PPWR-Wiederverwendungssysteme: Pflichten für Unternehmen ab 2026
PPWR reuse systems are among the topics that companies should actively assess now. The new EU Packaging and Packaging Waste Regulation, or PPWR for short, has already entered into force and will apply predominantly from 12 August 2026. As an EU regulation, it generally applies directly in Member States and aims to reduce packaging waste, strengthen recycling and promote reuse more effectively. This is particularly important for B2B companies that develop, fill, import, distribute or use packaging for transport and logistics. A reuse system is more than just an idea for reusable packaging: it requires clear processes, return routes, documentation and partners throughout the supply chain.
What are PPWR reuse systems?
A PPWR reuse system is an organised process that enables reusable packaging to be used multiple times. Reusable means that the packaging is designed to withstand several cycles, can be cleaned or reconditioned and then fulfils the same or a comparable purpose again.
It is important to distinguish reuse from recycling. In recycling, packaging material is collected, sorted and recovered after use. In reuse, the packaging remains intact as a product. A reusable box, a reusable pallet or a durable transport container can therefore form part of a reuse system if return, inspection, cleaning and redeployment work reliably.
For companies, it is therefore not only the packaging itself that matters. The system behind it is equally important: Who takes the packaging back? How is its condition checked? Who cleans or repairs it? How is the number of times it has been used documented? And who is responsible if a partner in the supply chain fails to perform?
We advise you on all matters relating to the VerpackDG/PPWR:
Legal framework: What changes as a result of the PPWR?
The PPWR is the new EU Packaging and Packaging Waste Regulation. It was published as Regulation (EU) 2025/40, entered into force on 11 February 2025 and, after the transition period, is expected to apply predominantly from 12 August 2026. It will gradually replace the previous Packaging Directive. As a regulation, it does not need to be fully transposed into national law in the same way as a directive, although national implementing rules may still remain important.
The PPWR contains specific requirements for reuse systems. Companies that first make reusable packaging available on the market or use it in such a system should assess whether a suitable system is in place. The system must work in practice: it must enable the packaging to be returned and ensure that it can actually be reused.
The PPWR also includes further obligations that may be indirectly linked to reuse. These include requirements for packaging design, substance restrictions, labelling, documentation and conformity evidence. Not every obligation applies immediately, and not every obligation affects every type of packaging in the same way. Companies should therefore classify their packaging by packaging type, material, area of use and country of supply.
Important: During the transition period, the PPWR does not automatically replace all existing obligations under the German Packaging Act. Packaging that typically becomes waste at private end consumers may still be subject to the obligation to participate in a system. This means that the company must participate in a dual system with these packaging volumes and report the quantities in the LUCID Packaging Register. The ZSVR continues to describe the core obligations as: register, participate and report.
Who is affected by PPWR reuse systems in the B2B sector?
Companies using packaging in professional supply chains may be affected in particular. This includes manufacturers, importers, trading companies, fulfilment service providers, logistics companies and brand owners. Reusable transport packaging, shipping solutions, crates, containers, pallets, buckets and reusable packaging for commercial goods transport are especially relevant.
Put simply, a company placing packaging on the market is the company that first makes a product or packaging commercially available in a market. This role is important because many obligations are linked to the first step in the supply chain. Depending on the business model, this may be the manufacturer, importer, retailer or another company.
Not every company must build its own reuse system. In many cases, participating in an existing pooling, take-back or reusable packaging system may be appropriate. However, responsibilities must be clearly defined. A contract with a service provider does not automatically replace the internal assessment of whether PPWR requirements are met for your own packaging and supply chain.
Practical implementation: 7 steps for companies
1. Record packaging types
Start with a complete packaging list. Record sales packaging, grouped packaging, shipping packaging, service packaging and transport packaging separately. Note the material, weight, country of supply, place of use and typical place of waste generation.
2. Assess reusability
Review which packaging can already be used multiple times. Consider durability, cleanability, repairability and suitability for multiple cycles. Packaging is not automatically PPWR-compliant simply because it could theoretically be reused.
3. Clarify roles in the supply chain
Define who carries out which task: provision, take-back, sorting, cleaning, repair, documentation and redeployment. Record these points in writing. This helps with internal audits and with questions from customers, authorities or business partners.
4. Define the return process
A reuse system depends on an effective return process. Define collection points, transport routes, deadlines and responsibilities. Also assess whether deposit, pooling or digital tracking solutions would be appropriate.
5. Prepare data and evidence
Companies should begin collecting master data on packaging early. This includes material composition, weight, supplier, technical specifications and information about intended use. This data is becoming more important because the PPWR strengthens documentation and evidence obligations.
6. Update contracts
Review procurement, logistics and disposal contracts. Who bears the cost of loss, damage or cleaning? Who provides data? Who is liable if packaging is not returned? Without clear contracts, unnecessary gaps can arise later.
7. Do not overlook existing packaging licensing obligations
If your packaging typically becomes waste at private end consumers, packaging licensing remains a separate compliance requirement. A packaging licence is participation of those packaging volumes in a dual system. It is not the same as a PPWR reuse system.
We advise you on all matters relating to the VerpackDG/PPWR:
Common mistakes with PPWR reuse systems
A common mistake is equating reusable packaging with a reuse system. A robust box on its own is not enough. Without return, inspection and repeated use, there is no reliable system.
The second mistake is an unclear allocation of roles. Especially in B2B contexts, many partners work together. If nobody is accountable, return volumes and packaging conditions remain unclear.
Third, companies underestimate the required data base. Companies that only start collecting material data, supplier information and packaging weights in 2026 lose valuable time. Preparation should begin now.
Fourth, PPWR obligations are confused with national packaging obligations. The two are connected but not identical. A packaging licence does not fulfil a reuse requirement. Conversely, a reusable packaging system does not automatically replace participation in a dual system for packaging that is subject to the obligation to participate in a system.
Conclusion: Set up processes now instead of reacting in a rush later
PPWR reuse systems are not merely a sustainability topic. They are becoming an important component of packaging compliance. Companies should now record their packaging, clarify roles, define return processes and systematically collect data.
If you also place sales, grouped or shipping packaging on the German market, review your packaging licensing obligations as well. zmart supports you with packaging licensing under German packaging law. Relevant internal points of reference also include zmart information on PPWR consulting, transport packaging and other EPR topics such as ElektroG and battery law. However, each of these topics should be assessed separately so that obligations are not conflated.
FAQ on PPWR reuse systems
When do the PPWR rules apply?
The PPWR entered into force on 11 February 2025. Many provisions will become applicable after the transition period from 12 August 2026. Individual requirements may take effect gradually at a later date. Companies should therefore not focus on a single date, but assess their packaging against the specific obligations that apply.
Is every reusable package automatically PPWR-compliant?
No. Packaging can be reusable without the overall system being sufficiently organised. In practice, return, cleaning, inspection, repair, redeployment and documentation also matter.
Does this also affect transport packaging?
Yes. Transport packaging can be affected. Many reusable solutions are used in logistics and commercial goods transport, particularly in the B2B sector. However, companies should clearly distinguish transport packaging from sales and shipping packaging because different obligations may apply.
Does a reuse system replace the packaging licence?
No. The packaging licence concerns packaging subject to the obligation to participate in a system under German packaging law. A PPWR reuse system concerns the organised repeated use of reusable packaging. Both issues may be relevant at the same time.
Do small companies also need to assess this?
Yes. Smaller companies should also assess whether they first make packaging available or place packaged goods on the market. Whether specific obligations apply depends on the business model, packaging type, role in the supply chain and quantities involved.