With the first obligations taking effect on 12 August 2026, companies will face new requirements relating to labelling, declarations of conformity, substance restrictions and producer responsibility. Most importantly, the PPWR affects companies across virtually all industries and no longer distinguishes between B2B and B2C packaging.
The content of this article is based on our expert webinar on the PPWR featuring Justus Hoffmann, Business Lawyer and Product Compliance Expert at Munich Consulting Group.
The PPWR as Part of the EU Green Deal.
The PPWR is part of the European Green Deal and aims to reduce packaging waste, increase recycling rates, and strengthen the circular economy across the European Union. Unlike its predecessor, the PPWR is no longer a directive but a directly applicable regulation. As a result, its requirements will apply uniformly and directly across all EU Member States.
At its core are the “3Rs”: Reduce, Reuse, and Recycle. The regulation covers the entire life cycle of packaging and packaging waste, regardless of material, industry, or country of origin.
Packaging is no longer just a logistical consideration. It is becoming a compliance topic in its own right.
Who Is Affected by the PPWR?
Many companies still assume that the new requirements primarily affect consumer goods manufacturers and traditional B2C businesses. In reality, the scope is significantly broader.
The PPWR does not fundamentally distinguish between B2B and B2C. What matters is the function of the packaging itself. As a result, industrial manufacturers, machinery and plant engineering companies, automotive businesses, retailers, e-commerce providers, private label manufacturers, importers and distributors are all potentially affected.
Transport packaging and internal packaging solutions may also fall within the scope of the regulation.
The PPWR does not only affect B2C businesses. Industrial companies, machinery manufacturers and automotive organisations are impacted as well.
„The PPWR does not distinguish between B2B and B2C. Packaging is packaging.“
Justus Hoffmann
Business Lawyer and Product Compliance Expert at Munich Consulting Group.
Key PPWR Milestones.
Implementation will take place gradually over several years. The regulation officially entered into force in February 2025, while the first binding requirements will apply from 12 August 2026.
Additional obligations will follow in the years ahead, including new labelling requirements, recyclability criteria, recycled content targets and reusable packaging requirements.
Companies should therefore view the PPWR not as a one-off compliance project, but as a long-term transformation of their packaging strategy.
12 August 2026 marks the start of the first binding obligations.
Packaging Is Not the Same as Packaging Material.
One of the most important aspects of the PPWR is its revised understanding of what constitutes packaging. The regulation clearly distinguishes between packaging material and an actual packaging unit.
Materials such as cardboard, filling materials, films and adhesive tapes are initially considered packaging materials only. They become packaging within the meaning of the PPWR only when they form the final packaging solution together with the product.
This distinction has direct implications for responsibilities, documentation requirements and conformity assessments.
Roles and Responsibilities Under the PPWR.
The PPWR redefines the responsibilities of various economic operators and assigns specific obligations to each of them. In particular, the roles of producer and manufacturer are highly relevant.
A producer is the party that manufactures packaging or packaged products, or has them manufactured under its own name. Producers are responsible for conformity, labelling, technical documentation and declarations of conformity, among other obligations.
A manufacturer is the party that first places packaging on the market in an EU Member State. This role involves registration, reporting and Extended Producer Responsibility (EPR) obligations, among others.
Importantly, a company may assume multiple roles at the same time depending on the packaging concerned.
In many cases, the company named on the packaging is also responsible for regulatory compliance.
Key Requirements Taking Effect from 2026.
With the first requirements becoming applicable in August 2026, companies will face a range of new obligations.
These include new labelling requirements, the preparation of EU declarations of conformity for packaging and the establishment of technical documentation.
In addition, substance restrictions for certain materials used in packaging will apply. Extended producer responsibility and national registration requirements will also become increasingly important.
For many organisations, the greatest challenge is not a single requirement but the systematic collection and management of all necessary data and supporting documentation.
Labelling, declarations of conformity and technical documentation will become standard requirements.
Why Companies Should Act Now.
Although many requirements will be introduced gradually, the necessary preparation begins today. Companies need to analyse existing packaging structures, define responsibilities, establish data processes and integrate suppliers more closely into compliance activities.
The challenge lies in the broad range of topics involved, including regulatory requirements, material data, packaging labelling, supplier documentation, recyclability, recycled content and reuse targets.
As a result, the PPWR affects far more than Product Compliance and Sustainability teams. Procurement, Engineering, Logistics and Sales functions will also play an important role.
Taking a Strategic Approach to the PPWR.
Successful implementation starts with transparency. Companies need a clear understanding of the packaging they use, the roles they assume and the data that is already available.
Based on this foundation, regulatory risks can be assessed, responsibilities assigned and implementation measures prioritised. At the same time, organisations can prepare for future requirements relating to recyclability, recycled content targets and enhanced labelling obligations.
The PPWR is far more than another labelling requirement. It fundamentally changes the role of packaging throughout the entire value chain.
Successful implementation begins with transparency regarding packaging, data and responsibilities.
Webinar Recording & Next Steps.
Would you like to gain a deeper understanding of the PPWR and learn how the regulation affects your packaging, processes and responsibilities?
In our webinar recording, Packaging in Transition, we explain the roles companies may assume under the PPWR, the obligations that become relevant from 2026 onwards and how these requirements can be translated into practical business processes.
You will also receive practical recommendations for the first implementation steps as well as insights into common challenges faced by companies in practice.
Please note: The webinar is conducted in German.
Practical examples, role clarification and actionable recommendations in our webinar recording.
Take the Next Step with Our PPWR Workshop.
As a structured starting point for implementation, we offer a practical PPWR workshop. Together, we analyse your specific situation, identify relevant requirements and develop initial measures tailored to your organisation.
The workshop helps you clarify roles and responsibilities, assess regulatory risks, create transparency regarding packaging data and establish a robust implementation roadmap.
This transforms regulatory requirements into a clear and actionable plan for your business.
From understanding requirements to building a practical implementation roadmap.
