PPWR: What the new EU Packaging Regulation means for your company
Starting in 2026, the PPWR (Packaging and Packaging Waste Regulation), known in German as the EU Packaging Regulation, will introduce a new framework that fundamentally changes packaging requirements across the European Union. For companies that manufacture, fill or place packaging on the market, this means: Those who are not familiar with the PPWR obligations now risk higher costs, delays in product development and, in the worst case, fines later on. This article clearly explains what the PPWR is, which legal requirements apply and how you, as a B2B company, can approach implementation in a structured way.
What is the PPWR? Key terms explained
The PPWR (Packaging and Packaging Waste Regulation) is an EU regulation that replaces the previous EU Packaging Directive. The key difference is that a regulation applies directly in all EU Member States and does not first need to be transposed into national law, as is the case with a directive. For companies, this means that the rules apply uniformly across the EU and leave less room for national exceptions.
The PPWR pursues three main objectives:
Waste prevention: Less packaging material and less packaging waste per product.
Recyclability: All packaging must be designed to be recyclable by 2030.
More reuse: Mandatory quotas for reusable packaging in certain sectors, such as shipping and food service.
We advise you on all matters relating to the VerpackDG/PPWR:
Important technical terms in connection with the PPWR
Producer: Any company that makes packaging available on the EU market for the first time – for example, by selling packaged goods to end consumers or business partners.
Authorised representative: A person or organisation established in the EU that fulfils PPWR obligations on behalf of a company based outside the EU. This mainly affects online retailers established outside Europe.
Obligation to participate in a system: The obligation to participate in a dual system that organises and finances the collection and recovery of packaging waste from private households. In Germany, this obligation already exists independently of the PPWR under the Packaging Act and will remain in place after the PPWR is introduced.
Recyclability (Recyclability Grades): The PPWR introduces a classification system for packaging recyclability, with grades ranging from A to E. Packaging in the lowest grades will be excluded from the market from certain deadlines onward or subject to higher fees.
Legal framework: These obligations and deadlines apply
The PPWR was published in the Official Journal of the EU in December 2024 and formally entered into force 20 days later. The actual substantive obligations will apply in stages from 12 August 2026, with further requirements following through to 2030 and 2035. As some detailed provisions and implementing acts of the European Commission are still being developed, companies should keep track of further developments.
Key obligations affecting B2B companies include:
Design requirements: Packaging must be designed to be recyclable. From 2030, in principle, only packaging that meets the minimum recyclability criteria may be placed on the market.
Labelling requirements: In the future, packaging is expected to carry standardised labels indicating material type and disposal instructions so that consumers can separate waste correctly.
Minimisation requirement: The ratio of packaging volume to product volume will be regulated. Empty space and excessive volume, for example in shipping packaging, must be reduced.
Ban on certain packaging formats: From 2030, bans will apply to certain types of single-use packaging, for example in the food service sector.
Reporting obligations: In the future, companies must be able to provide more detailed information about the quantities of packaging they place on the market and its recyclability.
Important for context: The PPWR does not replace the existing obligation to participate in a system under the German Packaging Act. Anyone placing sales packaging filled with goods on the German market for private end consumers will still require a packaging licence. The PPWR supplements this obligation with additional design and reporting requirements. Since the specific national implementation of individual PPWR requirements has not yet been conclusively determined, it is advisable to follow current announcements from the competent authorities and seek legal advice if in doubt.
Practical implementation: How to proceed as a company
Implementing the PPWR generally affects several departments at the same time – from procurement and packaging development to compliance. A structured approach helps keep the effort manageable:
Step 1: Record your packaging portfolio. Obtain a complete overview of all packaging that your company currently places on the market, including material type, weight, composition and intended use.
Step 2: Assess recyclability. Have your existing packaging assessed for recyclability according to the upcoming PPWR criteria. Common problem areas include composite materials, dark plastics and labels that cannot be separated.
Step 3: Adapt designs at an early stage. Where packaging is unlikely to meet the requirements, the switch to recyclable alternatives should be planned early. In practice, development and approval processes for new packaging often take several months.
Step 4: Document quantities and data. Establish internal processes for continuously collecting the packaging quantity data required for reporting obligations.
Step 5: Do not overlook existing obligations. While preparing for the PPWR, the existing obligation to participate in a system remains in force. Check whether your packaging licence is up to date and whether the reported quantities are correct.
Step 6: Define responsibilities. Appoint an internal body responsible for PPWR implementation, monitoring developments in implementing acts and coordinating adjustments.
We advise you on all matters relating to the VerpackDG/PPWR:
Common mistakes in PPWR implementation
A frequent mistake is viewing the PPWR solely as a task for packaging development, even though procurement, sales and compliance are also affected. Many companies also underestimate the lead time required in practice to switch to recyclable packaging. Another common misconception is that the existing packaging licensing obligation will cease to apply once the PPWR takes effect. This is not the case; both obligations apply in parallel.
Frequently asked questions about the PPWR
When does the PPWR become mandatory?
The PPWR has formally been in force since early 2025. Most substantive obligations for companies will apply in stages from 12 August 2026, with further requirements following through to 2030 and 2035.
Does the PPWR also affect small and medium-sized enterprises?
Yes. In principle, the PPWR does not differentiate according to company size. However, microenterprises may benefit from exemptions or longer transitional periods in certain areas, although the exact details have not yet been fully defined.
Do I still need to obtain a packaging licence despite the PPWR?
Yes. The obligation to participate in a system under the German Packaging Act remains unaffected by the PPWR. Anyone supplying sales packaging filled with goods to private end consumers must continue to license this packaging.
What happens if my packaging does not meet the recyclability criteria?
Packaging that does not meet the minimum requirements may, in principle, no longer be placed on the EU market from the applicable deadlines onward. Further implementing acts of the European Commission will specify the details of the classification and transitional arrangements.
Where can I find reliable, up-to-date information about the PPWR?
As certain details of the PPWR are still being specified through implementing acts, it is advisable to continuously monitor official EU sources and consult specialised advisory services or legal advisers for packaging law.
Conclusion
The PPWR introduces far-reaching new requirements for B2B companies that place packaging on the market, particularly regarding design, recyclability and reporting. As the deadlines will apply in stages from 2026 and individual details are still being specified, it is worthwhile to address the issue early and in a structured manner. It is important to note that the PPWR does not replace the existing packaging licensing obligation; it supplements it.
Would you like to meet your existing obligation to participate in a system in a legally compliant and straightforward way? With the zmart packaging licence, you can report your packaging quantities easily online. Further related topics for B2B producers: