FAQ & compliance

PPWR-Easy assesses every subject-matter question along a fixed source hierarchy:

1. Regulation (EU) 2025/40 and binding delegated and implementing acts.
2. Binding interpretation by the Court of Justice of the European Union (CJEU).
3. Published guidelines, notices and FAQs of the European Commission: not legally binding in themselves, but for PPWR-Easy the authoritative EU-wide harmonised interpretation.
4. Binding national legislation, to the extent it falls within the PPWR's regulatory and transposition scope.
5. National interpretation aids from authorities and registers (e.g. ZSVR/EUNR) as a supplement; they do not override an existing Commission interpretation of the PPWR.
6. Association information, specialist articles and other editorial sources only as a supplement.

Conflict rule:

• A lower-ranking source may only supplement a higher-ranking source, never override it.
• In the event of a contradiction, PPWR-Easy follows the Commission's interpretation as the EU-wide standard assessment and points out the deviation.
• Only the CJEU can interpret Union law with binding effect.
• PPWR-Easy does not provide legal advice.

PPWR-Easy is deliberately affordable – not because we cut corners on quality, security or functionality. Built the traditional way, with large development teams and system integrators, a platform of this scope would likely have incurred development costs of roughly €800,000 to €1,000,000. Powerful AI systems now enable markedly faster and more efficient development. Domain logic, testing and security reviews remain indispensable. We pass this productivity advantage on to our customers instead of maximising the price artificially. Small and larger mid-sized companies therefore get a professional PPWR solution for €79 per month – a very tangible benefit of technological change.

PPWR-easy structures your packaging compliance in one place instead of scattered spreadsheets.

• packaging master data with materials, weights, categories and documents
• supplier management with structured data collection via a secure magic link – no account, no login
• role determination per packaging item and per target market with documented reasoning
• release centre with four-eyes approval for verified packaging units
• packing station for recording packaging volumes actually shipped
• volume reporting and EPR master data per country
• printable material marks and disposal instructions
• PPWR training and the AI assistant Mario for follow-up questions

No. The platform structures data, roles, documents and obligations and documents them traceably. Legally binding assessments in individual cases remain the task of your legal advisers. The answers given by the AI assistant Mario are orientation, not legal advice.

The interface is available in German and English, including the handbook, the training course and the supplier request form. Labelling and disposal texts are always generated in the language of the target market, independently of the interface language.

The legal documents – terms and conditions, privacy policy, imprint and data processing agreement – are legally binding in their German version only.

After registration a setup wizard guides you through the basic configuration in five steps: training, company data, target markets, suppliers and packaging items including assignment. Existing packaging and supplier lists can be imported via CSV; German and English column headers are both recognised.

• Trial: free for 10 days, 1 full seat and 5 packing-station seats, ends automatically without cancellation
• Professional: EUR 79 net per month, 3 full seats and 10 packing-station seats
• Enterprise: EUR 149 net per month, 5 full seats and 30 packing-station seats, plus REST API and custom fields

Annual payment comes with a 10 per cent discount. All prices are net, plus statutory VAT. The current scope of each plan is shown in the pricing section on the home page.

The trial ends automatically after 10 days. No cancellation is needed and no payment method is stored. The data you entered is retained and remains available unchanged after an upgrade.

You sign in exclusively with your business email address and your password. New accounts are activated through a confirmation link sent to the address provided (double opt-in).

Passwords must be at least 10 characters long and contain at least one upper-case letter, one lower-case letter, one digit and one special character. Strength is shown while typing.

Yes. In your account settings you can enable time-based one-time password authentication (TOTP) using an app such as Google Authenticator, Microsoft Authenticator or 1Password. Once enabled, the six-digit code is required at every sign-in.

Not at present. Available options are sign-in with your business email address and password, plus TOTP two-factor authentication. A connection to corporate identity providers via SAML or OpenID Connect is currently not implemented.

• owner: full rights including billing and account deletion
• administrator: management of users, master data and releases
• member: works with master data and requests within the assigned scope
• packing station: reduced access solely for recording volumes at the packing bench

Each plan includes a fixed number of full seats and packing-station seats. If the number is exceeded, surplus accounts are blocked until seats become free again or the plan is extended.

After 30 minutes without activity the session ends automatically; this value can be adjusted in the settings. Independently of that, every session ends no later than 24 hours after sign-in and requires signing in again.

Security-relevant account events – sign-in, account change and password recovery – are logged with a timestamp and are visible to you.

You select packaging items and suppliers and send a request by email. The supplier receives a personal access link to a form where they can enter material data, recycled content, weights and evidence such as data sheets or certificates. No user account is required.

Several articles from the same supplier can be bundled into one request so that everything is answered in a single pass.

Every link contains a randomly generated, single-use token valid only for that specific request. The link expires 14 days after the request is created and is invalidated once the form is submitted. The link only opens that one form – there is no access to your account or to other data.

Uploaded evidence is served through short-lived signed links, not through publicly reachable addresses.

No. Incoming declarations arrive in the release centre and are reviewed there. Only after four-eyes approval do they become the binding data basis for labelling, volume reporting and documentation. Every approval and every later correction is logged.

Yes. Besides material and recycled content, the request templates cover substance restrictions, including REACH status and PFAS in food-contact packaging. The templates can be adjusted.

Yes. The Enterprise plan provides a documented REST API at /api/public/v1. It covers packaging items, suppliers, customers and volume data and ships with an OpenAPI description.

• authentication with an API key as a bearer token that you create in the settings and can revoke at any time
• keys are stored as a hash only and displayed in clear text just once
• fine-grained permissions per key, separated into read and write
• rate limit of 120 requests per minute per key
• idempotency via the “Idempotency-Key” header on write calls; mandatory for bookings
• tenant scope: a key addresses data of your own company only

Yes, in the Enterprise plan. Custom fields can be defined for packaging items, suppliers and customers, marked as mandatory, and are carried through forms, CSV import and export and the API.

Yes. Packaging items, articles and suppliers can be imported via CSV. The import validates the file first, shows a preview with detected errors and aborts in a controlled way on faulty rows instead of writing partial data. German and English column headers are supported.

Yes. Under “My company” in the “Data export” tab you export your core data as a ZIP archive of CSV files – packaging items, suppliers, shipments, configurations and a document index. There is no vendor lock-in.

This export is a customer data export for further use, not an operational backup and not a substitute for your own data protection strategy.

A manually triggered export of selected master data for further use in EUDR processes. It deliberately contains no assessment or audit results, is limited to a fixed field list, is strictly scoped to your company and ships with a SHA-256 checksum per file.

Under the data processing agreement, operation of the platform – including database, file storage and email delivery – takes place in the EU region of the sub-processors used.

The data processing agreement names ISO 27001 certifications held by the sub-processors as one form of evidence. PPWR-easy itself does not hold such a certification.

• transport encryption with TLS 1.2 or higher for all connections
• encryption at rest with AES-256 by the hosting sub-processor (technical and organisational measures of the data processing agreement)
• tenant separation through database-side row-level security; policies and tests protect against cross-tenant access
• role and permission model following the least-privilege principle
• logging of security-relevant account events and traceable logs for approvals and corrections
• daily backups on EU servers as set out in the data processing agreement; recovery window according to the hosting provider's standard

We make no commitment on recovery times, maximum tolerable data loss or periodic restore tests as long as this is not contractually documented.

There is no end-to-end encryption in the strict sense in which even the operator cannot read the content – that would be incompatible with server-side evaluation, search and reporting.

We use sub-processors to run the service. The current list forms part of the data processing agreement and covers in particular platform and hosting operations, the managed database including authentication and file storage, and the delivery of transactional emails.

For payment processing, Google sign-in and the AI assistant, additional services are used whose providers may process data outside the EU. Under the data processing agreement such transfers only take place with appropriate safeguards under Article 44 et seq. GDPR; details are set out in the privacy policy.

We inform you in advance of intended changes to sub-processors in line with clause 7 of the data processing agreement, and you may object.

Yes. The data processing agreement under Article 28 GDPR, including the technical and organisational measures, is concluded digitally in text form and can be downloaded as a PDF. You find it in the settings and on the privacy page. Every acceptance is logged with timestamp and document version; a new version triggers a renewed acceptance request.

No. Your content is not used to train AI models or for other secondary purposes. The assistant Mario draws on the PPWR-easy knowledge base and on the data of your own tenant to answer questions.

The account can be deleted in the settings. This removes the company data and the associated user accounts, except for data we must retain for commercial or tax law reasons, such as invoice records. Export your data before deleting.

We use no advertising cookies and run no personalised advertising tracking. Technically necessary cookies for sign-in, session handling and language selection are required for operation.

Beyond that, the hosting and infrastructure services we use may process operational, security and reach telemetry. This includes, for example, an analytics script served by the hosting platform and the bot-management cookie “__cf_bm” set by Cloudflare. That processing serves secure and stable operation, not advertising.

When you use the payment function or Google sign-in, content from those providers is loaded only if you actually use these features.

The current privacy policy prevails for providers, purposes, legal bases and retention periods.

Paid plans have a minimum term of 12 months. The notice period is one month to the end of the respective term. The free trial ends automatically and does not need to be cancelled. The terms and conditions prevail.

PPWR stands for the Packaging and Packaging Waste Regulation, formally Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste. It replaces the former Packaging Directive 94/62/EC.

Being a regulation, it applies directly in every Member State and does not need to be transposed into national law first. National rules such as the German Packaging Act remain relevant where the regulation expressly leaves discretion to Member States, in particular for the design of extended producer responsibility.

The regulation entered into force in February 2025 and generally applies from 12 August 2026. Many individual obligations phase in later.

• from 2026: general duties, role-specific duties and supply-chain due diligence
• from 2028: labelling duties on material composition and waste sorting
• from 2030: recyclability requirements, first minimum recycled content in plastic packaging, first re-use targets
• from 2035 and 2040: tightened recycling and re-use targets

Exact dates depend on packaging type and sector and are partly specified only by delegated acts. The regulation text always prevails; PPWR-easy helps structure the relevant deadlines but is not legal advice.

It affects you as soon as you make packaging or packaged products available on the EU market – whether you supply consumers or business customers only.

• you fill, ship or sell goods in packaging
• you manufacture or supply packaging or packaging material
• you import packaged goods from a third country into the EU
• you sell packaged goods into another EU country

If any of this applies, you will normally hold at least one role under Article 3 PPWR and therefore concrete obligations. Micro-enterprises benefit from specific exemptions, but not from a general exemption from the regulation.

• direct application in all Member States instead of 27 national variants
• binding technical requirements for the packaging itself (recyclability, recycled content, minimisation)
• precisely defined supply-chain roles, each with its own obligations
• evidence duties via technical documentation and an EU declaration of conformity
• harmonised labelling of material and disposal route

Penalties are set by the Member States; the regulation requires them to be effective, proportionate and dissuasive. In practice consequences range from fines to distribution restrictions and withdrawal orders, up to civil liability towards customers in the supply chain.

The role attaches to the individual packaging item and market, not to the company. An online retailer can be the manufacturer of its self-designed shipping box, a distributor of purchased merchandise and, for shipments to Austria, additionally a producer under extended producer responsibility.

That is why PPWR-easy determines roles per packaging item and per target market and documents the reasoning in a traceable way.

Under Article 3(1)(13) PPWR, a manufacturer is anyone who manufactures packaging or a packaged product, or has packaging or a packaged product designed or manufactured, and markets it under their own name or trademark.

The definition contains an exemption for micro-enterprises: where a micro-enterprise has packaging designed or manufactured under its own name or trademark and the packaging supplier is identifiable, that supplier is deemed the manufacturer under the conditions set out there.

For transport, shipment and e-commerce packaging the supplied condition is decisive: where the packaging is delivered in its final form (pallet, crate, box, ready-made mailer, carton – including flat-packed), the manufacturer of the empty packaging is generally the manufacturer; filling, erecting or an ordinary shipping label do not create that role. Where only packaging material is supplied and the packaging is formed during the packing operation (stretch film on the roll, strapping, tape), the applying company is the manufacturer of the packaging created there.

This point is currently disputed: the European Commission FAQ of 3 August 2026 treats stretch film on the roll as finished packaging, whereas ZSVR/EUNR and the IK customer information of 20 August 2026 classify it as packaging material. The Commission FAQ is not legally binding and does not amend Regulation (EU) 2025/40. PPWR-Easy therefore relies on the recorded "supplied condition / final form" attribute and keeps unresolved cases visible.

Main duty of the manufacturer: ensure and demonstrate that the packaging complies with the regulation, via technical documentation and an EU declaration of conformity. Whether you are the manufacturer in a given case depends on whose name or trademark is used for marketing and who commissioned design or manufacture.

Article 3(1)(15) PPWR defines the producer in several sub-cases (points a to e). What they share is that someone makes packaging or packaged products available in a given Member State for the first time on a professional basis. The role is assessed separately per Member State.

• point a: manufacturers, importers or distributors established in that Member State who first make transport packaging, service packaging, reusable packaging or primary production packaging available there
• point b: anyone who professionally unpacks goods in that Member State without being the end user, where the resulting packaging is not already covered by another sub-case
• point c: operators established in that Member State who first make other packaged products available there on a professional basis
• point d: operators from another Member State or a third country supplying end users in that Member State directly by distance sales
• point e: the corresponding constellation for packaging filled outside the Member State and first made available there

Main duties: registration in the national packaging register, regular volume reporting and financing of collection and treatment. Which sub-case applies must be assessed per market and packaging type; national implementation of extended producer responsibility may differ.

An importer is a person established in the EU who places packaging or packaged products from a third country on the EU market.

Main duties: verify before placing on the market that conformity assessment, labelling and documentation exist, keep the records and provide their own contact details. Frequently – though not necessarily in every case – the producer role in the target market applies in addition.

A distributor is any operator in the supply chain other than the manufacturer or importer who makes packaging or packaged products available on the market.

Main duty: verify with due care that upstream operators have met their obligations – in particular labelling, declaration of conformity and registration. Anyone who modifies packaging, or markets it under their own name or trademark, in such a way that the manufacturer definition is met carries the manufacturer's duties.

A supplier is anyone who supplies packaging or packaging material to a manufacturer.

Main duty: provide the manufacturer with all information and records needed for conformity assessment – for example material composition, recycled content, recyclability and information on substance restrictions.

Fulfilment service providers offer warehousing, picking, packing and dispatch services for third parties. They are economic operators in their own right under Article 3 PPWR, but they do not automatically carry the duties of a manufacturer or producer.

Classification is case-specific and follows the contractual arrangement, whose name or trademark the packaging is marketed under, and the definitions in Article 3(1)(13) and (15). Merely selecting the box and cushioning material does not in itself necessarily create the manufacturer role.

For extended producer responsibility, Article 44 PPWR governs the appointment of an authorised representative in the Member State where a producer first makes packaging available without being established there. This typically concerns distance sales from another Member State.

For producers established in a third country, Article 45 PPWR adds further requirements. In both cases Member States retain discretion, in particular over registration, evidence and procedures. Whether and how an appointment is required must therefore be checked per target market; no blanket statement covering all third-country sellers is possible.

Anyone who purchases packaged goods purely for their own use and does not pass them on acts as an end user and to that extent carries no economic-operator duties. As soon as the goods or the packaging are passed on, resold, professionally unpacked or used to ship your own products, a role of your own may arise – this must be assessed case by case.

• restriction of substances of concern, including heavy-metal limits and PFAS restrictions in food-contact packaging
• recyclability based on design criteria
• minimum recycled content in plastic packaging
• minimisation of weight, volume and empty space
• labelling of material and disposal route
• requirements for re-use and refill systems

Packaging counts as recyclable if it is designed for recycling and can be separately collected, sorted and processed into secondary raw materials. Assessment uses performance grades.

From 1 January 2030 – or 24 months after the relevant delegated act enters into force, if that is later – packaging may only be placed on the market if it reaches at least grade C. From 1 January 2038 at least grade B is required.

The critical cases are hard-to-separate composites, disruptive additives, full-body sleeves and non-removable labels.

Plastic packaging is subject to staggered minimum shares of post-consumer recycled content from 2030, rising again in 2040. The level depends on the packaging type; food-contact and contact-sensitive packaging have their own values, and narrow exemptions exist.

Evidence comes from upstream supplier declarations. PPWR-easy collects these in a structured way through a supplier request sent as a secure magic link – no account and no login – and documents them per packaging item.

Packaging must be reduced to the minimum needed for function and safety. From 2030 an empty-space ratio of no more than 50 per cent applies to grouped, transport and e-commerce packaging. Filling material does not count as used volume.

Packaging will carry harmonised labelling on material composition that supports separate collection. The Commission sets the details in implementing acts; for most packaging the duty applies from 2028.

PPWR-easy generates material marks and disposal instructions per packaging item and provides them ready to print – in the language of the target market.

Only in clearly limited cases. Article 9 PPWR requires compostability across the Union only for a few packaging types, such as stickers on fruit and vegetables and – subject to the conditions in that provision – certain tea bags, coffee pads and coffee capsules.

There is no Union-wide compostability obligation for very lightweight plastic carrier bags; Member States may, however, require them to be compostable where separate bio-waste collection exists. For all other packaging, material recycling is the required route.

For certain sectors – including B2B transport and sales packaging, beverages and e-commerce shipping packaging – binding re-use targets apply from 2030 and rise in 2040. Reusable packaging must be part of a functioning return and refill system; the regulation provides exemptions for individual sectors.

• technical documentation per packaging item demonstrating compliance
• the manufacturer's EU declaration of conformity
• supplier declarations and evidence on material, recycled content and substance restrictions
• EPR registration numbers per Member State and the corresponding volume reports

These records must be presented to market surveillance authorities on request and retained for the prescribed period.