AUTHOR: GUNTER VAN HOOF, VP, GLOBAL CTD & PACKAGING SOLUTIONS

Marken, UPS Healthcare Precision Logistics, is aware of its obligations under Regulation (EU) 2025/40 on Packaging and Packaging Waste (PPWR), which becomes generally applicable on 12 August 2026.

To support compliance, Marken has established a cross-functional program involving Packaging, Procurement, Legal, and Sustainability teams and is actively working with packaging suppliers. Our immediate focus is on Marken-branded and Marken-provided packaging subject to the PPWR, ensuring that required compliance documentation is available and can be provided promptly when requested by clients, customs authorities, or market-surveillance authorities.

Marken's Compliance Responsibilities

Where Marken qualifies as the manufacturer under the PPWR, we are establishing and maintaining the required documentation to demonstrate conformity, including, where applicable:

• Completion of applicable conformity assessments
• Preparation and retention of technical documentation
• Issuance and maintenance of the required EU Declaration of Conformity
• Supporting material, composition, testing, and compliance records, including evidence that substances of concern have been appropriately assessed and minimized and that the combined concentration of lead, cadmium, mercury and hexavalent chromium does not exceed 100 mg/kg. subject to any applicable exemptions
• Manufacturer identification and packaging traceability information
• Processes for addressing non-conformities and supporting regulatory authorities

The specific responsibilities under the PPWR depend on the packaging and supply chain arrangement. For client-owned, client-specified, or third-party packaging, responsibility for compliance documentation may remain with the client or another economic operator. Marken is available to help clarify roles, responsibilities, and documentation requirements.

Requesting PPWR Documentation

If a customs broker, market-surveillance authority, or other competent authority requests PPWR documentation related to Marken-provided packaging, Marken will coordinate the provision of the applicable EU Declaration of Conformity and supporting documentation, as required.

The PPWR provides a 10-day response period following a reasoned request from a competent authority. Timely notification to Marken is therefore essential to ensure the relevant packaging can be identified and the required documentation provided within the regulatory timeframe. To streamline this process, please direct all PPWR documentation requests to:        packaging.compliance@marken.com.

When submitting a request, please include, where available:

• Authority or customs request details
• Shipment or AWB reference
• Packaging type or SKU
• Country of import
• Date of the request
• Documentation requested

This contact should also be used for any questions regarding packaging responsibility, Marken's role under the PPWR, or documentation ownership.

Marken remains committed to working closely with suppliers, clients, and internal stakeholders to maintain an effective PPWR compliance program and help ensure the uninterrupted movement of critical healthcare shipments.