic-operator duties, conformity documentation, market surveillance, penalties, and application dates.
rules covering the entire life-cycle of packaging
RoHS
enforcement runs through national market surveillance authorities. The Directive requires market surveillance for EEE entering the Union market, corrective measures for non-conforming products, and penalties that are effective, proportionate, and dissuasive.
RoHS market surveillance, corrective measures, and penalties are addressed in Articles 18, 7, 9, 10, and 23.
Member States shall carry out market surveillance
Operational implication
Before launch, claims approval, authority response, or corrective action, check whether the issue is packaging non-compliance under PPWR, product hazardous-substance compliance under , or both.
Official PPWR text used for packaging scope, economic-operator duties, conformity documentation, market surveillance, penalties, and application dates.
RoHS requires market surveillance, corrective measures, and national penalties.
effective, proportionate and dissuasive
Overlap and reuse
PPWR
PPWR can share operational inputs with , especially supplier records, material descriptions, product identifiers, and release gates. PPWR still controls the packaging-specific conclusions on recyclability, labelling, EPR, minimisation, and conformity documentation.
Official PPWR text used for packaging scope, economic-operator duties, conformity documentation, market surveillance, penalties, and application dates.
JRC report used for design-for-recycling and recyclability-assessment methodology context under the PPWR proposal.
methodology to assess recyclability of packaging
RoHS
A supplier composition record can support both workstreams, but conclusions must stay tied to the EEE's homogeneous materials and exemptions. PPWR conclusions stay tied to the packaging unit, packaging-specific substance rules, and packaging conformity assessment.
RoHS substance restrictions, exemptions, and conformity evidence must be assessed separately from PPWR packaging evidence.
does not contain the substances listed in Annex II
Operational implication
Reuse supplier and material data where the fact is identical, but keep legal conclusions, public wording, deadlines, declarations, and retained evidence mapped to the framework that actually requires them.
Official PPWR text used for packaging scope, economic-operator duties, conformity documentation, market surveillance, penalties, and application dates.
RoHS substance restrictions, exemptions, and conformity evidence are separate from packaging evidence.
Annex II
Practical decision rule
PPWR
Use PPWR when the decision is about packaging or packaging waste: whether packaging may be placed on the EU market, how it is designed, labelled, reused, recycled, documented, reported, or handled through EPR.
Official PPWR text used for packaging scope, economic-operator duties, conformity documentation, market surveillance, penalties, and application dates.
Commission overview used for the practical policy summary, including mid-2026 application, recyclability by 2030, 2030 and 2040 recycled-content targets, and PFAS timing.
All Packaging must be recyclable by 2030
RoHS
Use when the decision is about the electrical or electronic product and whether its materials, components, or spare parts comply with the RoHS substance restrictions, exemptions, technical documentation, and CE-marking rules.
RoHS decision-making turns on EEE scope, Annex II substances, exemptions, documentation, and CE marking.
the requirements set out in Article 4
Operational implication
If both frameworks may apply, publish a short crosswalk: PPWR statement, statement, source URL, accountable owner, evidence record, next review date, and any blocked RoHS assumptions.
Official PPWR text used for packaging scope, economic-operator duties, conformity documentation, market surveillance, penalties, and application dates.
Official PPWR text used for packaging scope, economic-operator duties, conformity documentation, market surveillance, penalties, and application dates.
Commission overview used for the practical policy summary, including mid-2026 application, recyclability by 2030, 2030 and 2040 recycled-content targets, and PFAS timing.
RoHS applies to EEE categories in Annex I, restricts ten substances, and requires documentation and CE marking.
does not contain the substances listed in Annex II
1
Section 1
When should teams use this PPWR vs RoHS comparison?
It is relevant when packaging and product-compliance work meet in the same launch, supplier review, bill of material, or market-access gate. A device shipment, spare part, accessory, or e-commerce package can create PPWR packaging questions even when the product team is also running a workstream.
Keep two release records. The PPWR record identifies the packaging unit, materials, applicable sustainability requirements, and packaging declaration. The record identifies the EEE, homogeneous materials, restricted substances, exemptions, conformity route, and product declaration.
Use it before assigning packaging design, labelling, EPR, recyclability, recycled-content, or conformity-documentation work.
It is relevant when a supplier evidence pack could be reused but the legal conclusion still belongs to only one framework.
Verify substance thresholds, product scope, and each exemption against the Directive and the exact applicable entry before approving the product.
Official PPWR text used for packaging scope, economic-operator duties, conformity documentation, market surveillance, penalties, and application dates.
Commission overview used for the practical policy summary, including mid-2026 application, recyclability by 2030, 2030 and 2040 recycled-content targets, and PFAS timing.
Commission overview used for the practical policy summary, including mid-2026 application, recyclability by 2030, 2030 and 2040 recycled-content targets, and PFAS timing.
Official PPWR text used for packaging scope, economic-operator duties, conformity documentation, market surveillance, penalties, and application dates.
"rules covering the entire life-cycle of packaging"