The law is live but not all at once
Regulation (EU) ****/** entered into force on February **, ****, and has generally applied since August **, ****. It covers packaging and packaging waste regardless of material or origin, bringing the packaging surrounding EU-bound garments firmly into scope.
Yet August ** did not trigger every PPWR requirement. The European Commission’s June guidance acknowledged a “significant number” of questions from stakeholders and Member State authorities, an indication of the complexity facing economic operators.
For apparel supply chains, the distinction matters. Manufacturers must meet applicable conformity and technical-documentation requirements, while EU importers must verify that relevant conformity procedures have been completed. Suppliers are also required to provide manufacturers with information needed to demonstrate compliance. A non-EU garment factory is therefore not automatically the legally responsible EU importer or EPR producer, but EU buyers can push packaging-data requirements upstream through sourcing contracts.
