How should packaging makers write PPWR and environmental claims?
On a packaging manufacturer’s website, packaging sold in the EU comes with the EU declaration of conformity the PPWR requires, the BRCGS Packaging Materials certificate if there is one, and environmental claims whose scope is stated clearly. The Packaging Regulation (2025/40) has applied since August 12, 2026; an environmental claim may be made only for a property beyond the legal minimum and with a statement of what it covers.
Packaging does not appear as a separate row in TİM’s sector table; it entered the cluster with its own guide because its regime is different. This guide is the detail of the packaging row of the certificate map by sector; the general rules for environmental claims are in the environmental claims on a website guide.
Which document does a packaging buyer ask for?
For a manufacturer selling packaging to the EU, the buyer’s question now comes from a regulation. The Packaging and Packaging Waste Regulation (PPWR, 2025/40) entered into force on February 11, 2025 and has applied since August 12, 2026 (Art. 71). Before packaging is placed on the market, the regulation requires a conformity assessment, technical documentation and an EU declaration of conformity (Art. 15); these documents are kept for 5 years for single-use packaging and 10 years for reusable packaging.
A buyer may also ask for a certificate covering production itself: BRCGS’s standard for packaging materials (Packaging Materials) is in its 7th edition today, and certified sites are searched in the BRCGS Directory. How certificates generally belong on a website is covered in the certified manufacturer website guide; this page describes in detail the two topics specific to packaging, the declaration of conformity and the environmental claim.
How are the declaration of conformity and the certificate shown on the website?
The declaration of conformity is a document tied to a packaging type: on the site, either the declaration itself sits on that packaging type’s page, or the site says how to request it. A single general compliance file does not say which packaging type was declared against which requirements. For the BRCGS certificate, the site writes the certified site and the path to its Directory record; in a company with several sites, the certificate stands with the site it belongs to, together with the site code.
How is an environmental claim written for packaging?
By the PPWR’s own rule. Under Article 14 of the regulation, an environmental claim may be made only for a property beyond the legal minimum, and it states whether the claim covers the whole packaging unit, a part of it, or all the packaging the company places on the market. So a property the law already requires cannot be the subject of an environmental claim, and a claim whose scope is not stated also falls foul of the rule. The regulation also prohibits misleading labels about the packaging’s material or properties (Art. 12(8)).
If the sale also reaches consumers, two more rules come into play. In Turkey, according to the Advertising Board’s guide, general phrases such as “recyclable”, “environmentally friendly” or “eco” may not be used without explanation; the claim states which life-cycle stage it covers and how it was measured (Art. 5(4)). In the EU, since September 27, 2026, a general environmental claim without recognized excellent environmental performance, and a claim about the whole product when it is valid for only one aspect, are unfair in all circumstances in business-to-consumer commerce.
| Item | On the website | Basis |
|---|---|---|
| EU declaration of conformity | Yes; the declaration itself or how to request it, with the packaging type | PPWR Art. 15 |
| BRCGS Packaging Materials certificate | If certified; with the certified site and Directory record | BRCGS |
| Environmental claim | For a property beyond the legal minimum; with its scope | PPWR Art. 14 |
| Environmental claim without a stated scope | No | PPWR Art. 14 · Advertising Board guide Art. 5(4) |
| Misleading label or mark | No | PPWR Art. 12(8) |
Where declarations belong on a packaging website
- 01EU declaration of conformity
- 02BRCGS Packaging Materials certificate
- 03Environmental claim, with its scope
- 04Environmental claim without a stated scope
- 05Misleading label or mark
What should a packaging website not say?
- An environmental claim without a stated scope: the packaging unit, a part of it, or all packaging?
- Presenting a property the law already requires as environmental superiority.
- A misleading label or mark about the packaging’s material or properties.
- Extending the BRCGS certificate to the products of a site that is not certified.
- Showing all packaging types as declared with a single general conformity file.
What changed in packaging in 2026?
The PPWR started to apply on August 12, 2026. The Commission’s Environmental Omnibus proposal (COM(2025) 982) only proposes suspending the authorized representative obligation for direct sales to consumers in another member state; Parliament voted on October 20, 2026, the file is in negotiation, and the August 12, 2026 date has not changed. So a sentence on the site like “the PPWR has been postponed” is wrong.
The next date is the harmonized material label: under Article 12, from August 12, 2028, or 24 months after the implementing acts, whichever comes later. The label’s format will be settled by those acts; in our reading, saying on the site “compliant with the new EU label” is premature today.
How does a buyer verify the documents?
Depending on the type of document. The BRCGS certificate is searched in the BRCGS Directory; verification requires a free “Directory Lite” account. The EU declaration of conformity is the manufacturer’s own declaration: the buyer matches the packaging type in the declaration with the product they bought, and asks for the technical documentation if needed. Accredited management system certificates can be searched in CertSearch; the four-step path is in the is a company’s ISO certificate real guide.
How are the product page and the machine layer built?
The page for a packaging type carries its material, its dimensions or capacity and the link to the declaration of conformity in a table; if there is an environmental claim, it sits in the same table together with its scope. The measurement or document the claim rests on should be one click away from the page; a claim whose basis cannot be seen leaves the buyer with a sentence they cannot verify.
In the machine layer, the certificate can be marked up as a Certification identical to the record visible on the page, knowing that Google does not use this markup for packaging: Google supports certification markup only in merchant listings, for the EU energy label and vehicle CO2 classes. Adding a certificate to the markup that the page does not state tells neither the buyer nor the machine anything true.
A short checklist for a packaging website
- Is each packaging type’s declaration of conformity on the site, or is it written how to request it?
- Are environmental claims made for a property beyond the legal minimum?
- Is the scope of each environmental claim (unit, part, all packaging) written?
- Is the BRCGS certificate shown with the certified site and Directory record?
- Is there a potentially misleading material label or mark on the site?
- Is an unexplained general environmental phrase left on pages that reach consumers?
- Is the retention period of the conformity documents (5 or 10 years) known?
The information here is not legal advice; confirm which rule applies to you from official sources and from your certification body’s current requirements.
Let’s read how your conformity and environmental claims appear on your site together: in a free preliminary review we send a written note on which claim has its scope written.
Request a free preliminary review
For a site that shows your certificates as a record buyers can verify, B2B website builds and measures the certificate page, the product scope and the path to a quote together.
FREQUENTLY ASKED QUESTIONS
When did the PPWR start to apply?
On August 12, 2026. The regulation had entered into force on February 11, 2025; the Environmental Omnibus proposal did not change this date.
How is an environmental claim made for packaging?
Under PPWR Article 14, only for a property beyond the legal minimum, and stating whether the claim covers the packaging unit, a part of it, or all the company’s packaging.
When does the harmonized material label become mandatory?
From August 12, 2028, or 24 months after the implementing acts, whichever comes later.