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Is your company affected by PPWR?
Yes, most companies are affected.

PPWR applies to all types and materials of packaging used to contain, protect, handle, deliver, or present products to other economic operators (B2B) or final customers (B2C).

Affected parties may include:

• Online retailers and marketplace sellers shipping into the EU
• Import/export businesses bringing packaged goods into the EU
• Logistics and fulfillment service providers using their own packaging

What is the PPWR?

PPWR stands for Packaging and Packaging Waste Regulation. It’s the new EU regulation on packaging and packaging waste (Regulation (EU) 2025/40) that replaces the old Packaging Directive 94/62/EC.

It is part of the European Green Deal and the Circular Economy Action Plan, and its core goal is to make packaging more sustainable and reduce packaging waste per person in the EU by 15 % by 2040 compared with 2018.

In force since: February 2025. Applicable from: 12 August 2026, with staged requirements up to 2040

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Core Goals and Requirements of the PPWR

Recycling & Use of Recycled Materials

• By 2030 at least 70 % of all packaging must be recyclable. (80% until 2038)
• Plastic packaging must contain minimum recycled content (e.g., 35 %).

Reusability and Refill Obligations

• From 2026: participation in reuse systems becomes required.
• By 2030: a significant share of sales and transport packaging must be reusable.

Labeling & Transparency

• From 2026: Identification mark and manufacturer and importer information on packaging.
• From 2028: EU-harmonized pictograms and information on material composition and recycled content.
• From 2029: QR codes with information on reusable and compostable packaging.
• From 2030: Digital information on substances of very high concern

Extended Producer Responsibility (EPR)

• From 2026, companies will have to register in national registers across the EU, and from 2027 they will have to report packaging quantities and pay fees for packaging waste.

Minimizing Packaging:

• From 2030, the empty space within packaging (e.g., space filled with paper or bubble wrap) may not exceed 50%.
• Duplicate bottoms or unnecessary layers in packaging will no longer be permitted from 2030.

Entry into force of the PPWR in February 2025

Why you should act now!

Placing non-compliant packaging on the market can have serious consequences. Companies should take early action to minimize risks and comply with the PPWR requirements:

Exclusion from the EU market

• Market surveillance authorities in EU Member States can demand corrective action if packaging does not meet identification or documentation requirements.
• Persistent violations can lead to sales bans and recall orders.
• Non-compliance can mean that packaging may only be reintroduced to the market after it has been brought back into compliance.

Reputational damage

• Violations of the PPWR can significantly affect sustainability ratings, consumer confidence, and relationships with investors and partners.

Financial penalties and costs

• PPWR requires Member States to establish penalties that are “effective, proportionate, and dissuasive.”
• Specific fines and measures are expected and may vary depending on the Member State.

Additionally, there are costs associated with recalls and the disposal of non-compliant packaging.

Legal and contractual liability

• Non-compliance can lead to liability risks towards service providers, online marketplaces, and business partners.

What you and your company should do now and how we can help!

With the upcoming implementation deadline of the PPWR and in order to meet the complex and constantly evolving requirements, a structured, cross-functional implementation is needed. Based on our extensive experience, we have developed a roadmap that translates regulatory requirements into concrete, actionable steps.

Our approach not only ensures compliance with the minimum requirements by August 2026, but also creates a solid foundation for long-term regulatory resilience.

We support you in implementing the PPWR requirements efficiently and sustainably. Our structured 7-step roadmap lays the foundation for regulatory compliance until August 2026 and beyond.

Quick overview:

1. Analysis of your packaging flows: Identification and assessment of all relevant packaging.
2. Data management: Establishment of a traceability and documentation system.
3. Labeling requirements: Definition and implementation of necessary packaging labels.
4. Supplier management: Collaboration with packaging suppliers to ensure compliance.
5. Conformity assessment: Establishment of a testing and documentation system.
6. Governance system: Clear responsibilities and digital documentation.
7. Long-term planning: Monitoring of future regulatory developments.

Long-term planning

In addition to short-term measures, you should also keep an eye on the long-term requirements of the PPWR, the specific details of which will be further defined by numerous delegated acts of the EU Commission in the coming years. We will monitor these developments for you.

Here are the most important milestones as of today:

• 2027: Introduction of Extended Producer Responsibility (EPR) with registration obligations, reporting, and potential fees.
• 2028: Harmonized labeling requirements (e.g., pictograms) – adjustments to packaging design will be necessary.
• 2030: Requirements such as reuse quotas (e.g., 40% for sales and transport packaging, increasing to 70% by 2040), minimization of empty space (max. 50%), and minimum recycled plastic content (35%, increasing to 2040).

Our PPWR Portfolio

• PPWR Readiness Check: Analysis of your company’s impact
• Inventory and Gap Analysis: Detailed analysis of your packaging flows and creation of a customized PPWR action plan (roadmap)
• Implementation Support: Assistance with implementing PPWR requirements along the roadmap
• Establishing Internal Structures: Development of responsibilities, processes, and supplier communication
• Data Management: Ensuring data availability and developing efficient data management
• Expert Sparring: Support and guidance for your internal project team
• Holistic Implementation: From analysis to final implementation, we support you throughout the entire process

Frequently Asked Questions about PPWR