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The EU Packaging and Packaging Waste Regulation (PPWR) – what you need to know now

From 12 August 2026, the new Packaging and Packaging Waste Regulation (PPWR) will apply throughout the EU. It replaces the previous EU Packaging and Packaging Waste Directive and introduces harmonised rules for all member states.

The PPWR at a glance

The new EU Packaging and Packaging Waste Regulation (PPWR) will be legally binding in all EU member states from 12 August 2026 and will replace individual national regulations. The regulation is being introduced because – although indispensable for product protection, transport and hygiene – packaging is having an increasing impact on the environment due to the constant rise in volumes. Against this background, the aim of the PPWR is to help make packaging more sustainable across the EU, reduce waste and promote the development of a well-functioning circular economy.

A key element of the PPWR is the clear allocation of roles along a packaging item’s entire life cycle – from the supplier to the manufacturer, producer and importer to the distributors. Each role carries specific obligations, so companies need to assess what roles they play to understand which requirements apply to them.

Legal requirement from 12 August 2026

The PPWR entered into force in February 2025 and will apply directly in all EU Member States from 12 August 2026. It replaces Germany’s previous Packaging Act (VerpackG).

Germany’s Packaging Law Implementation Act (VerpackDG) is the national legislation that sets out competent authorities, enforcement, and supplementary national provisions. Comparable national implementing acts exist in the other EU Member States as well.

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The PPWR combines structural and environmental goals.

Unity

Harmonise packaging
regulations in the EU

Market coherence

Establish a functioning
internal market

Infrastructure

Advance the development of high-quality
sorting and recycling systems

Environment

Decrease the negative
environmental impacts of packaging

Conservation of resources

Reduce (unnecessary)
packaging and waste

Circular solutions (reuse and refill)

Examine packaging life cycles with a focus
on recyclability and reusability
Who is affected?
The timetable

Who is affected?

The PPWR defines the separate roles of
the economic operators.

For the first time, the PPWR establishes specific responsibilities spanning the entire packaging life cycle. Each role comes with its own obligations. This clear role allocation provides legal clarity and ensures that responsibility is assigned in accordance with the polluter-pays principle.

Suppliers

Art. 3.16 – obligations under Art. 16

Any natural or legal person that supplies packaging or packaging material to a manufacturer.





  • Obligations
    • Provision of the necessary information for assessing conformity

Manufacturers

Art. 3.13 – obligations under Art. 15

Any natural or legal person that manufactures packaging or a packaged product or has it manufactured. Exception: micro-enterprises (fewer than 10 employees and a maximum annual turnover of €2 million).


  • Obligations
    • Conformity assessment
    • Technical documentation

    Can be fulfilled by an authorised representative

Producers

Art. 3.15 – obligations depend on function

Any manufacturer, importer or distributor that places packaging or a packaged product on the market for the first time nationally or in another member state or makes it available directly to end users.



  • Obligations
    • Obligations depend on function (manufacturer, importer or distributor)
    • Extended producer responsibility

Importers

Art. 3.17 – obligations under Art. 18

Any natural or legal person established within the Union that places packaging from a third country on the market.




  • Obligations
    • Ensure that the conformity assessment has been carried out by the manufacturer
    • Maintain conformity status during storage and transport

Distributors

Art. 3.18 – obligations under Article 19

Any natural or legal person in the supply chain, other than the manufacturer or importer, that makes packaging available on the market.

    Companies should assess what roles they play to understand which requirements and obligations apply to them.
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    Key dates at a glance

    2025
    2026
    2027
    2028
    2029
    2030
    …
    Substances in packaging (C)
    Recyclability (C)
    Minimum recycled content (C)
    Bio-based plastics (C)
    Composting (C)
    Packaging minimisation
    Packaging minimsation
    Reusable packaging (C)
    Labelling requirements (material composition)
    Labelling requirements (packaging)
    Empty space ratio
    Formats
    Conformity assessment
    Further details
    Implementation
    Effective / Applies from
    C = to be assured through conformity assessment procedures

    Wichtige Fristen im Überblick

    Übersichtsgrafik mit Zeitstrahl von 2025 bis 2030 zu den wichtigsten Fristen der PPWR (Packaging and Packaging Waste Regulation). Aufgelistet sind Themen wie Stoffe in Verpackungen, Recyclingfähigkeit, Mindestrezyklatanteile, biobasierte Kunststoffe, Kompostierung, Minimierung von Verpackungen, Wiederverwendung, Kennzeichnungspflichten (Materialzusammensetzung und Verpackungen), Leerraumquote, Formate und Konformitätsbewertung. Die Balken zeigen, ab wann Detailierungen, Umsetzungen oder Geltungsbeginn vorgesehen sind. Grau steht für „Weitere Detaillierungen“, Dunkelblau für „Umsetzung“ und Hellblau für „Erfüllt/Geltungsbeginn“.

    Overview of key PPWR articles

    The C indicates that the requirements marked with a C must be assessed as part of the declaration of conformity.
    Art. 5 – substances in packaging (C)
    Darstellung einer weißen Kunststoffflasche die von einem grünem Lichtstrahl gescannt wird.

    Substances in packaging

    This article stipulates that certain substances that are harmful to the environment or human health may no longer be contained in packaging. Particular focus is placed on per- and polyfluoroalkyl substances (PFAS) and other substances that make recycling difficult or have an adverse impact on humans and the environment. The exact lists of substances and limit values are supplemented by the EU and may be expanded over time. The goal is to make packaging safer and improve the quality of recycled materials.
    Art. 6 – recyclability (C)

    Recyclability (C)

    Packaging must be designed in such a way that it is technically sortable and recyclable. Recyclability is classified into three classes (A, B, C).

    • Grade A: > 95 % high quality and readily recyclable
    • Grade B: > 80 % recyclable with certain restrictions
    • Grade C: > 70 % low recyclability


    As of 1 January 2038, only packaging in Classes A and B may be placed on the market. The specific design requirements will be defined in a delegated act in January 2028.

    Art. 7 – minimum recycled content (C)
    Weiße Kunststoffsprühflasche löst sich in Rezyklate auf

    Minimum recycled content (C)

    Mandatory minimum percentages of post-consumer recycled content (PCR) have been set out for plastic packaging. The rates depend on the type of packaging:

    Packaging type 2030 2040
    Contact-sensitive material made from PET 30 % 50 %
    Contact-sensitive material made from other plastics (e.g. PP) 10 % 25 %
    Single-use plastic drinks bottles 30 % 65 %
    Non-contact-sensitive packaging made from various plastics 35 % 65 %

    These targets will roll out from 2030 and increase gradually until 2040. The requirements will apply per manufacturer and per packaging category. The goal is to stabilise the market for recycled materials and reduce dependence on primary raw materials.

    Art. 8 – bio-based feedstock in plastic packaging (C)
    Hand hält eine braune Kaffeekapsel vor einer Kaffeemaschine

    Bio-based feedstock in plastic packaging (C)

    The European Commission plans to review the state of technological development and environmental performance of bio-based plastics in packaging by 12 February 2028. On this basis, it may submit specific legislative proposals – for example, to lay down sustainability requirements, introduce bio-based feedstock rates, possibly replace recycled content with bio-based materials in cases of poor recyclability and adjust the definition of “bio-based plastic”. Article 8 thus establishes a data-driven, forward-looking foundation for enabling greater integration of renewable raw materials in packaging.
    Art. 9 – compostability of certain packaging (C)
    Roter Apfel mit Bio-Siegel neben einem Teebeutel vor blauem Hintergrund

    Compostability of certain packaging (C)

    From 12 February 2028, certain packaging formats, such as permeable tea bags, single-use coffee units (“soft capsules”), adhesive labels on fruit and vegetables, and very lightweight plastic bags must be industrially compostable, with member states also being permitted to require home compostability. This compostable packaging is exempt from the recycling obligation, and the Commission may analyse whether other types of packaging should be compostable in the future – but without a fixed time frame for any such extensions.
    Art. 10 – packaging minimisation
    About Us

    Packaging minimisation

    Packaging must be reduced in volume and weight so that it contains only the amount of material necessary to fulfil its functions in terms of protection and information. Key aspects:
    • Empty space ratios: limiting unused volume in shipping and sales packaging
    • Prohibition of unnecessary layers of material or decorative elements that make recycling difficult
    • Use of packaging shapes that are as thin-walled or optimised as possible

    The requirements apply to all types of packaging – with the exception of protected registered or trademarked designs and indications of geographical origin protected under product law – with the aim of preventing unnecessary waste.
    Art. 11 – reusable packaging (C)
    Grünes Recycling-Symbol mit drei Pfeilen

    Reusable packaging (C)

    Article 11 defines when packaging is considered reusable: it must be designed for multiple trips, be collectable in a reuse system and meet hygiene and safety requirements. The European Commission will set binding minimum reuse numbers (“rotations”) for different types of packaging by 12 February 2027.
    Art. 12 – labelling requirements (C)
    Weiße Kartonverpackung mit Recycling-Symbol und Aufdruck „Scatola Raccolta Cartone“

    Labelling requirements (C)

    In future, all packaging must be marked with EU-wide harmonised symbols for correct disposal and additional information about, for example, material composition and reusability. This label must be easily identifiable and legible by consumers and permanently affixed. There are transition periods for existing packaging stocks during which old labels may still be used. The goal is to simplify and improve the separation and recycling of packaging.
    Art. 24 – empty space rules
    Schwarze Kopfhörer-Verpackung in einem offenen Versandkarton mit Papierpolsterung

    Empty space rules

    The PPWR aims to avoid unnecessary empty space in packaging in order to reduce material usage and transport emissions. In online retail in particular, shipping packaging is often significantly larger than necessary – the resulting empty space also includes filling materials such as air cushions, foam or paper. In future, this space must be reduced to the minimum necessary.

    From 2030, the empty space ratio may not exceed 50% of the total volume in the case of grouped, transport and e-commerce packaging. Reusable packaging is exempt from this requirement.
    Art. 25 – format restrictions
    Picture depicting: Single-use plastic nets for fresh fruit and vegetables, Single-use plastic plates and cups, Single-serve "takeaway" portions e.g. coffee creamer, sugar sachets and small hotel toiletries.

    Format restrictions

    In the future, certain single-use packaging and containers, especially in the catering, food service and food retail sectors, will no longer be allowed to be placed on the market. These include, for example, single-use food containers for immediate consumption on the spot or plastic packaging for certain portion sizes. The aim is to reduce short-life packaging waste and promote reuse systems.
    Art. 39 – conformity assessment
    Picture of a sheet of paper containing following text: Content in accordance with Annex VIII Unique identification of the packaging Name & address of the manufacturer (or, where applicable, of the authorised representative) Description of the packaging for the purpose of traceability Product & legal conformity References to standards/specifications Possibly: certification body Signature

    Conformity assessment

    From 12 August 2026, companies must hold a declaration of conformity (C) for each type of packaging they place on the market. With this self-declaration, they confirm that the packaging in question complies with the requirements of Articles 5 to 12, 24 and 26 of the PPWR and meets all applicable technical standards. Manufacturers, producers and distributors are obliged to archive these documents and make them available to the competent authorities upon request.
    Only
    Days
    :
    Hours
    :
    Minutes
    :
    Seconds
    until application of the PPWR

    Why it makes sense
    to prepare well in advance.

    Addressing the new requirements in good time helps companies to plan with certainty and gives them the opportunity to develop strategies and implement changes to processes and materials step by step. Preparing in advance can also help to avoid potential shortages of recycled materials or alternative packaging solutions.
    360

    Zentek – 360° service for PPWR

    The Zentek Group provides various support formats to help companies prepare for the upcoming Packaging Ordinance (PPWR). These include webinars, explanatory information materials and accompanying services to help companies understand and implement the future requirements. The services are aimed at companies that want to familiarise themselves with the contents of the PPWR at an early stage and plan the necessary steps.

    offered PPWR Services

    What should you do now?

    A practical five-step
    guide to organising implementation:
    Mitarbeiter Zentek
    Step 01

    Clarify role(s)

    Assess which role(s) your company plays – as a supplier, manufacturer, producer, importer and/or distributor.
    Frau betrachtet aufmerksam eine Kosmetikflasche im Geschäft
    Step 02

    Analyse packaging, obtain/gather specifications

    Check your existing packaging as regards specifications, recyclability, material usage and labelling.

    Designer arbeitet am Computer an einem 3D-Modell einer blauen Verpackungsflasche
    Step 03

    Implement requirements

    Plan the necessary adjustments step by step, e.g. in terms of design, materials or labelling.
    Geschäftsfrau arbeitet am Schreibtisch mit Laptop und unterzeichnet Dokumente
    Step 04

    Prepare evidence

    Make sure that you have complete technical documentation and regularly update the declaration of conformity.
    Weißes Recycling-Symbol mit blauen Kunststoffpartikeln auf blauem Hintergrund
    Step 05

    Develop a recycled materials strategy

    Secure reliable supplies of the required recycled content in advance.
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      Penalties for infringements
      of the PPWR

      Failure to comply with the PPWR can have serious consequences for companies. In addition to legal penalties, there is a risk of incurring financial sanctions and reputational damage. The possible penalties range from the exclusion of individual packaging items from the market to substantial fines, with the exact amounts applicable to Germany being determined by February 2027 at the latest.

      Exclusion from
      the market

      Non-compliant packaging may not be placed on the market.

      Sales ban

      Packaging already on the market may not continue to be sold if infringements are identified.

      Financial consequences

      Possible fines and loss of revenue

      Reputational risk

      Significant damage to image with possible long-term impacts

      Level of fines

      Not yet determined; no later than 12 February 2027 in Germany.

      National differences

      Penalties and regulations may vary between EU member states.

      Authorised representative in the EU – mandatory under the PPWR

      The PPWR makes appointing an authorised representative mandatory whenever companies place packaging on the market in an EU member state in which they are not themselves located.

      The authorised representative assumes responsibility for compliance with national extended producer responsibility (EPR) regulations. Duties include:

      • Communication with the competent authorities
      • Fulfilment and documentation of all reporting obligations
      • Ensuring compliance with country-specific packaging requirements








      In Germany, this is governed by Section 5 VerpackDG (applicable from 12 August 2026) (new):

      • The appointment must be made before the first time packaging is made available on the German market
      • The authorisation/power of attorney must be issued in writing and in German
      • The authorised representative must be notified to the ZSVR without undue delay after appointment
      • The notification is made as part of the registration process (Section 6 VerpackDG) and requires confirmation by the ZSVR
      • Important: Registration and data reporting cannot be carried out by the authorised representative – these obligations remain with the producer/manufacturer
      We can take on the role of authorised representative for you and make sure you’re compliant in all the relevant markets.
      Let’s talk
      More about EPR

      Case studies

      Illustrative example: Ensuring EPR compliance in other EU countries – with Zentek as your authorised representative

      We’re here to help you.

      We see the PPWR as an opportunity and will give you proactive, comprehensive support in interpreting and fulfilling your obligations.
      PPWR consultation and analysis
      Impacts of the PPWR on your business
      Design for Recycling
      Packaging optimisation to ensure high recyclability
      clozed loop™
      Establishment of closed resource cycles to secure long-term demand for recycled materials
      Let’s talk

      Further important questions about the PPWR

      What changes are there for single-use packaging?

      From 2030, extensive restrictions on single-use packaging will apply in the EU. Specifically, from 1 January 2030, various types of single-use packaging will no longer be allowed to be placed on the market (see Annex V of the PPWR). These include:

      – Single-use plastic outer packaging used at the point of sale to bundle goods, e.g. outer packaging film, shrink film

      – Single-use plastic packaging for unprocessed fresh fruit and vegetables, e.g. nets, bags, trays, containers

      – Single-use plastic packaging for food and beverages filled and consumed on the premises of the hospitality industry, e.g. trays, disposable plates and cups, bags, films, crates

      – Single-use plastic packaging for condiments, preserved foods, sauces, coffee cream, sugar and spices in the hospitality industry, e.g. packets, containers, trays, boxes

      – Single-use packaging for the accommodation sector intended for a single booking, e.g. shampoo bottles, bottles for hand and body lotion, packets for small soap bars

      – Very lightweight plastic carrier bags, e.g. very thin carrier bags for loose food (unless they are required for hygiene reasons or intended as primary packaging for loose food) 

      How do PPWR and the German Packaging Act (VerpackG) differ?

      The PPWR will replace Germany’s previous Packaging Act (VerpackG) as of 12 August 2026. Germany’s Packaging Law Implementation Act (VerpackDG) was adopted by the Bundestag and will enter into force on 12 August 2026. It serves as Germany’s national implementation, enforcement and competence framework, and provides supplementary provisions in relation to the PPWR.

      While the PPWR sets out the substantive requirements for packaging and applies directly in all EU Member States, the VerpackDG governs national responsibilities, enforcement, and Germany-specific supplements.

      What is important now?

      First, companies should clearly define the role or roles they will assume under the PPWR. Only those who know their role can correctly fulfil the associated obligations – this is currently the most important focus.

      In view of the time constraints, producers should start preparing for the declaration of conformity at an early stage. This requires collecting data and evidence on the respective type of packaging. The declaration of conformity is one of the first binding obligations from the date of application, which is why timely preparation is crucial. 

      Do the rules also apply to imported goods from third countries?

      Yes. The PPWR applies to both EU-based companies and companies that import packaging or packaged products into the EU. This means that all products entering the EU market must comply with the PPWR requirements, regardless of the country of production.

      Packaging from third countries may only be placed on the market if it complies with the requirements and appropriate conformity assessment procedures have been carried out. Importers are obliged to ensure that the necessary evidence is available and provided to the authorities upon request. 

      What happens to remaining stocks of non-compliant packaging?

      Once the respective transition periods have expired, non-compliant packaging may no longer be placed on the market or sold.

      However, a one-time exception applies to remaining stocks that were already manufactured or imported before the deadlines expired: they may continue to be made available on the market for up to three years after the respective labelling requirements come into force. After that, their use is permanently prohibited. 

      To which types of packaging does the PPWR apply?

      The PPWR applies to all packaging and all packaging waste, regardless of the material used. It covers all types of packaging – from sales, service and shipping packaging to transport packaging and special packaging. The regulations apply in all areas where packaging is used or becomes waste: industry, trade, administration, the service sector and private households. 

      How does Zentek support you in implementation?

      Zentek accompanies you as a partner and reliable mediator on the path to PPWR compliance. We are at your side – from initial orientation to operational implementation. Our range of services includes initial consultations, webinars, customised workshops, design for recycling, closed loopTM solutions and acting as your authorised representative to provide you with reliable support in all regulatory requirements.

      360 Service
      Support you can rely on.
      You want to be certain that processes are effective, rules are followed and help is available whenever you need it. Our transparent, reliable and practical services are designed to satisfy all of these needs.
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      Expertise

      We continuously analyse and adapt to the latest requirements and market developments. We help companies understand which requirements are relevant to them now and which will be in the future.
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      We take a practical approach to resolving individual issues, developing specific recommended actions that combine legal certainty with cost-effectiveness.
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      Legal certainty

      All processes – from packaging design to volume reporting – are based on current requirements. Companies act in compliance with the rules at all times.
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      Implementation

      From dual-system participation to reporting, in addition to planning measures, we also provide operational support until quantifiable results are achieved.
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      Efficiency

      Complex processes are structured, digitally supported and clearly documented. This reduces internal effort and creates space for core business activities.
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