Facts & News on the EU Packaging Regulation (PPWR)

The new EU Packaging and Packaging Waste Regulation (PPWR) is a European Union regulation covering packaging and packaging waste placed on the market in Europe.

It officially entered into force on February 10, 2025, and will become fully applicable after an 18-month transition period, starting August 12, 2026. From that date onwards, businesses like yours will face new obligations that you should be aware of to avoid sanctions and ensure compliance.

Together with our partner  Lizenzero, we’ll break down what the PPWR entails and what its new requirements may mean for you as a business owner.

What is behind the PPWR?

At its core, the PPWR aims to minimize the negative impact of packaging and packaging waste on the environment across the EU. In addition to promoting a sustainable circular economy and reducing waste, the regulation also reinforces Extended Producer Responsibility (EPR) — putting more accountability on manufacturers and distributors of packaging.

Why do we need the PPWR?

Currently, the EU Packaging Directive 94/62/EC applies. While it already introduced measures to reduce the environmental impact of packaging, each member state has implemented it differently. This has created a patchwork of national rules and laws, making compliance more complex for businesses operating cross-border.

Moreover, the directive’s measures are not far-reaching enough. Packaging waste continues to increase both in the EU and globally.

The PPWR, on the other hand, is a regulation, meaning its provisions will apply uniformly across all EU member states, leaving less room for interpretation. On top of that, the requirements will be stricter than before.

Which role(s) does your business play?

The PPWR defines several roles (actors) with different sets of obligations. Knowing which role(s) apply to your business is crucial for compliance.

Here’s a quick overview:

• Producer: A company that manufactures packaging or packaged products (or has them manufactured) and sells them under its own brand.
  Example: A firm has chocolate bars produced in Italy and sells them under its own brand in Germany → Producer.
  
  
• Manufacturer: A broader term that includes producers, importers, and distributors once they place packaging on a member state’s market. This often applies to (online) retailers.
  Example: A German retailer imports French wine in bottles and sells it in Germany → Manufacturer.
  
  
• Supplier: Supplies packaging or packaging materials to a producer.
  Example: A carton producer sells shipping boxes to an online retailer.
  
  
• Importer: An EU-based company bringing packaging from a third country (outside the EU) into the EU market.
  Example: An Italian firm imports packaged goods from China.
  
  
• Distributor: Any company in the supply chain that makes packaging or packaged products available on the market (unless they qualify as producer or importer).
  Example: A wholesaler buying goods from manufacturers and reselling them to retailers.

Important: Fulfillment service providers are also subject to new PPWR obligations. They must verify whether their clients meet their responsibilities — if not, they must terminate the partnership.

How PPWR goals impact your business

The PPWR applies to all companies introducing packaging to an EU country, distributing it within the EU, or manufacturing it. Beyond waste management and recycling responsibilities (already common in most EU states), the regulation introduces new, concrete sustainability requirements. Let’s look at the most relevant ones:

Reduction of packaging waste & reuse

From 2030, producers and importers must ensure that packaging is designed to minimize weight and volume, according to Article 10. For your business, this may require adjusting packaging sizes to better match product dimensions.

Article 11 also emphasizes reuse. Shipping packaging, for example, should be designed so it can also be used for returns.

Recycled content in packaging

Article 7 of the PPWR addresses the minimum recycled content in plastic packaging. Recyclates are raw materials obtained from reprocessed plastic waste, which can be used in the production of new plastics or packaging.

From 2030 onwards, all plastic components of packaging placed on the market must contain a certain percentage of recycled material. The required share depends on the type and intended use of the packaging and is calculated as an annual average per packaging type, format, and production site. Compostable plastic packaging and packaging with less than 5% plastic content are exempt from this rule.

In addition, the PPWR sets out new criteria for the recyclability of packaging, applicable from 2023. These requirements (summarized under the term “Design for Recycling”) cover aspects such as the use of additives and adhesives, as well as the composition of labels, coatings, and printing inks.

Labeling obligations

According to Article 12, packaging will need to feature clear information on recyclability and disposal. Some countries (e.g. France, Italy) already require this. A harmonized EU label is expected to become mandatory on August 12, 2028.

Declaration of conformity

From August 12, 2026, companies must issue declarations of conformity to confirm compliance. This will help ensure that authorities can monitor enforcement.

Appointment of authorised representatives

Under the PPWR, companies are further required to appoint an Authorised Representative (AR) to fulfill their Extended Producer Responsibility (EPR) obligations (Article 45.3). The only exception applies to member states where the company itself is established. This measure is designed to prevent businesses from circumventing their EPR obligations.

The Authorised Representative will, on behalf of the company, be responsible for tasks such as providing the EU declaration of conformity and the necessary technical documentation to the respective market surveillance authorities.

Checklist: Preparing your business for the PPWR

To be as well-prepared as possible, it makes sense to take action now. The PPWR brings many new requirements that will apply across the EU. While many of these obligations are still being finalized in the form of delegated acts before the regulation takes effect, some will already apply to your business starting August 12, 2026.

To help you navigate the jungle of regulations, we’ve put together a handy starter checklist:

1. Clarify your role(s) under the PPWR
   
   • Am I a producer, manufacturer, importer, distributor, supplier, or does my company even fall into multiple roles?
   • In which countries am I active in which role?
   • Which packaging do I place on the market?
2. Check cross-border obligations
   
   • Does my company have a local entity in every country it ships to?
     If not: Appoint an Authorised Representative (AR) in time.
3. Compliance and documentation
   • Can I already request recyclability certificates from my suppliers?
   • Do I have a clear overview of who supplies packaging and who places it on the market?
   • Have I ensured that my technical documentation can capture all relevant data to prepare my company’s declaration of conformity?
   • Do I need to adjust contracts with fulfillment providers or distribution partners?
     
4. Keep EPR obligations in sight
   • Which systems (e.g. dual systems in Germany) do I currently use in which countries?
   • Is my company fully compliant with EPR obligations in all export markets?
     
5. Consider reuse & return systems
   • Do I have packaging in my portfolio that will soon need to meet minimum reuse quotas?
   • Do I need partners or return solutions?
     
6. Design & labelingDesign & Kennzeichnung
   • Am I already designing packaging according to “Design for Recycling” principles?
   • Do I have upcoming obligations for standardized EU-wide recycling symbols/labels on my radar?
7. Internal processes & IT
   • Does my ERP/shop system need to map additional data (e.g. packaging types, weight, reporting)?
   • Who in the company is responsible for PPWR compliance?