Table of contents
Brief overview
- The EU packaging regulation (PPWR) applies to all packaging, including B2B, transport and logistics packaging
- Companies can take on several roles at the same time (e.g. manufacturer, importer, distributor)
- National EPR obligations remain in place (registration, quantity reporting, fees)
- Further detailed regulations will follow, but key requirements already apply now
- Harmonized EU labelling is expected to be mandatory from 2028
- New requirements include recyclability, minimization and data availability
- Companies should now systematically prepare their packaging data and supply chains
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Current legal situation: PPWR at a glance
The Packaging and Packaging Waste Regulation (PPWR) is an EU regulation with the aim of harmonizing packaging more closely and promoting the circular economy.
Central elements are:
- Requirements for recyclability and design-for-recycling
- Specifications for reducing packaging volume and empty space
- Introduction of reuse and reusable quotas (especially in the transportation sector)
- EU-wide labeling systems
- Stricter requirements for data availability and transparency
Important: Even if further implementing acts follow, the basic requirements are already set today. So do not delay in taking action to ensure compliance as early as possible.
We therefore recommend in particular
- The creation of a complete packaging inventory
- Separation into sales, collection, shipping and transport packaging
- Allocation according to material type, weight, function and distribution channel
- Checking which packaging needs to be adapted in terms of weight, volume and empty space in the future
- An initial assessment of possible reusable/reusable solutions for transport packaging
Establishment of a reliable database for subsequent proof of conformity and EPR notifications
Scope of application: B2B and transport packaging also affected
A key point of the current clarifications is that the PPWR not only applies to consumer packaging, but also explicitly to:
- Transport packaging
- Commercial packaging (B2B)
- Shipping packaging in e-commerce
Companies must therefore consider and evaluate their entire packaging structure along the supply chain.
It is particularly relevant that a company – depending on its business model – can take on several roles at the same time:
- Manufacturer
- Importer
- Distributor
- EPR-obligated “Producer”
In future, this distribution of roles must be assessed separately for each country and sales channel.
Manufacturer obligations under the PPWR
Even though the PPWR harmonizes many requirements, the basic manufacturer obligations remain in place and will be expanded in some cases. In future, companies must in particular ensure that
1. packaging design and material requirements
- Compliance with design-for-recycling specifications
- Reduction of material usage and empty space
- Consideration of recycled content (mandatory in certain areas in future)
2. data and verification obligations
- Creation of a complete packaging inventory
- Documentation from:
- Material composition
- Weight
- Function
- Recyclability
3. supply chain integration
- Integration of packaging suppliers
- Ensuring the availability of conformity and product data
Effects on national EPR systems
The PPWR harmonizes the packaging requirements to a greater extent, but does not automatically replace the national EPR systems.
This means that
companies must continue to fulfill the following obligations, depending on the country:
- Registration with national authorities or registers
- Participation in take-back systems
- Payment of EPR fees
- Compliance with national reporting obligations
The specific obligation depends on who is considered a producer in the respective country.
What information you should request now:
Companies should already involve their packaging suppliers in a structured manner and request the following information in particular:
- Exact material composition
- Indication of whether monomaterial or composite material
- Weight per packaging component
- Information on recyclability / design-for-recycling suitability
- Information on possible recycled content
- Format, volume and dimensions
- Information on reusability
- available conformity and product documentation
- Clear assignment of packaging components to products or product groups
Pollutants and PFAS
The PPWR also confirms existing limit values:
- Max. 100 mg/kg for the sum of:
- Lead
- Cadmium
- Mercury
- hexavalent chromium
In addition, PFAS restrictions are being introduced for food contact packaging in particular.
PFAS are currently less of a focus for B2B and transport packaging without food contact – but should still be considered in supplier inquiries.
Labelling: Harmonized EU symbols from 2028
The PPWR provides for a harmonized EU labelling system.
The deadlines are:
- Technical specifications until August 2026
- Application expected from August 2028 or later
The plan is:
- EU-wide sorting labels
- Orientation towards existing material codes (e.g. Decision 97/129/EC)
- Supplemented by pictogram-based systems
Important:
- National labeling systems to be discontinued in the long term
- For transport packaging, the requirements do not apply in all cases, especially in the B2B sector to a limited extent
What could the labeling look like?
As things stand at present, it can be assumed that the content of the future labeling system will be based on existing European material labeling logics, in particular Decision 97/129/EC on the material identification of packaging. At the same time, the technical proposal published by the Joint Research Center (JRC) indicates that the future sorting labeling system will also incorporate elements from pictogram-based systems already developed in the Scandinavian and Baltic states. However, the final design has not yet been finalized.
Important for companies:
As things stand, the harmonized sorting marking does not apply across the board to all transport packaging. Classic B2B transport packaging is currently not the main focus here; however, it is not exempt in all constellations, especially not for certain e-commerce packaging. Reusable packaging is also subject to its own labeling requirements.
FAQ - Frequently asked questions about the PPWR
Does the PPWR also apply to B2B and transport packaging?
Yes, the regulation applies in principle to all packaging, including commercial packaging.
Do companies still have to fulfill national EPR obligations?
Yes, the PPWR does not replace national EPR regulations. Registration, volume reporting and fees remain in place.
When do the new labeling requirements apply?
EU-wide labeling is expected to be mandatory from 2028, depending on the final implementing acts.
Practical classification
For companies with industrial supply chains, the PPWR is not just a “consumer packaging issue”. It should already be examined today:
- in which countries the company itself is a producer ,
- which packaging falls under minimization, recycling and reuse requirements,
- and which supplier data will be mandatory in the future.
Our practical advice is therefore:structure
now, build up a database and check roles per country – detailed decisions on final labels and individual technical specifications can then be made after publication of the other EU legal acts.
