PPWR authorised representative: What companies need to know from August 2026

What is the PPWR and why does it affect companies?

The PPWR is an EU regulation on packaging and packaging waste. It replaces the previous EU Packaging Directive and applies directly in all 27 EU Member States. Individual countries do not first need to transpose it into national law.

Germany supplements the PPWR through the new Packaging Law Implementation Act. It governs areas in which the EU leaves Member States room for their own rules.

The objective of the PPWR is clear: Less packaging waste should be generated in the EU. Packaging should be easier to recycle and contain more recycled material.

For companies, this creates new requirements. The rules affect companies that first make packaging available in the EU. This includes manufacturers, importers and retailers. The PPWR does not apply only to sales packaging. Grouped packaging, transport packaging and service packaging are also covered.

What is a PPWR authorised representative?

A PPWR authorised representative is a person or company established in the EU. A company based outside the EU appoints this authorised representative in writing. The authorised representative then assumes certain PPWR obligations within the EU.

You may already know this principle from the German Electrical and Electronic Equipment Act (ElektroG) or battery law. Companies offering products from a third country in the EU often need a responsible entity established in the EU. This entity acts as the contact point for authorities and registers.

Depending on the appointment, a PPWR authorised representative may take on tasks such as:

• Registration with the competent national authority

• Reviewing and organising PPWR obligations

• Preparing and retaining the PPWR declaration of conformity

• Communicating with market-surveillance authorities

• Reporting packaging quantities

Who is subject to this obligation?

The obligation affects companies if all of the following points apply:

• The company is established outside Germany.

• The company places packaging or packaged goods on the German market for the first time.

• The company has no establishment in Germany that assumes these obligations.

Typical examples include:

• A manufacturer based in the United States supplies packaged products directly to retailers or end consumers in the EU.

• An online retailer based in Austria sells to customers in Germany through marketplaces.

• A Swiss company exports goods to EU countries.

When does the obligation apply?

The PPWR entered into force on 11 February 2025. Most practical obligations apply from 12 August 2026. This also includes the obligation to appoint a PPWR authorised representative.

From this date, affected companies based outside the EU may no longer place packaging on the EU market without an authorised representative.

You should be aware of these deadlines:

• 12 August 2026: The obligation to appoint a PPWR authorised representative and provide a declaration of conformity applies.

• From 2030: Minimum requirements for recycled content become binding.

• From 2030: Stricter recyclability requirements apply.

• From 2040: Further requirements on recyclability and reuse quotas will follow.

Do not wait until shortly before the deadline. Selecting a suitable authorised representative, preparing the declaration of conformity and completing registration take time. Start no later than the first quarter of 2026.

We advise you on all matters relating to the VerpackDG/PPWR:

How non-EU companies can meet the obligation

Step 1: Check whether you are affected

First, clarify whether your company makes packaging available on the EU market for the first time. If you supply customers or retailers directly in the EU, you are generally affected.

Step 2: Select an authorised representative

The authorised representative must be established in the EU. The appointment must be made in writing. Clearly define which tasks the authorised representative will take on. Make sure they are familiar with packaging law and administrative processes.

Step 3: Prepare registration and the declaration of conformity

The authorised representative registers your company with the competent authority. A PPWR declaration of conformity must also be available. It confirms that your packaging meets the PPWR requirements. These include, for example, recyclability, labelling and minimum recycled-content requirements.

Step 4: Organise ongoing obligations

The work does not end with the initial registration. You must report quantities, keep documentation up to date and document packaging changes. If authorities raise questions, the authorised representative must be able to respond.

Common mistakes and how to avoid them

The same mistakes often occur in practice:

• Starting too late: Companies that only begin looking shortly before 12 August 2026 may not find a suitable authorised representative in time.

• Granting an unclear mandate: If the responsibilities are not clearly defined, the authorised representative cannot act with certainty.

• Forgetting the declaration of conformity: Appointment of an authorised representative alone is not sufficient. You must document that your packaging meets PPWR requirements.

• Confusing this with packaging licensing: PPWR authorisation does not replace participation in a dual system under German packaging law. Both obligations apply in parallel.

• Failing to report product changes: If packaging changes, you must review and, where necessary, update the declaration of conformity.