The European Packaging and Packaging Waste Regulation (PPWR) entered into force on 11 February 2025 and will generally apply directly in all EU Member States from 12 August 2026. However, many of its specific requirements will be phased in over the following years. But which types of packaging are affected, which companies need to take action, and what exactly will they need to do? Product compliance expert Patrick Fischer Riegert from imds professional answers these and other key questions.

What is the PPWR and what are its main objectives?

BU: Patrick Fischer-Riegert

For me, the PPWR is above all a clear signal from the EU: in the future, packaging should not only protect products effectively and look appealing, but also become significantly more sustainable. The regulation aims to reduce packaging waste, use fewer materials, and keep valuable resources in circulation for longer.

For companies, this means rethinking packaging. It should not be viewed merely as a compliance obligation, but also as an opportunity to improve processes and demonstrate responsibility in a visible way.

What will change for companies from 12 August 2026?

In my view, 12 August 2026 marks the starting point for practical implementation. From that date, the PPWR will generally apply directly across all EU Member States.

Companies will need a much clearer understanding of the packaging they use, how it is designed, and which requirements already apply. They will also need to determine their specific role within the supply chain and identify what information or evidence they require from suppliers.

It is important to remember, however, that not all requirements take effect immediately. Many obligations will be introduced gradually over the following years.

Which obligations apply from that date and which will come later?

From August 2026 onward, the initial focus will be on establishing clear responsibilities, managing packaging data, and maintaining the necessary documentation. Companies should know exactly which packaging they use, which materials it contains, and who is responsible for meeting the relevant requirements.

Certain substance restrictions will also apply from that point, including PFAS limits for food-contact packaging.

Many of the major sustainability requirements will become more concrete from 2030 onward. These include harmonized recyclability assessments, recycled content targets, and packaging minimization requirements. From 2035, it will also become important to demonstrate that packaging is actually recycled at scale.

Which companies will be most affected?

The PPWR affects all companies throughout the packaging value chain, including those that design, manufacture, import, fill, distribute, or sell packaging.

One important point is that not every company automatically has the same obligations. The determining factor is always the company’s specific role. Who is responsible for packaging compliance? Who places the packaging on the market? In which country is the packaging likely to become waste?

This can become particularly complex in the case of private-label products, imports, and international supply chains.

How is the automotive industry affected?

In principle, the automotive industry is affected just like any other sector, because the PPWR applies across industries.

Implementation can be especially challenging in automotive supply chains due to the large variety of packaging formats and the complexity of logistics networks. Components, spare parts, and accessories are constantly transported in cartons, films, pallets, load carriers, and reusable containers.

As a result, companies often deal with a large number of packaging variants and suppliers. They therefore need a clear understanding of what data is available and who is responsible for meeting and documenting the relevant requirements.

What is behind the new declaration of conformity and how much effort will it require?

The declaration of conformity is essentially the formal proof that a package complies with the applicable PPWR requirements.

However, it cannot be based on assumptions alone. The responsible producer must have access to technical documentation, material information, and reliable supporting evidence.

The amount of effort involved will depend heavily on a company’s current level of preparedness. Organizations that already have well-structured packaging data and supplier documentation in place will be able to approach the process systematically. Those that still need to gather information from emails, spreadsheets, and different departments will face considerably greater challenges.

 

What evidence will companies need to provide?

That always depends on the packaging, the company’s role, and the relevant implementation stage.

Examples of required evidence include material information, technical specifications, supplier declarations, test reports, and information regarding restricted substances. Depending on the type of packaging, additional evidence relating to recyclability, recycled content, reusability, or packaging minimization may also be required in the future.

One point I consider particularly important is that a supplier declaration is a valuable foundation, but it does not automatically remove the responsible company’s own accountability.

How high is the risk of non-compliance, for example regarding market access?

I believe many companies still underestimate this risk. The consequences extend far beyond potential fines.

If packaging does not meet the applicable requirements, it may not be allowed on the market. In the case of packaged goods, this could also mean that the product itself cannot be sold.

Additional consequences may include rework, delays, inquiries from customers or authorities, and, in the worst case, product withdrawals or recalls.

What changes can be expected in supply chains?

I think supply chains will require a much higher level of transparency. Companies will need to ask more detailed questions about which materials are used, which substances may be present, and what supporting documentation is available.

For suppliers, this means that they will no longer be expected to provide only packaging or materials. They must also be able to provide the corresponding compliance information.

As a result, I expect specifications, supplier agreements, and contractual requirements to become more detailed. Trust will remain important, but it will increasingly need to be supported by reliable data and documentation.

Do companies need to completely rethink their packaging strategies?

Not necessarily from scratch, but certainly in a much more conscious and strategic way.

Packaging will no longer be evaluated solely on the basis of cost, appearance, and functionality. Material efficiency, recyclability, reusability, and regulatory requirements will play an increasingly important role.

As a result, many organizations will need to reassess their existing packaging solutions. What can remain unchanged? What needs to be modified? And where might an entirely new approach be required?

One thing is clear to me: this is not a task that can be handled by a single department on the side. Procurement, engineering, quality, sustainability, packaging management, and sales all need to work together.

What role does digitalization play, particularly with regard to material and recyclability data?

For me, digitalization is a key enabler because the PPWR relies heavily on data and documentation.

Companies must be able to trace how packaging is constructed, which materials it contains, which documents are available, and where the information originates.

The PPWR does not prescribe a specific IT system. However, once companies are dealing with numerous packaging types, locations, and suppliers, isolated spreadsheets can quickly become difficult to manage. Structured digital solutions can help ensure that data remains current, complete, and traceable.

Where do you currently see the greatest uncertainties in implementation?

The overall direction of the PPWR is now relatively clear. What remains uncertain for many companies is the practical implementation.

Several important details will only be defined through additional legal acts, assessment methodologies, and technical standards. This applies, for example, to recyclability assessments, labeling requirements, and certain calculation methods.

In my view, the biggest uncertainty is therefore no longer whether companies need to act, but how they should implement the requirements effectively within their existing processes.

Background Information

  • The PPWR replaces the previous Packaging Directive and establishes a harmonized regulatory framework for all packaging across the EU.
  • From 12 August 2026, the regulation becomes legally applicable, and non-compliant packaging may no longer be placed on the market.
  • The regulation affects all stakeholders throughout the packaging value chain.
  • Key requirements include recyclability, recycled content, reuse, and packaging minimization.
  • Documentation of compliance will be mandatory from August 2026.
  • The regulation introduces limits and restrictions for certain substances of concern, including PFAS.
  • Key objectives include reducing packaging waste and promoting recycling and reuse.
  • Many detailed implementing rules will be introduced gradually, creating additional challenges for companies.

Company Profile

imds professional helps companies meet material and product compliance requirements in a sustainable and reliable manner while ensuring adherence to all applicable regulations. Our core business includes consulting, services, and training related to environmental legislation, regulations, directives, and customer-specific requirements.

As a leading service provider in the field of Product Environmental Compliance, we are committed to helping organizations optimize their environmental compliance programs and create measurable business value. Through independent, focused consulting and tailored services and training programs, we support companies in maintaining competitiveness amid increasing regulatory demands.

Since 1999, small and medium-sized enterprises as well as global manufacturing and processing companies have relied on our expertise. For more information, visit www.imds-professional.com.

 Text and fotos: imds professional GmbH & Co. KG

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