NEW RULES BAG EUROPE’S PPWR REACHES SEED PACKAGING, BRINGING NEW RESPONSIBILITIES FOR COMPANIES INSIDE THE EU AND EXPORTERS SUPPLYING THE EUROPEAN MARKET. BY: MARCEL BRUINS O n 12 August 2026, the European Union began applying its new Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, commonly known as the PPWR. For seed companies, this is not simply a regulation aimed at bottles, food containers and consumer packaging. Seed packets, paper sacks, polypropylene bags, boxes, drums, liners, big bags, pallets and other packaging used to contain, protect, handle or deliver seed can all fall within its scope. That does not mean every seed company had to replace its packaging on 12 August. Many of the PPWR’s most significant design requirements will not take effect for several years, while others still depend on secondary EU legislation. Nevertheless, packaging is becoming another part of the broader sustaina bility responsibilities of seed companies, an evolution already visible in how companies are addressing their environmental footprint across production, facilities and supply chains. The practical task now is to establish who carries which responsibility, understand what packaging the company places on the European market, assemble the necessary information and documentation, and start preparing packaging formats for the requirements approaching later this decade. FIRST ESTABLISH YOUR ROLE One of the more confusing aspects of the PPWR is that famil iar terms such as manufacturer and producer have specific legal meanings. A manufacturer is not necessarily the company that physically makes an empty seed sack. Depending on the commercial arrangement, a seed company that has packaging produced for its products and places the packaged seed on the market under its own name or trademark can itself be consid ered the manufacturer for PPWR purposes. A producer, meanwhile, is primarily the party carrying extended producer responsibility, or EPR, in the Member State where the packaging is first made available and is expected to become waste. An importer is an EU established company placing packaging or packaged products from a third country on the EU market. The European Commission’s June 2026 guidance on the PPWR provides detailed explanations of these economic operator roles. These distinctions are particularly relevant in a sector where seed frequently crosses several borders before reaching the farmer. As Seed World Europe recently explored in its cover age of new EU trade agreements and their implications for seed movement, a variety may be bred in one country, multiplied in another, processed elsewhere and marketed across several des tinations. PPWR responsibilities therefore need to be mapped against the actual supply chain rather than simply assigned to whichever company bought the packaging. Consider a U.S. grass seed company selling seed in its own branded 25 kg polypropylene bags to a French importer. The U.S. company could have manufacturer responsibilities con cerning the packaged product, while the French business has separate obligations as importer and may also become the rele vant producer for EPR purposes in France. Direct sales from a non-EU company to European end users can produce a different allocation of responsibilities, including possible requirements concerning an authorised representative. WHAT COMPANIES NEED TO ADDRESS NOW Manufacturers need to determine which PPWR requirements already apply to their packaging and ensure conformity with those provisions. Depending on the packaging and the compa ny’s role, this includes conformity assessment, technical docu mentation, an EU declaration of conformity and identification of the manufacturer. Importers have their own obligations, including verifying that required conformity procedures and documentation have been completed and providing importer identification information. Companies should not, however, interpret 12 August 2026 as the date on which every future PPWR requirement sud denly became mandatory. The harmonised material composition labelling system, for example, is scheduled for later implementa tion, and the detailed criteria governing several other provisions are still being developed. The Commission’s updated PPWR IN THE 56 I SEED WORLD EUROPE I SEEDWORLD.COM/EUROPE | OCTOBER 2026 Seed bags may look unchanged, but their regulatory status is changing. Under the EU Packaging and Packaging Waste Regulation, companies need to consider not only the material used, but also who places the packaging on the market, where it becomes waste and how future recyclability, recycled content and reuse requirements could apply.
View this content as a flipbook by clicking here.