PPWR Packaging Change Control — A Decision Table on Whether Reassessment Is Needed When a Label, Adhesive or Supplier Changes

Key takeaway — Change control asks two questions: ‘what has changed’ and ‘can it affect compliance’. Article 15(4) requires reassessment under the Article 38 procedure where compliance may be affected, and Article 39(2) requires the declaration to be kept continuously up to date. Impact can only be judged by comparing the before and after specifications, not the name of the change (‘design revision’).

This article is based on Regulation (EU) 2025/40 (PPWR) and Commission Notice C/2026/3084 (implementation guidance), as checked on 6 October 2026. For the specification sheet that records the pre-change specification, see packaging specification sheet and supplier document requests, and for the declaration to be revised after a change, see the EU declaration of conformity guide.

Compare before and after specifications rather than the name of the change

Article 15(4) requires the manufacturer to have procedures in place so that series production of packaging remains in conformity with the Regulation, to take due account of changes in packaging design or characteristics and of changes in the harmonised standards, common specifications or other technical specifications applied, and to carry out a reassessment under the Article 38 conformity assessment procedure where it considers that compliance may be affected. To check whether a material or adhesive layer change is hidden under the heading ‘design revision’, record the following on the change request.

This request form is our own working format. It does not replace statutory technical documentation; it is used as the input needed for the impact review.

Impact decision table by change type

The requirements that may be affected differ for each packaging, and not every requirement applies right now. The table below is our own proposal summarising, by change type, which requirements' evidence needs revisiting.

Section 6 of the Commission guidance explains that the recyclability principle in Article 6(1) applies from 12 August 2026, that the design-for-recycling criteria in Article 6(2)(a) apply from 1 January 2030 or 24 months after the delegated act enters into force, whichever is later, and that until the delegated act enters into force there is no need to carry out the conformity assessment under Article 38 and Annex VII for recyclability. So do not close the before-and-after assessment on the strength of a supplier's ‘recycled material’ wording alone, but do not assume either that detailed criteria not yet applicable must be assessed now.

Fictional example: changing the adhesive on a removable label

This is a fictional example for illustration. Suppose the removable label on a household product bottle is kept but only the adhesive supplier changes. Even if the label size and printing are the same, check the new specification and evidence for any difference in separation conditions or the material to which it applies. If the existing report covered the old adhesive, a review is needed as to whether the data support the new combination. This example does not mean that an adhesive change always requires a specific test; the assessment method and whether further testing is needed are decided by the impact judgement.

Check that the technical documentation and the declaration cover the right subject

Point 2 of Annex VII requires the technical documentation to include a description of the packaging, design and manufacturing drawings and component materials, a list of the standards and specifications applied, and test reports, and point 3 requires the manufacturing process and its monitoring to ensure conformity with the technical documentation and the requirements. When there is a change, compare the drawings, materials and assessment evidence with the actual order specification and, where needed, reflect new evidence and reassessment results. Because the declaration must also be kept continuously up to date under Article 39(2), confirm the packaging covered and the content of the change.

Changing only the modification date of a document file is no substitute for the review. Recording the reason for and impact of the change, the evidence used and the parts updated lets the scope of the earlier judgement be found at the next change.

Link document versions to stock, orders and shipments

Where old-specification stock and new-specification receipts overlap, link the documents to each shipping configuration. Marking in internal records and in the material sent to the importer from which order or lot the changed packaging is used reduces the mixing of two versions under the same product name. Article 18(2) requires the importer to verify the manufacturer's technical documentation and accompanying documents before placing on the market, so record which version was delivered to the importer as well.

Whether stock may be supplied is judged by the relevant requirement, the time of placing or making available on the market and the transitional provisions. Article 15(8) requires the manufacturer that considers packaging it has placed on the market not to comply with the applicable requirements to take corrective measures, withdrawal or similar immediately and to inform the market surveillance authorities, and paragraph (9) provides an exception for reusable packaging placed on the market before 11 February 2025. Do not assume that stock is always permitted, or that it must all be destroyed, merely because it is stock.

Completion criteria: five things to close before the next order

• Have the before and after specifications been identified at part number and revision date level?
• Have the conclusion and evidence of the impact review been recorded?
• Has the new evidence needed been obtained, or the reassessment completed?
• Do the technical documentation and the declaration point to the post-change specification?
• Is the version marked on the applicable order or lot and on the material sent to the importer?

Change procedures for human-use medical devices are covered in the medical device change approval, change certification and change notification guide and assessing the scope of a model addition change. If medical device packaging changes, handle that change control and PPWR change control in the same change record.

Common misunderstandings

Documents that speed up the review if prepared before enquiring

• Before and after specifications (part number, material, adhesive, weight, drawing revision date)
• Reason for the change and the order in which it is planned to apply
• Current list of technical documentation and declaration version
• Specification covered by existing test reports

Please mention PPWR packaging in your message when you use the PPWR change review enquiry. Based on the documents you hold, we will indicate the impacts and document scope needing further confirmation. The scope and cost of the review are advised individually after we have confirmed the packaging configuration and the content of the change.

Prepared and sources checked: 2026-10-06. Sources: Regulation (EU) 2025/40 recital 14, Article 3(1)(13), Article 6(9), Article 15(4) to (9), Article 16, Article 18(2) and (3), Article 21, Article 39(2), Annex VII points 2 and 3 · Commission Notice C/2026/3084 Section 6 (timing of recyclability application). The change request form, decision table, completion criteria and fictional example are our own practical tools and do not replace a compliance judgement on individual packaging.