PPWR 2026: An Overview of Obligations, Deadlines, and Roles

Abstract

The EU Packaging Regulation classifies packaging as a regulated product. Just as with electrical appliances or toys, the following now applies: Packaging may no longer be placed on the EU market without a conformity assessment, technical documentation, and a declaration of conformity. Strict PFAS limits also apply to food-contact packaging. This is the core of what can be tested starting August 12, 2026.

It is not the size of the company that determines who bears which responsibility, but rather the role associated with each product. A retail company may act as a manufacturer for its own brand, as an importer for imported goods, and as a distributor for branded products. Incorrect role classifications are therefore among the greatest compliance risks. They lead to gaps in declarations of conformity, registration, and labeling.

The greatest challenge lies not in individual threshold values, but in reliable packaging data. Companies must be able to demonstrate for each piece of packaging what it is made of, how much recycled material it contains, and who is responsible for it. Those who build this database now will not only meet today’s obligations but also the requirements for recyclability and recycled content starting in 2030.

What is the PPWR?

The PPWR (Packaging and Packaging Waste Regulation) is the EU regulation on packaging and packaging waste, Regulation (EU) 2025/40. It was published in the Official Journal on January 22, 2025, entered into force on February 11, 2025, and has been in effect since August 12, 2026. As a regulation, it is directly applicable in all 27 member states without the need for national legislation to implement it. The official questions and answers can be found in the European Commission’s FAQ section.

What are the objectives of the EU Packaging Directive?

The regulation is intended to reduce packaging waste and keep packaging in circulation. Specifically, it has three objectives:

• Less packaging waste: The amount of waste per capita is to be reduced by 5% by 2030, 10% by 2035, and 15% by 2040, compared to 2018.
• Improved recyclability: Starting in 2030, all packaging must be recyclable. Plastic packaging must contain a minimum percentage of recycled material.
• A unified single market: Uniform rules for design, labeling, and documentation across all member states will replace the current patchwork of national regulations.

What distinguishes the PPWR from the old Packaging Directive?

The old Packaging Directive merely provided a framework. Each member state decided for itself how to implement it. As a result, identical products had to be labeled, registered, and documented differently depending on the country of sale. The new regulation fundamentally changes this:

• Legal Form: The directive had to be implemented at the national level. The regulation is directly applicable.
• Responsibility: Instead of being assigned by company category, responsibilities are assigned by role for each product.
• Proof: A new requirement is the EU Declaration of Conformity for each package.
• Labeling: Starting in 2028, national special rules will be replaced by EU-wide harmonized labeling.
• Recycled Material: Starting in 2030, minimum recycling rates will apply to plastic packaging for the first time.
• Bans: Starting in 2030, certain types of single-use plastic packaging will be expressly prohibited.

Will the PPWR be postponed?

No. The regulation has been in effect since August 12, 2026; there is no postponement of the core obligations. Although numerous German associations from the waste management, packaging, and consumer goods industries had called for the effective date to be postponed to January 1, 2027, However, the European Commission ruled out a postponement and published a guidance document with an accompanying FAQ list in March 2026.

What PPWR requirements have been in effect since August 12, 2026?

Since the regulation took effect, three requirements have been directly applicable: the restrictions on heavy metals, the PFAS limits for food-contact packaging, and the requirement for conformity assessment and an EU declaration of conformity. In addition, there are labeling and information requirements for the various roles involved.

Heavy Metals: Limit Value for Each Package

According to Article 5 of the Regulation, the sum of the concentrations of lead, cadmium, mercury, and hexavalent chromium in a package or its components must not exceed 100 mg/kg. This limit is carried over from the old directive. What is new is that compliance with this limit is now part of the conformity assessment and must be documented.

PFAS Ban on Food Packaging

As of August 12, 2026, packaging that comes into contact with food may contain per- and polyfluoroalkyl substances (PFAS) only if their levels remain below strict limits:

• 25 ppb for each individual PFAS, measured by targeted analysis
• 250 ppb for the total concentration of all PFAS
• 50 ppm for all PFAS, including polymeric PFAS

PFAS have frequently been used as grease- and water-repellent coatings, for example in paper and cardboard packaging for baked goods, fast food, or pet food. Affected companies should obtain supplier declarations and, if in doubt, arrange for laboratory analyses.

EU Declaration of Conformity and Technical Documentation

Starting in August 2026, the Declaration of Conformity will be the key to accessing the EU market for all packaging. Before placing the packaging on the market, the manufacturer must conduct a conformity assessment procedure (Articles 15 and 38, Annex VII) to demonstrate that the packaging meets the requirements of Articles 5 through 12. On this basis, the manufacturer issues the EU Declaration of Conformity (Art. 39).

The technical documentation includes, in particular:

• a description of the packaging and its intended use
• the material composition and the substances used
• Evidence regarding heavy metal and, where applicable, PFAS limit values
• Applicable standards or technical specifications
• Test Reports and Supplier Declarations

The technical documentation and the declaration of conformity must be retained for five years in the case of single-use packaging and for ten years in the case of reusable packaging. If a piece of packaging is also subject to other EU legal acts requiring a declaration of conformity, a single declaration covering all applicable regulations is sufficient.

Labeling and Traceability

The manufacturer must include its name or brand name and a mailing address on the packaging, as well as a type, lot, or serial number for identification purposes. Importers must add their own contact information. This information enables market surveillance authorities to trace each package back to a responsible party.

PPWR Roles: Who Is Responsible for What?

The regulation assigns obligations not to companies, but to roles. The decisive factor is the function a company performs with respect to a specific product and its packaging. The terms are defined in Article 3.

Note on the translation: The German version uses “Erzeuger” for the English “manufacturer” and “Hersteller” for the English “producer.” Anyone working with English guidelines should be aware of this; otherwise, responsibilities may be misassigned.

Why a Company Can Assume Multiple Roles

Roles are not fixed characteristics of a company; rather, they depend on the product and the distribution channel. The same company may:

• to be a producer for a private label because his name appears on the packaging
• For imported goods, you must also be the importer
• to act merely as a distributor of other companies' brand-name products
• will be required to register as a manufacturer in every country where their products are sold

In addition, importers and distributors themselves become producers if they place packaging on the market under their own name or brand, or modify it in a way that may affect its conformity (Art. 20).

How to Determine Your Role

Role definition always begins at the product level. These questions help you create a role profile for each item:

1. Under whose name or brand is the packaging sold in the EU?
2. Who designed the packaging or had it manufactured?
3. Does the product originate from a third country, and who is the first to place it on the market in the EU?
4. In which member states will the product be made available for the first time?
5. What role do marketplaces or fulfillment service providers play, both contractually and in practice?

The role profile is not permanently fixed. Changes in the product line, suppliers, or distribution channels can alter responsibilities and should be reviewed regularly.

Common Misconceptions About Role Assignment

• “The responsibility lies with the packaging supplier.” The supplier provides information. The declaration of conformity is issued by the manufacturer—which is usually the brand owner.
• “The marketplace or fulfillment service provider handles that.” Without a clear contractual provision, responsibility remains with the owner of the goods.
• “We’re just retailers.” Anyone who carries private-label brands is the manufacturer of those products, regardless of who bottles or produces them.
• “One registration is enough.” Up-to-date information, reports, and supporting documentation are required on an ongoing basis.

PPWR Deadlines: The Timeline Through 2040

The regulation does not take effect on a single effective date. The requirements will be phased in based on the technical and organizational complexity of their implementation. The following deadlines are crucial for your planning:

• February 11, 2025: The regulation takes effect.
• August 12, 2026: The law takes effect, including a declaration of conformity, technical documentation, limit values for PFAS and heavy metals, and manufacturer labeling. In Germany, the Packaging Act (VerpackDG) takes effect.
• February 12, 2028: Certain types of packaging, such as tea bags, coffee pods, and fruit stickers, must be compostable. In the food service industry, reusable options apply to takeout orders.
• August 12, 2028: All packaging will bear a standardized label indicating its material composition.
• January 1, 2029: Deposit systems for single-use plastic beverage bottles and metal beverage cans holding up to three liters are mandatory.
• February 12, 2029: Reusable packaging must bear a label indicating that it is reusable.
• January 1, 2030: All packaging must be recyclable. In addition, there will be minimum recycled content requirements for plastics, bans on certain single-use plastic packaging, a 50% void space limit, and reusable packaging requirements for transport packaging.
• January 1, 2035: Packaging must also be effectively recycled on a large scale.
• January 1, 2038: The lowest recycling category, C, will be eliminated.
• January 1, 2040: Recycling rates are rising, and per capita packaging waste is expected to have fallen by 15 percent.

Recyclability and Recycled Content: What Will Apply Starting in 2030

Starting January 1, 2030, only recyclable packaging may be placed on the market. Plastic packaging must also contain a minimum percentage of post-consumer recycled material (PCR). Both requirements necessitate long lead times for design, material testing, and supply contracts.

Recyclability by Performance Level

Article 6 classifies packaging into performance levels A, B, and C based on its recyclability. This classification is based on criteria for design for recycling, which the Commission establishes by delegated act.

• Starting in 2030: Packaging must meet at least Level C.
• Starting in 2035: Packaging must also be effectively recycled on a large scale.
• Starting in 2038: Level C will be eliminated; only Levels A and B will be permitted.

The performance level is also intended to influence the amount of licensing fees. Packaging that is easy to recycle will therefore also be more cost-effective.

Recycling Rates for Plastic Packaging

Recycled content requirements specify the minimum percentage of a plastic packaging item that must be made from recycled material. The determining factor is whether the packaging comes into direct contact with the product (contact-sensitive) or not. According to Article 7, these minimum percentages apply starting in 2030; the values in parentheses apply starting in 2040:

• Contact-sensitive PET packaging (excluding single-use beverage bottles): 30% (50%)
• Contact-sensitive packaging made from other plastics (excluding single-use beverage bottles): 10% (25%)
• Single-use plastic beverage bottles: 30% (65%)
• Other plastic packaging: 35% (65%)

Exceptions include, among others, compostable plastic packaging, certain packaging for medical devices and pharmaceuticals, and packaging in which the plastic content is less than 5 percent of the total weight. The Commission shall establish the methods for calculating and verifying the recycled content in implementing acts.

Bans, Empty Containers, Reusable Items, and Deposits: What Will Apply Starting in 2028 and 2030

In addition to design and labeling, the PPWR Regulation directly affects the product range. Certain packaging formats are prohibited, while others must be compostable or reusable.

What types of packaging will be banned starting in 2030?

Effective January 1, 2030, the following single-use plastic packaging is prohibited under Article 25 and Annex V:

• Fruits and Vegetables: Packaging for unprocessed fresh fruits and vegetables weighing less than 1.5 kg
• On-site consumption: Packaging for food and beverages consumed on-site at restaurants and cafes
• Single-Serving Portions in the Foodservice Industry: Packaging for Condiments, Sauces, Coffee Creamer, and Sugar
• Hotels: Small cosmetic and hygiene products, such as shampoo bottles and individually wrapped bars of soap
• Bundle wraps: Outer packaging used solely to bundle multiple products at the point of sale

The bans do not apply to composite packaging containing less than 5% plastic.

Minimizing Packaging and Empty Space

Starting in 2030, the weight and volume of all packaging must be reduced to the functional minimum (Art. 10). Packaging that creates the illusion of a larger contents volume through double walls, false bottoms, or unnecessary layers is prohibited. For consolidated, transport, and e-commerce packaging, the empty space may not exceed 50% (Art. 24). Producers must demonstrate compliance in their technical documentation.

Compostable Packaging

Effective February 12, 2028, certain types of packaging must be industrially compostable (Art. 9), including:

• Permeable tea, coffee, and herbal bags
• Coffee and tea pads, as well as capsules, that are disposed of along with the product
• Stickers on fruits and vegetables
• very lightweight plastic shopping bags

Reusable Container Requirements and Reuse Rates

The regulation promotes reusable products on several levels:

• Food Service: Starting in 2028, providers of takeout food and beverages must allow customers to bring their own containers and offer a reusable alternative.
• Transport Packaging: Starting in 2030, reuse rates will apply to pallets, crates, and similar transport packaging within the EU (Art. 29). Reusable packaging is generally required for shipments between locations of the same company.
• Beverages: Reusable targets are also set for certain types of beverage packaging.

Deposit-Return Systems Starting in 2029

By January 1, 2029, all member states must introduce deposit-return systems for single-use plastic beverage bottles and metal beverage cans holding up to three liters (Art. 50). The goal is a collection rate of 90 percent. For Germany, little will change because such a deposit-return system already exists. Companies that sell in Member States without a deposit-return system, on the other hand, will have to adapt to new labeling and take-back requirements.

PPWR Labeling and QR Code: What Must Be Included on the Packaging

The regulation introduces a uniform EU-wide labeling system designed to make it easier for consumers to sort their waste properly. National symbols that could be misleading regarding recyclability or reusability are no longer permitted.

In addition, Member States may require labeling that indicates the relevant extended producer responsibility system. This labeling must then be affixed in the form of a QR code or another open, standardized data carrier.

Is the QR code a digital product passport?

No. The QR code under the Packaging Ordinance is a data carrier for labeling and disposal information. The Digital Product Passport is governed by the Ecodesign Regulation (ESPR) [internal link to the ESPR article]. However, both systems require the same thing: structured, up-to-date product data that is accessible via open standards. Proprietary labeling systems do not meet these requirements.

PPWR in Germany: What the Packaging Act (VerpackDG) Regulates

In Germany, the Packaging Law Implementation Act (VerpackDG) replaced the previous Packaging Act (VerpackG) on August 12, 2026. The Bundestag passed the law on June 11, 2026, and it was promulgated on July 13, 2026 (Federal Law Gazette 2026 I No. 207).

The Packaging Act does not replace the EU regulation, whose requirements apply directly. It regulates the matters that the regulation leaves to the Member States:

• Enforcement and Responsibilities: Which authorities monitor compliance and how registration and reporting work
• Extended Producer Responsibility: System Participation, Registration, and License Fees, Aligned with the European Definition of a Producer
• National recycling rates: At least 75% for plastic packaging starting in 2028 and at least 80% starting in 2030
• Use of Recycled Materials: The Bundestag has called on the federal government to promptly submit regulations governing the use of recycled materials.
• Sanctions: Penalty Provisions for Violations of Both Sets of Rules

What has changed compared to the Packaging Act?

For companies that were already registered and licensed under the Packaging Act (VerpackG), the basic principle remains the same: Anyone who places packaged goods on the market in Germany for the first time must register and participate in a system. The main changes are the terminology, which follows the EU regulation, as well as the obligations set forth in the regulation itself—in particular, the declaration of conformity and PFAS limits. Therefore, please verify whether your existing registration with the Central Packaging Register accurately reflects the new role-based structure.

Penalties: Consequences of Violating the Packaging Ordinance

The regulation itself does not specify uniform fine amounts. It requires Member States to provide for effective, proportionate, and deterrent sanctions (Art. 68). In Germany, these are governed by the Packaging Act (VerpackDG). [Add the fine ranges from the VerpackDG and specify the section number]

In addition to fines, companies face other consequences that are often more severe:

• Sales Bans: Market surveillance authorities may prohibit the supply of non-compliant packaging.
• Recalls: If violations continue, an order may be issued to recall goods that have already been delivered.
• Delistings: Trading partners and marketplaces require declarations of conformity and proof of extended producer responsibility (EPR). If these are missing, products will not be listed.
• Competition Law Cease-and-Desist Letters: Competitors in Germany regularly issue cease-and-desist letters regarding missing registrations and false environmental claims on packaging.
• Damage to reputation: Packaging visibly conveys sustainability promises to the outside world. Any mistakes there are immediately noticeable.

Special Cases

PPWR for SMEs

The regulation generally applies regardless of company size. It provides certain exemptions for microenterprises, such as with regard to specific reusable packaging and information requirements. The declaration of conformity, as well as PFAS and heavy metal limits, also apply to small businesses. The biggest hurdles for SMEs lie in limited personnel and technical resources, particularly when it comes to collecting data from suppliers.

A realistic starting point for small and medium-sized businesses:

• Start with the top-selling products
• Clarify and document the role for each product
• Obtain supplier declarations specifically for these products
• Take advantage of free guides and events offered by Chambers of Commerce and Industry (IHKs) and industry associations

PPWR for Online Retailers and Marketplaces

In e-commerce, the risk is particularly high because information is increasingly verified automatically. Online retailers are responsible for their own shipping packaging and must comply with the 50% void space limit starting in 2030. Marketplace operators must ensure that sellers are registered on their platform. For goods from third countries without an importer based in the EU, fulfillment service providers may be held liable.

What are the rules for the restaurant and hotel industries?

The restaurant and hotel industries are particularly affected by the new rules. Starting in 2028, reusable options will be required for takeout; starting in 2030, single-use plastics for on-premises consumption, single-serving portions, and small hotel cosmetic packaging will be banned. Businesses should review their product lines early on and plan for reusable systems.

What are the rules for companies outside the EU?

Even companies not based in the EU must comply with the regulation if their packaging enters the EU market. Their EU importer must verify that a declaration of conformity is available and bears responsibility in the event of non-compliance. An authorized representative must be designated in each country of sale to fulfill EPR obligations.

Implementing PPWR: Five Steps for Businesses

The new rules present companies with many tasks, but not all of them need to be completed at the same time. This sequence avoids duplication of effort and lays the groundwork for the obligations taking effect in 2028 and 2030.

The Supply Chain Due Diligence Act (LkSG) and the EUDR also impose similar requirements on supplier data and supply chain governance. Those who use existing processes for supplier inquiries can save a significant amount of effort during implementation.

Conclusion

The EU Packaging Regulation replaces the patchwork of national rules with a uniform system consisting of roles, declarations of conformity, and design requirements. As of August 12, 2026, the declaration of conformity will determine whether packaging is permitted on the EU market. By 2030, requirements regarding recyclability, recycled content quotas, and format bans will be added. In Germany, the Packaging Act (VerpackDG) supplements the regulation with provisions on enforcement, registration, and sanctions.

In the short term, this means more work. In the long term, however, duplicate efforts will decrease because the same data applies across all member states. Companies that clearly define their roles and organize their packaging data in a structured manner gain planning certainty and a stronger negotiating position with suppliers and recycling service providers.

Five questions to help you assess your level of maturity:

• For each product, do you know whether your company is a producer, importer, distributor, or manufacturer?
• Is there an EU Declaration of Conformity with technical documentation available for every package in the product line?
• Do you have reliable PFAS test results for all food-contact packaging?
• Are the material composition, weight, and recycled content for each package recorded in a central system, or are these details scattered across emails and Excel spreadsheets?
• Are you registered in all countries where you sell your products, and have you appointed an authorized representative in those countries where you do not have a registered office?

If any of these questions remain unanswered, in most cases it’s not an organizational problem, but a data problem. And that’s exactly what can be solved.