Disposal of transport packaging
Transport packaging protects goods during transport between manufacturers, retailers and logistics centres. It typically arises at commercial points of generation (e.g. retail warehouses, construction sites, hospitality businesses) rather than as packaging waste in private households.
Under the PPWR, manufacturers and distributors are required to take back this packaging and ensure it is sent for recovery/recycling. At national level, the Packaging Law Implementation Act (VerpackDG) sets out in particular competent authorities and enforcement, as well as supplementary provisions within the framework of EU requirements.
The aim is to prevent waste, strengthen recycling and thereby secure valuable raw materials.
Obligations at a glance
- Registration in the LUCID packaging register
- Ensure transport packaging is taken back (from customers)
- Return of materials to the circular system
- Evidence and reporting requirements
The principle
Producers and distributors are required to take back transport packaging from their commercial customers after use. The producer or distributor organises collection or provides collection points. The packaging is then sorted, recycled or reused. Evidence of volumes and recovery methods must be kept and reported regularly to ensure transparency and legal certainty.
Note (from 2028 – Producer Responsibility Organisations): In the future, approved Producer Responsibility Organisations (PROs) are expected to play a role in the take-back and recovery of transport packaging. As the details and authorisation criteria are still being defined, we are closely monitoring developments and aligning our processes early – so that B2B take-back continues to be organised reliably and companies can meet their obligations consistently.
Obligation
Waste generation
Storage and collection
Recovery
valuable raw materials are not lost.
The PPWR creates a single EU framework.
With the Packaging and Packaging Waste Regulation (PPWR), which will apply from 12 August 2026, transport packaging and commercial packaging will also come more strongly into focus. Going forward, producers and importers will need to demonstrate across the EU that such packaging is recyclable, that take-back systems are in place, and that the quantities collected are reported transparently.
Harmonised rules
– the same requirements for all member states.
Less effort
More certainty
clear and binding standards.
In summary:
The EU-wide requirements of the PPWR are supplemented in Germany, from 12 August 2026, by the national implementation and enforcement provisions set out in the VerpackDG. Any business that delivers goods in multiple member states must prepare to meet harmonised, stricter requirements – both in the design of transport packaging, particularly with regard to reusability, and in terms of
evidence and reporting obligations.
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Zentek – 360° service for transport packaging
The Zentek Group offers practical support for the legally compliant return and recycling of transport packaging. This includes the organisation and documentation of return processes, individual industry solutions and services for the efficient fulfilment of legal requirements along the supply chain.
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