Packaging and Packaging Waste Regulation (PPWR)

SEG Automotive Statement on PPWR Regulation (EU) 2025/40

• Introduction
• Company Identification and Product Portfolio
• Roles under the PPWR
• Packaging Categories and EU Declarations of Conformity
• Extended Producer Responsibility (EPR) Registrations
• PPWR Contact Information
• Ongoing Implementation and Commitment

1. Introduction

SEG Automotive operates globally and is committed to meeting the applicable requirements of Regulation (EU) 2025/40 on packaging and packaging waste, commonly referred to as the Packaging and Packaging Waste Regulation or PPWR, for packaging and packaged products placed or made available on the European Union market.

SEG Automotive is implementing the requirements applicable from 12 August 2026 across its relevant packaging portfolio and supply-chain flows, including the determination of the applicable economic-operator roles. In parallel, SEG Automotive is progressively preparing for subsequent PPWR milestones and related implementing or delegated acts.

This implementation approach addresses, in particular:

• Packaging sustainability and labelling: Articles 5 to 12
• Economic-operator obligations: Articles 15 to 21
• Conformity assessment and EU Declaration of Conformity: Articles 38 and 39
• Producer registration and extended producer responsibility: Articles 44 and 45

2. Company Identification and Product Portfolio

SEG Automotive operates internationally. The scope of this statement is limited to the application of the PPWR to packaging and packaged products placed or made available on the European Union market.

Sales Entities:

• SEG Automotive Germany GmbH, Stuttgart, Germany
• SEG Automotive France SAS, Drancy, France
• SEG Automotive Italy S.r.l., Torino, Italy

Production Entities:

• Starters E-Components Generators Automotive Hungary Kft., Szirmabesenyő, Hungary
• SEG Automotive Spain S.A.U., Treto, Spain

Product Portfolio

SEG Automotive supplies automotive components and systems to Original Equipment (OE) market, Original Equipment Service and Independent Aftermarket, including electrical machines, starting and power-generation systems, electrification solutions and remanufactured products. SEG Automotive also supplies drive-system solutions for light electric mobility applications.

3. Roles under the PPWR

Under the definitions in Article 3 of Regulation (EU) 2025/40, a SEG Automotive legal entity may act as manufacturer, importer and/or producer, depending on the packaging concerned and the relevant supply-chain flow.

The roles shown below describe the roles currently identified within SEG Automotive’s PPWR implementation scope. The applicable role is assessed on a case-by-case basis, taking account of factors including the packaging design and branding, the entity placing or making the packaging available on the market, the origin of the packaging and the Member State concerned.

Entity — PPWR Role — Legal basis:

• SEG Automotive Germany GmbH — Manufacturer, Importer, Producer — Article 3(13), (15), (18)
• SEG Automotive France SAS — Producer — Article (18)
• SEG Automotive Italy S.r.l. — Producer — Article (18)
• Starters E-Components Generators Automotive Hungary Kft. — Manufacturer, Importer, Producer — Article 3(13), (15), (18)
• SEG Automotive Spain S.A.U. — Manufacturer, Importer, Producer — Article 3(13), (15), (18)
  
  
  
  

4. Packaging Categories and EU Declarations of Conformity

SEG Automotive predominantly uses transport packaging to protect, handle, store and deliver automotive components and systems.

Packaging is classified according to the applicable material categories in Annex II, Table 1, of Regulation (EU) 2025/40. Where SEG Automotive acts as the manufacturer, EU Declarations of Conformity are drawn up in accordance with Articles 38 and 39 and Annex VIII. The declarations are organized by Annex II material category, with each declaration defining the specific packaging types, references or packaging families within its scope.

Single-use and Reusable Packaging

SEG Automotive uses both single-use and reusable transport packaging across its supply-chain flows. Single-use packaging is intended for one packaging cycle, while reusable packaging, including returnable containers, pallets, boxes, dividers, inserts and intermediate layers, is designed for multiple uses within an appropriate reuse system.

The applicable responsibilities are determined according to the packaging design, ownership, branding, reuse system and relevant supply-chain arrangement.

5. Extended Producer Responsibility (EPR) Registrations

In accordance with Articles 44 and 45 of Regulation (EU) 2025/40 and applicable national packaging legislation, SEG Automotive entities register and participate in the relevant national extended producer responsibility arrangements where they meet the applicable producer definition.

Entity — EPR registration/ participation:

• SEG Automotive Germany GmbH — ZVSR (LUCID)
• SEG Automotive France SAS — CITEO Pro
• SEG Automotive Italy S.r.l. — CONAI
• Starters E-Components Generators Automotive Hungary Kft. — MOHU
• SEG Automotive Spain S.A.U. — MITECO

6. PPWR Contact Information

Please contact the SEG Automotive PPWR Coordination Team ( [Opens in a new tab] Packaging-Communication@seg-automotive.com) for inquiries concerning:

• the PPWR role applicable to a specific SEG Automotive supply-chain flow
• packaging conformity documentation
• EU Declarations of Conformity
• supporting technical documentation
• EPR registration information

Alternatively, inquiries may be addressed to the relevant SEG Automotive legal entity listed above.