Who should own a PPWR compliance programme?

Start with the companies. For each packaging format, the Regulation names one manufacturer for the whole EU (Article 15) and a producer in each Member State where the packaging is first made available (Articles 44 and 45). Importers, distributors and fulfilment service providers carry their own checks (Articles 18 to 20). The Commission's guidance notice says a contract can delegate drafting the declaration of conformity, but not the manufacturer's legal responsibility.

A group with several companies needs this per entity. Record which company is the manufacturer for each format, and which is the producer in each country. The person who signs the EU declaration of conformity signs for and on behalf of the manufacturer, with their name and function (Annex VIII).

Then assign people. A programme owner holds the plan and approves its decisions. Task owners each hold a set of duties. Take a fictional manufacturer, Tarnwick, with an EU company established in Ireland. Its programme owner and approver is Hannah Okafor, Head of Product Stewardship.

Design and conformity work sits close to the packaging. At Tarnwick, the packaging engineer owns recyclability (Article 6), minimisation (Article 10) and reusability (Article 11), and keeps the technical documentation in Annex VII for each format. That includes the drawings, materials, test reports and the explanation of why weight and volume can't be reduced further.

Product stewardship owns the chemistry. That covers substances of concern and the 100 mg/kg heavy metals limit (Article 5), the food contact PFAS limits where they apply, and exemptions for packaging used to transport dangerous goods. The quality manager owns the procedures that keep series production in conformity, and the check that a change to design, materials or supplier triggers a reassessment (Article 15(4)).

Label artwork belongs to whoever owns it today, usually marketing or packaging design. Its PPWR work is the harmonised sorting label, from 12 August 2028 at the earliest (Article 12).

EPR follows each country's rules until the new EU producer registers are in place. At Tarnwick, the environmental compliance manager owns the registrations, scheme contracts and returns in each country where Tarnwick is the producer. Where the rules require one, they also own the appointment of an authorised representative for EPR (Article 45(3)). Finance owns the fees.

The quantities come from operations. Logistics and the sales ledger supply the tonnage of each packaging material made available in each country, by reporting period. From 1 January 2030, logistics also owns the data for the reuse targets on transport packaging, because the targets fall on the company that uses the packaging (Article 29). Customer service or logistics owns take-back where a country requires it, such as Germany for industrial packaging.

Legal reviews the decisions that turn on interpretation. That covers who is the manufacturer of custom or co-branded packaging, who is the producer when goods cross a border, and whether an exemption applies. It also covers supplier contract terms and mandates for authorised representatives.

Procurement owns supplier requests. Article 16 requires packaging suppliers to give the manufacturer the information and documentation it needs to show conformity. Procurement sends each request against a format and requirement, follows up, and adds PPWR clauses to new supplier contracts.

Leadership approves spending and changes to the product range. Examples are replacing a packaging format that can't meet a requirement, moving to reusable transport packaging before the 2030 reuse targets, and the budget for testing and fees. Agree in advance which decisions need leadership and which the programme owner can take.

Tarnwick's responsibility matrix reads as follows, one role at a time.

The programme owner, the Head of Product Stewardship, holds the plan, agrees the scope and approves the requirement map, and takes any question no one else can close. The packaging engineer is responsible for design evidence and technical documentation for each format. The quality manager is responsible for series production checks and reassessment triggers. The environmental compliance manager is responsible for national registrations and returns, with finance consulted on fees. Logistics is responsible for quantity and reuse data. Procurement is responsible for supplier requests and contracts. Legal is consulted on role decisions, exemptions and mandates. The managing director of the EU company signs the declarations of conformity and approves spending above an agreed limit.

Set escalation rules with dates. A missing supplier document goes from procurement to the programme owner after a set number of days, then to leadership. An unresolved role question goes to legal. When the Commission adopts an act that sets a date, the programme owner reruns the affected rows.

Ownership continues after launch. Each format keeps a named owner. Records are kept for 5 years after single-use packaging is placed on the market, or 10 years for reusable packaging (Article 15(3)), and a national authority's reasoned request must be answered within 10 days (Article 15(10)). Name who answers those requests.