The EU Packaging and Packaging Waste Regulation (PPWR) introduces changes to packaging design requirements and extended producer responsibility rules that also affect businesses in the optical sector, regardless of company size or packaging volumes.
The new EU Packaging and Packaging Waste Regulation (PPWR) became applicable in Finland on 12 August 2026. The regulation establishes criteria for packaging characteristics and defines the manufacturer responsible for ensuring compliance. It also partially revises the way a packaging producer is defined, including liability for Extended Producer Responsibility (EPR) obligations.
Jukka Ropponen, Director of Public Affairs at the Federation of Finnish Special Commodity Trade ETU, emphasizes that the regulation applies to all operators in the optical sector, including the smallest businesses.
“Many small optical businesses may have assumed that producer responsibility did not apply to them because of their limited packaging volumes. This is no longer the case. The turnover threshold was already abolished in 2024, and PPWR now introduces additional obligations for these operators. Company size or packaging quantity is no longer a valid reason to remain outside the scope of the requirements.”
The packaging manufacturer is responsible for compliance
In the optical sector, the regulation typically concerns three types of packaging:
- Sales packaging, such as eyeglass cases, lens cleaning cloth packages, contact lens blister packs, and solution bottles.
- Grouped packaging, meaning packaging that combines several products for retail logistics purposes.
- Transport packaging, such as cardboard boxes and other packaging used to deliver products from wholesalers or importers to stores, or directly to consumers.
“A key requirement guiding packaging design is that all packaging must be recyclable by 2030. For example, plastic packaging must gradually incorporate increasing proportions of recycled plastic content in packaging materials,” says Ropponen.
The EU will also introduce harmonized packaging labels that must be used on both new and existing packaging. In addition, transport and grouped packaging will be subject to restrictions on packaging volume and empty space, with a maximum of 50% empty space permitted.
Responsibility for ensuring and documenting packaging compliance lies with the manufacturer or commissioning party. For sales and grouped packaging, the manufacturer is normally the operator that completes and fills the packaging before placing it on the market.
For transport and service packaging, the manufacturer is generally the party that physically produces the packaging, or the company that commissions it under its own brand.
Producer responsibility and the definition of a producer in the optical sector
Every package must have a designated producer that carries the obligations of Extended Producer Responsibility (EPR). The producer must organize and finance the collection, waste management, and recycling of used packaging, and annually report the materials and quantities of packaging placed on the market.
As a general rule, the producer is the operator that first places the packaging or packaged product on the market. Consequently, responsibility may lie not only with a manufacturer, but also with another actor in the supply chain.
In the optical sector, the producer may in practice be:
- An importer or manufacturer of spectacle frames, sunglasses, or contact lenses.
- A packer or importer of contact lens solutions and other optical care products.
- An optician’s store, to the extent that it packages products itself, for example in-store.
- An online retailer or foreign distance seller that supplies packaged products directly to Finnish consumers.
The PPWR requirements may naturally lead to additional costs for businesses. These costs may arise from redesigning packaging to meet recyclability and over-packaging requirements, as well as updating packaging labels and related printing expenses.
As a packaging producer, an optical sector company is generally required to join a producer responsibility organization that manages the practical collection and recycling of packaging on its behalf. The company’s responsibilities then include annual reporting of packaging volumes and payment of recycling fees, which producer responsibility organizations determine based on the reported data.
In Finland, companies can choose between two packaging producer responsibility organizations: Suomen Pakkaustuottajat Oy and Sumi Oy.
PPWR Checklist for Businesses in the Optical Sector
- Determine your role for each type of packaging individually. Assess whether you qualify as a producer under PPWR for the sales, grouped, and transport packaging you handle.
- Review your packaging portfolio for material composition, recyclability, possible over-packaging, and excessive empty space.
- Update packaging labels according to the PPWR implementation timetable.
- If you sell packaged products directly to consumers in another EU Member State, determine whether you need an authorized representative.
- Ensure that your company is registered with a packaging producer responsibility organization.
- Monitor the phased implementation of PPWR requirements, national enforcement measures, and any future clarifications or guidance.
