145 answers on packaging compliance.

The PPWR (Packaging and Packaging Waste Regulation) is the new EU regulation on packaging and packaging waste. It replaces the previous Directive 94/62/EC and creates a directly applicable, EU-wide legal framework for all packaging placed on the internal market. Its aim is to regulate the entire life cycle of packaging — from design and manufacture through labelling to reuse and recycling.

The EU packaging regulation (PPWR) defines binding requirements in several core areas: sustainability requirements for packaging design (e.g. recyclability, material minimisation), minimum shares of recycled plastic (recycled content), labelling duties for material identification and disposal, restrictions on certain packaging formats (e.g. single-use packaging in hospitality), the duty to draw up a declaration of conformity, and requirements for reuse and refill systems.

The PPWR affects every economic operator dealing with packaging on the EU market: packaging manufacturers, fillers and packers, importers of packaged products from third countries, retailers and distributors, fulfilment service providers and online marketplaces. Companies based outside the EU also fall under the regulation as long as they offer packaged products on the European internal market. The specific duties depend on your role in the value chain.

Yes. The PPWR applies in principle to every company placing packaging on the EU market — regardless of size. For certain requirements the regulation provides relief and longer transition periods for SMEs, for example on minimum recycled content. Even so, small companies still have to meet the basic duties such as recyclability and the declaration of conformity. Engaging with the requirements early is advisable for SMEs too.

As an EU regulation, the PPWR applies directly in all 27 EU member states — without needing to be transposed into national law. That means the requirements apply in Germany just as they do in France, Italy, Spain, Poland, the Netherlands and every other member state. For the EEA (European Economic Area), incorporation into the EEA Agreement is envisaged.

Failing to comply with the PPWR carries serious consequences: market surveillance authorities can impose sales bans on non-compliant packaging, fines within the national sanction framework, recall obligations for products already placed on the market, and reputational damage with customers and business partners. The exact level of sanctions is set by the member states, but the EU sets the framework. Companies that build their compliance in a structured way early minimise this risk.

The essential difference: the previous Directive 94/62/EC had to be transposed into national law by each EU member state, which led to different rules in every country. The PPWR, by contrast, is a regulation — it applies directly and uniformly across all EU states. In substance the PPWR is considerably more comprehensive: it contains more concrete recyclability requirements, binding minimum recycled-content shares for the first time, new labelling duties and an explicit duty to draw up a declaration of conformity.

The PPWR replaces the previous EU packaging directive and will take precedence over national laws in the areas it governs. The German Packaging Act (VerpackG) will be amended or repealed in the parts covered by the PPWR. National rules can, however, remain in areas the PPWR does not govern exhaustively — for example specific deposit systems or extended producer responsibilities. Companies should keep both levels in view.

A declaration of conformity (DoC) is a legally binding document with which the responsible economic operator declares that a packaging meets all applicable requirements of the PPWR. The DoC serves as the central proof of compliance and must be producible during market surveillance, audits or on request from authorities and business partners. It is comparable to CE declarations of conformity for products, but relates specifically to packaging.

The duty to draw up a declaration of conformity lies with the manufacturer of the packaging, or with the economic operator who first places the packaging on the EU market. For imported products the importer is responsible. In practice that means: whoever designs, manufactures or first fills a packaging with a product and brings it onto the EU market must ensure a DoC exists and is available.

A PPWR-compliant declaration of conformity must contain at least the following: name, trade name and contact details of the responsible economic operator; unambiguous identification of the packaging (article number, description, image); a declaration that the packaging meets the applicable PPWR requirements; details of the material composition and recyclability; details of the recycled content (for plastics); reference to the harmonised standards or technical specifications applied; the date, name and signature of the responsible person.

The declaration of conformity must be in writing — digital or on paper. It must be available in one or more official languages of the EU member state in which the packaging is placed on the market. An English version is advisable but not sufficient on its own if the authorities require a national language. Digital formats such as PDF are common and accepted. Important: the DoC must remain retrievable for the entire life of the packaging plus the retention period.

The DoC must be updated as soon as relevant parameters change — the material composition, the recycled content, the packaging structure or the regulatory requirements themselves. There is no fixed update interval (annually, say), but a regular review is advisable, particularly after packaging changes, supplier changes or new delegated acts from the EU. A DoC generator can simplify this considerably, because changes flow directly into the existing documentation.

The declaration of conformity does not have to be filed proactively with an authority. It must, however, be producible on request from the competent market surveillance authority within a reasonable period. Companies are obliged to keep the DoC and the associated technical documentation for at least 10 years from the date the packaging was placed on the market. A structured digital archive — for example through a PPWR tool — makes access much easier when it is needed.

In principle yes: every packaging placed on the market must be covered by a DoC. Packaging with identical materials, identical structure and identical properties can, however, be combined into one DoC (grouping or family declaration). The condition is that all grouped packaging genuinely meets the same compliance requirements. Where they differ — different plastic shares, for instance — separate DoCs are required.

An incomplete or faulty declaration of conformity can lead to the packaging being classified as non-compliant — with the same consequences as a lack of compliance: sales bans, fines and possible recall obligations. Beyond that, a deficient DoC can damage the confidence of business partners, who increasingly demand PPWR compliance as a procurement criterion. Systematic documentation — ideally supported by a DoC generator — considerably reduces the risk of error.

The PPWR takes effect in stages. After publication in the Official Journal, general provisions and institutional rules apply first. The specific substantive requirements — such as recyclability, minimum recycled content and the declaration of conformity duty — become mandatory in phases over several years. The exact dates vary by requirement area and packaging type. Companies should set up their compliance roadmap now to keep every deadline in view.

The PPWR introduces binding recyclability requirements for all packaging. Packaging must be designed so that it can be effectively recycled after use. The assessment uses criteria such as sortability, separability of materials and the availability of recycling infrastructure. From certain key dates, packaging must demonstrate a minimum recyclability that rises in defined steps. Packaging that does not meet these criteria may in due course no longer be placed on the market.

The minimum recycled content sets out what minimum percentage of the plastic used in a packaging has to consist of recycled material (post-consumer recyclate). The PPWR provides for staged targets that rise over the years. This requirement is intended to strengthen demand for secondary raw materials and promote the circular economy. Companies must evidence the recycled content and document it in the declaration of conformity.

The PPWR introduces harmonised labelling duties for packaging. These include: information on material composition for correct disposal by consumers, harmonised EU symbols (instead of individual national solutions), machine-readable information (e.g. digital watermarks or QR codes) and information on recyclability and reusability. The exact formats and symbols are specified in delegated acts.

Yes, the PPWR provides transition periods that allow companies to adapt their existing packaging and processes to the new requirements. Packaging placed on the market before the respective requirement took effect generally enjoys grandfathering for a defined period. New packaging and substantially modified packaging must meet the requirements from the respective key date.

The PPWR contains provisions to promote reuse and refill systems. Among other things it provides that certain packaging categories (transport packaging, hospitality) must meet binding reuse targets. Beyond that, the regulation creates the framework for EU-wide deposit systems, particularly for single-use beverage packaging and single-use cups. The exact targets and implementation deadlines are set in detail by delegated acts.

The European Commission will adopt numerous delegated acts under the PPWR that set out concrete technical detail. Planned are, among others: criteria and methods for assessing recyclability, detailed requirements for evidencing recycled content, harmonised formats and symbols for packaging labelling, specifications for digital product passports for packaging, and requirements for reuse systems. These acts will be published successively and supplement the main regulation.

On 12 August 2026 the core provisions of the PPWR become directly applicable. From that key date, only packaging that complies with the PPWR may be placed on the market. That covers in particular: compliance with the substance restrictions (heavy metals under the 100 ppm sum rule, PFAS in food packaging), the recyclability requirements, the ban on greenwashing in environmental claims, and the duty to draw up a declaration of conformity together with the producer duties under Art. 15.

From 12 February 2027, EU member states must effectively apply their national sanction rules and EPR labelling on packaging becomes mandatory. From 12 August 2027 the official producer register must be in place and registration of producers possible. Anyone not registered by then may no longer place packaging on the market. For multi-country distribution that means: complete the registration in every relevant EU country in good time.

From 12 February 2028, binding requirements on packaging minimisation and the 50 % empty-space limit take effect. From 12 August 2028 the harmonised labelling duties bite: packaging must carry uniform EU material and disposal symbols, digital labelling (QR codes) is introduced, and information on the substances contained must be disclosed.

1 January 2030 is a central milestone: the minimum recycled-content shares for plastic packaging become binding (around 30–35 % PCR for contact-sensitive PET beverage bottles, for example), the packaging bans under Annex V take effect (among others single-use hotel cosmetics and single-use fruit and vegetable packaging under 1.5 kg), reuse targets become mandatory for certain categories, and all packaging must reach at least recyclability grade C.

From 1 January 2035 the “recycled at scale” criterion applies — packaging must no longer be merely theoretically recyclable but demonstrably recycled effectively at scale across Europe. From 2038 only packaging in recyclability grades A and B is permitted (>90 % recyclability); grade C then becomes inadmissible. From 2040 the minimum recycled-content shares rise considerably (to around 65 % PCR for PET bottles, for instance). These long-term targets should already feed into today’s product development.

The PPWR requires comprehensive documentation of your packaging data. That includes: material composition (all materials used and their weight shares), packaging structure (layers, composites), dimensions and weights, recycled content for plastic packaging, the recyclability assessment, information on heavy metal and PFAS content, supplier data and evidence of origin for recyclates. This data forms the basis of the declaration of conformity and must be traceable and verifiable.

For complete PPWR compliance you need: the declaration of conformity (DoC) for every packaging or packaging family, technical documentation of the material composition, evidence of recyclability (e.g. from certified test bodies or design-for-recycling assessments), certificates or supplier declarations on recycled content, laboratory analyses of heavy metal content and, where applicable, PFAS, and documentation of the labelling. Filing all of this evidence in a structured way is a core task of packaging compliance.

The recyclability of a packaging is assessed against the criteria defined in the PPWR and its delegated acts. In practice the evidence covers an analysis of material composition and separability, an assessment of compatibility with existing sorting and recycling infrastructure, a classification under the defined assessment scheme (e.g. grade A to E) and documentation as part of the technical file and the DoC.

The recycled content must be substantiated by traceable evidence. Common methods are: supplier declarations stating the post-consumer recyclate share, certifications by recognised schemes (e.g. RecyClass, EuCertPlast, ISCC PLUS), chain-of-custody evidence along the supply chain, and independent laboratory analyses. The figures are documented in the DoC and must be traceable in audits or on request from authorities.

Yes, existing packaging data from ERP systems (SAP, Microsoft Dynamics), PLM systems or product databases can be used as a starting point. In many companies basic data such as materials, weights and article numbers already exists. For PPWR compliance, however, this data has to be supplemented with specific information — recyclability assessments and recycled-content shares, for example. Reguly’s DoC generator is designed to take in existing data and add the PPWR-relevant fields in a targeted way.

The PPWR provides that the declaration of conformity and the associated technical documentation must be kept for at least 10 years from the date the packaging was placed on the market. This retention duty applies to the responsible economic operator and, for importers, to the imported products. Digital, structured documentation ensures that all evidence is quickly findable and complete even years later.

A systematic PPWR compliance process covers several steps: taking stock of all packaging and its materials, a gap analysis against the PPWR requirements, prioritising the areas of action by deadline and risk, building a data collection process for packaging data, implementing a DoC creation process, regularly reviewing and updating the documentation, and monitoring new regulatory developments.

PPWR compliance is the responsibility of management, but is typically steered operationally by specialist functions: compliance managers or regulatory affairs teams, quality management, packaging engineering, and purchasing/procurement (for supplier data and recyclates). In smaller companies one person often covers several roles. What matters is that clear ownership is defined and the necessary resources are provided.

Good audit preparation covers: complete and current DoCs for all relevant packaging, structured technical documentation with all evidence, clear allocation of responsibilities inside the company, evidence of a systematic compliance process, and documentation of changes and updates. The key is documentation that is complete and retrievable at any time — ideally digital and centrally organised, so that all files can be provided quickly when an authority asks.

A compliance roadmap is a structured plan that visualises all PPWR requirements, their deadlines and your company’s current level of fulfilment. It helps to set priorities, plan resources and measure progress. Instead of having to tackle every requirement at once, you can concentrate on the most time-critical and business-relevant topics. Reguly’s compliance roadmap shows your team at a glance what is already met, what comes next and where action is critical.

Involving suppliers is decisive, because much PPWR evidence — particularly on material composition and recycled content — can only be produced with data from suppliers. Recommended steps: communicate the PPWR requirements to all relevant suppliers, define clear data requirements and delivery dates, obtain supplier declarations on materials and recyclates, integrate supplier data into your own documentation process, and review and update supplier information regularly.

PPWR compliance affects several departments: regulatory affairs / compliance (overall responsibility, DoC creation), packaging / R&D (material selection, design for recycling), purchasing (supplier data, recyclate sourcing), quality management (testing and documentation), production (implementing the packaging specifications), marketing (labelling and communication) and logistics (transport packaging, reuse systems). A cross-functional approach is decisive for efficient compliance.

Several approaches are available for PPWR compliance: specialised PPWR software such as Reguly that covers the whole compliance process, general compliance management systems with packaging extensions, spreadsheet-based in-house builds for smaller portfolios, and consulting services with manual documentation. Specialised PPWR tools have the advantage that they already model the specific requirements of the regulation in the system — from data capture through DoC creation to monitoring deadlines and changes.

A DoC generator automates the creation of declarations of conformity for packaging. Instead of creating every DoC manually in Word or Excel, you record your packaging data in a structured system and the generator produces a professional, complete document from it. Advantages: consistency across all DoCs, a completeness check of all mandatory fields, time-saving creation, easy updating when things change, and audit-proof filing.

Reguly’s DoC generator takes you through all the information required for the declaration of conformity in a guided process. You upload your existing packaging documents or record the data manually. The system extracts and structures the relevant information, checks it for completeness and plausibility, and generates a finished, PPWR-compliant DoC as a PDF. The whole process usually takes a few minutes per packaging — instead of hours or days when done manually.

Yes, a specialised PPWR tool can present the current compliance status of all your packaging clearly. Reguly’s PPWR check, for example, gives you a first, free quick assessment of your readiness level. In the full dashboard you then see per packaging: which requirements are already met, where data is still missing, which deadlines come next and which measures should be prioritised.

Yes, PPWR software can be worthwhile even for companies with a smaller packaging portfolio — particularly where there are no specialised compliance resources in-house. A PPWR tool provides a ready-made structure for documentation, makes sure no mandatory information is forgotten, and saves time in creating DoCs. Especially for SMEs without their own compliance department, a specialised tool can lower the barrier to PPWR compliance considerably.

General compliance management systems offer a broad functional framework but are not tailored to the specific requirements of the PPWR. A specialised PPWR solution offers: pre-configured data fields for packaging materials and structures, integrated DoC generation to PPWR requirements, automatic tracking of PPWR-specific deadlines, assessment logic for recyclability and recycled content, and continuous updates as the rules change. The difference lies in depth and specialisation — not in breadth.

A static DoC template (as a Word document, say) can serve as a start but quickly reaches its limits: templates have to be filled in manually, completeness is not guaranteed, updates are error-prone and managing several DoCs becomes unwieldy. A DoC generator, by contrast, makes sure all mandatory fields are filled, produces consistent professional documents, allows easy updates and provides central filing. For companies with more than a handful of packaging types the advantages of a generator clearly outweigh those of a template.

A declaration of conformity (DoC) is an official document with which the producer confirms that a packaging meets all applicable requirements of the PPWR (substance restrictions, recyclability, minimisation and so on). It is a precondition for legally placing packaging on the EU market.

A producer is any natural or legal person who manufactures, or has manufactured, packaging or packaged products under their own name or brand. If you have products filled by a contract manufacturer but sell them under your own brand, you are generally the producer within the meaning of the regulation.

The core duties include ensuring conformity (Art. 5–12), carrying out the conformity assessment, issuing the EU declaration of conformity, maintaining the technical documentation, registering in the producer register and meeting labelling duties. Producers carry the main responsibility for marketability.

The technical documentation and the EU declaration of conformity must be kept for at least 5 years from the date the packaging is placed on the market. On request from market surveillance authorities, the documents must be producible within a few working days.

An EU-wide register in which all packaging manufacturers and producers have to register before placing packaging on the market (Art. 44). It serves to increase transparency and enforceability. The registration duty applies from August 2027.

Without a valid registration, packaged products may no longer be distributed in the EU. National authorities maintain the registers; the rules on how they are set up are adopted centrally by the Commission. Online marketplaces are additionally obliged to check registration before enabling a trader.

The technical documentation is the basis of the declaration of conformity. It must include a description of the packaging, its manufacturing process, information on the relevant requirements (heavy metals, PFAS, minimisation, recyclability) and test reports.

Extended producer responsibility (EPR) obliges manufacturers and importers to take financial and organisational responsibility for the entire life of their packaging — including collection, sorting and recycling. Under the PPWR the EPR requirements are harmonised EU-wide, while the actual implementation continues to run through national systems (in Germany, for example, the dual system with the Zentrale Stelle Verpackungsregister).

LUCID is the packaging register run by the Zentrale Stelle Verpackungsregister (ZSVR) in Germany. Every producer who first places packaging filled with goods on the market in Germany must register with LUCID before doing so — regardless of turnover or volume. Registration is a precondition for lawful participation in a system. Under the PPWR, EU-wide registers will additionally be built from August 2027, but LUCID remains the primary national register in Germany.

The licence fee depends on the material type and the volume placed on the market (in kg). Each material has its own tariff, which changes annually and differs between system operators. Plastic is typically the most expensive, glass and paper considerably cheaper. Under the PPWR the calculation logic is additionally supplemented by eco-modulation: recyclable packaging gets cheaper tariffs, poorly recyclable packaging pays surcharges.

Eco-modulation means that EPR contributions are graded on the basis of a packaging’s environmental properties. Packaging with high recyclability (performance grade A or B under the PPWR) pays lower contributions; non-recyclable packaging (grade D/E) is subject to malus surcharges. The aim is a financial steering effect towards circular packaging design. The PPWR makes introducing this grading binding for member states.

Yes — the EPR duty applies in every EU member state in which you place packaged goods on the market. Anyone selling in several EU countries (through online shops, say) generally has to register separately with an approved system in each country. The PPWR harmonises the basic rules, but the systems themselves remain nationally organised. There are service providers offering multi-country EPR registration as an all-round service.

Manufacturers established outside an EU member state must appoint an authorised representative in every country in which they place packaging on the market, who takes over the EPR duties (including registration, reporting and contribution payments). The PPWR makes this rule binding EU-wide. Companies without an EU establishment — from the US or China, say — cannot lawfully place packaging on the EU market without this step.

The PPWR tightens the limits for substances of concern in packaging (Art. 5). In particular the use of PFAS (per- and polyfluoroalkyl substances) in food packaging is heavily regulated. Such substances must be reduced to a technical minimum.

Art. 5 PPWR fleshes out the existing substance restrictions and adds new groups. Central restrictions: heavy metals (lead, cadmium, mercury, chromium VI) under the familiar 100 ppm sum rule, PFAS (per- and polyfluoroalkyl substances) in food packaging, substances of very high concern (SVHC) under REACH above defined concentrations, bisphenols in certain applications, and further candidate substances that can be added through delegated acts.

The PPWR keeps the 100 ppm sum rule familiar from the packaging directive: lead, cadmium, mercury and hexavalent chromium together must not exceed 100 mg/kg (ppm) in the packaging. Evidence is typically produced by X-ray fluorescence (XRF) or ICP-MS laboratory analysis. For certain recycled materials (waste glass, for example) temporarily higher limits are possible under conditions, but they are narrowly bounded.

The 100 ppm sum rule states that the sum of the concentrations of lead, cadmium, mercury and chromium VI in a packaging must not exceed 100 mg/kg (that is, 0.01 per cent by weight). The value relates to the whole packaging, not just to individual layers. For composite packaging the individual components have to be counted proportionally. The rule comes from the predecessor Directive 94/62/EC and was carried over into the PPWR.

The PPWR sets very low limits for PFAS in food-contact packaging — in practice equivalent to a far-reaching ban from 2026. For companies that means: PFAS content has to be documented through supplier declarations and laboratory analyses, and PFAS-containing coatings (grease or moisture barriers, for example) have to be replaced with alternatives. Critically: unintended contamination through recycling loops has to be checked as well.

Common for evidencing conformity are: XRF screening (a quick initial check for heavy metals), ICP-MS/ICP-OES (quantitative determination in an accredited laboratory), LC-MS/MS (determination of PFAS and organic SVHC), migration tests under EN 1186 or EN 13130 for food contact, and, where there is suspicion, target or non-target screening analyses. Test reports must come from accredited test bodies (to ISO/IEC 17025) and form part of the technical documentation.

The PPWR refers to the REACH candidate list of substances of very high concern (SVHC). If a packaging contains SVHC above defined concentration thresholds, these must be listed in the technical documentation and in part communicated. The list is updated twice a year — companies should review their supplier declarations accordingly and keep SCIP notification duties (to ECHA) in view.

Packaging containing substances of concern must be specially labelled from 2030 (through a QR code, for example). This is meant to make it easier for consumers to see which chemicals were used in the packaging design.

The recyclability of packaging is graded A (≥95 %), B (≥90 %), C (≥80 %), D (≥70 %) and E (<70 %). From 2030 all packaging must reach at least grade C, from 2038 only grades A or B. Packaging in grade E counts as not recyclable.

Design for recycling (DfR) means packaging has to be designed so that it can be sorted and recycled after use. That covers using mono-materials, avoiding disruptive coatings or adhesives, and making components easy to separate.

Reaching at least grade C by 2030 and A or B by 2038 is governed in detail by delegated acts. Clear EU-wide metrics are being formulated for calculating recycling shares per unit of weight.

From 2030, plastic packaging must contain binding minimum shares of post-consumer recyclate (PCR). For beverage bottles and PET containers the value is around 30–35 % from 2030, for example. Exemptions exist in part for highly sensitive areas.

Packaging must be designed so that volume and weight are limited to what is absolutely necessary for product protection and functionality. Deceptive packaging (double walls, false bottoms) that feigns volume is not permitted.

For transport, grouped and e-commerce packaging the empty-space ratio must not exceed 50 % (empty space from air pockets, polystyrene chips or filler material, for example).

The recycled content is calculated to standardised requirements on the basis of a mass balance. Only material demonstrably originating from post-consumer waste from permitted sources (certified recyclers, for example) is recognised.

A packaging no longer counts as recyclable merely because it can be recycled in the laboratory (design for recycling), but only if it is demonstrably recycled effectively in practice and at scale across Europe (from 2035).

From 2038 the recyclability requirements tighten drastically. Packaging in performance grade C is then prohibited as well; a recycling share of more than 90 % has to be reached.

The mandatory targets rise in 2040, to around 65 % for PET bottles and cans, for example. Companies have to secure reliable long-term supply chains for recyclates.

The rules on minimising empty space (max. 50 %) apply particularly to e-commerce, transport and grouped packaging. It is measured as the ratio of packaging volume to the volume of the contents.

Art. 10 obliges producers to design packaging so that weight and volume are reduced to the minimum absolutely necessary for product protection, functionality and consumer safety. Performance criteria — protection, storage, transport, information — must demonstrably not be achievable with a lighter or smaller packaging. Minimisation has to be documented separately for every packaging.

The PPWR defines performance criteria against which minimisation is assessed: product protection, manufacturing process, logistics, recyclability, conveying information, hygiene and safety, and legal requirements (child safety, for example) — with pure marketing explicitly not a justification for excess weight or volume. In the conformity assessment you have to show that any further reduction would jeopardise one of the performance criteria.

Deceptive packaging — packaging with misleading double walls, false bottoms or unnecessary voids that suggest a larger product — is not permitted under the PPWR. Structural necessities (product protection for fragile goods, for example) are exempt but must be demonstrable. Standardised fill quantities (in pharmaceuticals, for instance) remain permitted. For B2C packaging in food and cosmetics particular care is called for.

Minimisation is part of the technical documentation and the declaration of conformity. What is required: a description of the packaging design and the dimensions chosen, a justification per performance criterion (why is each dimension necessary?), where applicable a comparison with alternative packaging variants, test reports on product protection or transport stability, and evidence that minimisation was structurally considered during development. A DoC generator structures this evidence automatically.

The PPWR defines binding reuse targets for various packaging categories with key dates in 2030 and 2040. Affected are in particular transport and grouped packaging (pallets, crates), beverage packaging in the B2B sector, and packaging in hospitality. For certain sectors — transport within company sites, for instance — very high reuse targets apply (in part 100 %). The exact percentages are defined in Art. 29 and the associated delegated acts.

A refill system allows consumers to have their own containers or system-owned reusable containers refilled at the point of sale. The PPWR sets the framework on hygiene, labelling and availability. Consumer refill options become relevant particularly in hospitality (take-away coffee) and for certain non-food products (cleaning agents, cosmetics). Manufacturers must design the refill process so that product safety is maintained.

The PPWR names specifically: transport packaging (pallets, boxes, strapping), packaging between sites of one company, beverage packaging (alcoholic and non-alcoholic beverages in B2B), packaging for take-away and on-site consumption in hospitality, and certain e-commerce shipping packaging. Each category has its own targets and key dates. The detailed delimitation follows through delegated acts.

For micro, small and medium-sized enterprises (SMEs) the PPWR provides targeted relief on certain reuse duties — particularly in hospitality (take-away) and for transport packaging. The precise arrangement depends on turnover thresholds and headcount. Important: the relief mostly concerns the target duties, not the general compliance duties such as DoC creation or labelling.

Building a reuse system covers: selecting refillable containers (standard sizes, robust materials), a logistics concept for return and cleaning, a tracking system for containers (RFID or QR code), agreements with partners on pool use, a hygiene concept, and documentation of rotation counts for the compliance evidence. In practice many companies cooperate with established reuse pool providers rather than building their own system.

For reusable packaging under the PPWR the following evidence is relevant: technical documentation on suitability for multiple use (minimum number of rotations), evidence of the return and cleaning processes, statistical records of the actual rotation counts, labelling as reusable packaging, and evidence that the system reaches the required targets. This evidence forms part of the technical file and feeds into the declaration of conformity.

Annex V of the PPWR lists specific packaging formats that may no longer be placed on the market from 1 January 2030. They include: single-use packaging for fresh, unprocessed fruit and vegetables under 1.5 kg, single-use packaging for food and beverages in hospitality for on-site consumption, single-use grouped packaging in hotels (mini shampoos, coffee portions), very lightweight single-use plastic carrier bags, and shrink film around multipacks of single-use beverage packaging.

Yes, with clearly defined exemptions. Single-use packaging for fresh fruit and vegetables under 1.5 kg is in principle inadmissible from 2030. Exemptions apply where a packaging is demonstrably necessary to avoid food loss (for sensitive varieties such as berries, or for organic goods to make them clearly distinguishable). Member states can flesh out the exemptions but must justify them on the evidence.

Yes, single-use hygiene articles such as mini shampoo bottles, shower gels or lotions in hotels and other accommodation businesses fall under the ban from 2030. Businesses have to switch to refill dispensers, reusable containers or larger containers not specifically designed for single use. The ban applies to formats designed for a single use per guest — regardless of material.

Affected are in particular single-use packaging and single-use tableware for food and beverages consumed on site — that is, in restaurants, cafés and canteens. That includes single-use cups, plates, bowls and cutlery. For the take-away business, separate requirements apply with reuse targets rather than outright bans. The distinction between “on site” and “take-away” is decisive for the actual set of duties.

Shrink film around multipacks of single-use beverage packaging (a six-pack of water, for example) is prohibited by Annex V of the PPWR. Alternatives are cardboard grouped packaging, carrying handles made of recyclable materials, or entirely new secondary packaging concepts. Here too the ban applies from 2030. For product development that means: new multipack concepts should be tested early.

The PPWR obliges all EU member states to introduce a deposit return system (DRS) for single-use plastic beverage bottles up to 3 litres and single-use metal beverage cans by 1 January 2029 at the latest. Wine, milk and dairy products, among others, are exempt. Germany has operated a wide-ranging deposit system since 2003; other states have to build corresponding systems or harmonise existing ones.

The PPWR requires a separate collection rate of at least 90 % (by weight) for single-use plastic beverage bottles and single-use metal beverage cans by the end of 2029. Member states can deviate from a deposit system if they credibly reach the rate another way. For companies that means: on the EPR side, the collection and recycling infrastructure should be planned through early.

Member states must set up deposit systems by 1 January 2029 unless they reach the 90 % collection rate another way. For companies placing beverages on the market in several EU countries that means gradual harmonisation — with potentially different deposit amounts and return logic per country.

Anyone supplying beverages to several EU countries has to meet the respective national deposit and registration requirements. That covers: applying the correct deposit labelling for each destination country, registering with the local system operator, paying clearing fees where applicable, and making sure the packaging can be processed technically (bottle shape, barcode) in the respective return system. Platforms such as LUCID cover this for Germany; multi-country compliance requires further systems.

Online retailers placing packaged goods on the EU market are subject to the PPWR just like bricks-and-mortar retailers — but specific requirements additionally apply to shipping and transport packaging. These include empty-space limits (max. 50 %), labelling duties in online product listings as well, the duty to register for EPR in every destination country, and, from 2030, reuse targets for certain e-commerce transport packaging.

Shipping packaging (e-commerce packaging) must: stay below the 50 % empty-space share, meet the minimisation requirements under Art. 10 (no oversized boxes), be labelled as to material and disposal, meet the recyclability grades (at least grade C from 2030), and where applicable be transferable into reuse systems. Filler material counts towards the packaging volume and is subject to the same evidence duties.

The empty-space ratio is the ratio of empty space (air, filler material) to the internal volume of the shipping packaging. Formula: (internal volume − volume of the product(s)) ÷ internal volume. Products are counted including their primary packaging. If the ratio exceeds 50 %, the shipping packaging is not PPWR-compliant. The exact measurement procedures are specified in delegated acts and harmonised standards.

Fulfilment service providers who pack and ship on behalf of third parties take on parts of the economic operator responsibility under the PPWR. They must ensure that the packaging used is compliant and pass the necessary information on to their client. Where own-brand shipping boxes are used, the compliance duty lies with the fulfilment provider; for client packaging the duty remains in principle with the client.

Under the PPWR (Art. 45 among others), online marketplaces are obliged to check before enabling a trader whether that trader meets their EPR duties (evidence of LUCID registration in Germany, for example). Traders without a valid registration may not offer goods through the marketplace. Marketplaces carry a compliance control duty and risk fines themselves if they admit unregistered traders — comparable with the German VerpackG since 2022.

Greenwashing concerns environmental claims on packaging (“climate neutral”, “100 % recyclable”) that are untrue or cannot be verifiably substantiated by technical documentation. The PPWR penalises greenwashing with heavy fines or sales bans.

All voluntary statements (on recycled content, for example) and environmental claims must be substantiable. Beyond that, mandatory labelling — information on material, sorting and disposal — is compulsory.

Statements about environmental characteristics may only be made where the properties objectively go beyond the statutory minimum duties of the PPWR, are described transparently and are fully documented.

Packaging must make clear to consumers, through clear pictograms and information partly defined by implementing act, what material the packaging consists of and which waste stream it belongs in.

It may (in part must) be documented that extended producer responsibility is being met. The way this is stated (pictogram, text or QR code) is to be standardised.

By 2028, uniform labels or QR codes must be in place that help identify and assign the materials and provide precise information on the substances contained (PFAS, for example).

Additional mentions of bio-based plastic or high recycling shares fall under a strict evidence duty. Every percentage figure must be substantiated in the DoC using standardised procedures.

Markings must be physically present directly on the packaging (or at least as a sticker where the construction makes nothing else possible) and, in parallel, permanently legible in online product listings (e-commerce).

The PPWR governs the packaging-specific labelling and claim requirements. The EU directive on environmental claims (Green Claims Directive) supplements this horizontally across all product groups. Companies therefore have to secure environmental claims twice over: substantively and in regulatory terms under the PPWR (where packaging properties are concerned) and methodologically under the Green Claims Directive (through life-cycle analysis or certified schemes). Inconsistent claims between packaging and marketing material are particularly risky.

You need robust material data sheets (safety data sheets) from your suppliers, detailed information on layer structure, adhesives and inks, declarations of conformity (partial DoCs), laboratory reports (free of SVHC) and precise recycled-content shares.

Suppliers must provide officially certified evidence of where the recyclate comes from (post-consumer, for example) and, in the case of food contact, that a clearance under Regulation (EU) 2022/1616 assessed by EFSA exists.

Established certification schemes for recyclate and material evidence are: RecyClass (certification of recyclability and recycled content for plastic packaging), EuCertPlast (certification of plastic recyclers), ISCC PLUS (chain of custody for circular and bio-based materials, also relevant for chemical recycling), Blauer Engel for recycled paper, FSC and PEFC for paper and board origin, and DIN CERTCO for compostability. How far authorities accept each scheme is being specified in delegated acts.

Chain of custody (CoC) documents the unbroken flow of material from waste through sorting, recycling and processing to the finished packaging. For evidencing PCR shares that is decisive, because recyclates are often mixed with virgin material (in mass-balance procedures, for example). Only with clean CoC documentation is a declared recycled content legally robust. Schemes such as ISCC PLUS issue standardised CoC certificates that authorities accept.

Efficient collection works through: standardised data forms (a template with all PPWR-relevant fields), clear supplier requirements as a contract annex or purchasing condition, digital data pools with an upload workflow for suppliers, deadlines and escalation logic for missing answers, and regular validation of the data supplied (plausibility checks). Important: the simpler the process for suppliers, the higher the response rate.

A pragmatic approach: 1) a formal data request with a clear deadline and a reference to the PPWR relevance, 2) escalation to purchasing and management, 3) review of alternative suppliers with a complete data position, 4) where indispensable: your own laboratory analyses as a safeguard (costs time and money but covers your own responsibility), 5) in the long run: adjust purchasing conditions so that PPWR data delivery is part of the contract. Anyone unable to produce PPWR data will disappear from the EU market in the medium term.

Yes. Suppliers often issue a collective declaration for a material or article group (“this PE film is supplied with 30 % PCR”). These declarations apply until the specification changes and can be assigned to several finished packaging types. Important: the declaration must be named, dated and carry an article reference and a validity date. Every change to the supply specification (a new recyclate supplier, for example) requires a new declaration.

The PPWR obliges member states to define effective, proportionate and dissuasive sanctions (Art. 62). The actual level is set nationally. Reference points from related EU frameworks (the Ecodesign Regulation, the Market Surveillance Regulation) run to up to 4 % of annual EU turnover or several million euros per breach. Germany is working on an adapted sanction regime, which will probably be anchored in the Packaging Act or a new implementing act.

Market surveillance authorities (in Germany the state authorities) check on a sample and risk basis whether packaging placed on the market is PPWR-compliant. They can request documents (particularly the DoC and technical file), take samples for laboratory analysis, carry out on-site audits, issue sales and distribution bans, order recalls and impose fines. Exchange between EU market surveillance authorities runs through the ICSMS system.

Yes. If a packaging is classified as non-compliant, the competent authority can order a recall — including notification of retailers and end customers. Recalls are costly and damaging to reputation. They mostly occur where substance restrictions are breached (PFAS in food contact, for example) or where there are systematic labelling and documentation deficiencies. Clean DoC and test documentation is the most important protective instrument.

The burden of proof lies with the economic operator. Authorities do not have to prove that a packaging is non-compliant — it is enough that there are reasonable doubts. The producer, importer or retailer then has to show through the DoC, the technical documentation and where applicable laboratory reports that all PPWR requirements are met. The documents must be provided within a few working days of the request.

The PPWR sits within the scope of the EU Whistleblower Directive (2019/1937). That means: reports of PPWR breaches from inside the company or from business partners are protected, and companies with 50 or more employees must maintain internal reporting channels. Market surveillance authorities also accept external tip-offs about packaging non-conformity as a basis for investigation.

The PPWR does not replace Framework Regulation (EC) 1935/2004 on materials and articles intended to come into contact with food, nor the Plastics Regulation (EU) 10/2011 — they apply in parallel. While the PPWR addresses sustainability and circularity, the food contact rules govern the migration of substances into food. In practice that means: every food packaging has to be both PPWR-compliant and approved under food law. The technical documentation must contain both sets of evidence.

Yes, but only under strict conditions. Regulation (EU) 2022/1616 on recycled plastic food contact materials requires every recycling process for food contact to be assessed by EFSA and authorised by the European Commission. Currently authorised are in particular PET recycling processes (bottle-to-bottle). For PE, PP and other plastics in food contact the regulatory framework for recyclates is still being built. The PPWR refers explicitly to this parallel regime.

For certain substance restrictions the PPWR provides exemptions where the use is technically unavoidable and alternative substances are not available. These exemptions are narrowly bounded and require evidence. For heavy metals the 100 ppm sum rule largely applies to food packaging as well. For PFAS in food-contact packaging the PPWR sets particularly strict limits (in practice a far-reaching ban from 2026).

For PET recyclate in food contact the following evidence is relevant: authorisation of the specific recycling process by the European Commission following EFSA assessment, chain-of-custody documentation along the supply chain, a certificate for the recycling plant (under EuCertPlast or RecyClass, for example), a supplier declaration of conformity under Regulation (EU) 2022/1616, and your own migration testing for the finished product. This evidence supplements the PPWR DoC and is filed in a structured way in the DoC generator.

The CSRD (Corporate Sustainability Reporting Directive) obliges companies within its scope to publish sustainability data along the ESRS standards. Standard ESRS E5 (circular economy, resource use) requires information on packaging data, material use and recycling rates that can be fed directly from the PPWR documentation. The PPWR therefore produces the operational data — the CSRD uses it for reporting. Setting up PPWR compliance in a structured way considerably reduces the CSRD reporting effort.

Typical data points that are relevant for both the PPWR and the ESRS: material use by type and quantity, recycled-content shares (post-consumer and post-industrial), recyclability classifications, reuse rates per packaging category, packaging weights and volume reductions, and emissions along the packaging supply chain (Scope 3). A central data repository avoids duplicated effort between compliance and sustainability teams.

PPWR compliance is legally mandatory and product-related — it governs which packaging may be placed on the market at all. ESG reporting (under the CSRD/ESRS) is company-related and addresses transparency towards investors, customers and stakeholders. PPWR breaches have immediate market-access consequences (a sales ban), while ESG gaps mainly carry reputational and financing risks. The two regimes are closely interlinked but legally distinct.

Reguly records PPWR-relevant packaging data in a structured way and provides it in export formats that can be transferred into ESRS reports. Through the central data pool, product management, compliance and sustainability owners work from consistent, audit-proof data. That reduces duplicated effort, and a PPWR update flows straight into the ESG report.

Sustainability has long since stopped being a pure compliance topic and become a competitive factor. Consumers, retail partners and investors expect robust environmental claims — and regulators increasingly punish false promises hard. Anyone who documents the recyclability, recycled content and carbon footprint of their packaging cleanly meets the PPWR, the EmpCo Directive and the CSRD at the same time and builds trust in the market. Sustainability thus turns from a cost factor into a selling point — provided the claims can be evidenced.

Greenwashing describes environmental claims that create a greener impression than can actually be substantiated — blanket labels such as “environmentally friendly”, “sustainable” or “climate neutral” without solid evidence. With the EmpCo Directive (Empowering Consumers) and the planned Green Claims Directive, the EU is taking targeted action against such practices: unsubstantiated environmental claims will count as an unfair commercial practice and can lead to warnings, fines and sales bans. The risk therefore no longer lies only in reputational damage but in concrete legal sanctions.

The EmpCo Directive prohibits general, unspecific environmental claims without recognised evidence — terms such as “environmentally friendly”, “eco”, “green”, “biodegradable” or “climate neutral” where they are not backed by demonstrated, outstanding environmental performance. Particularly in focus: climate-neutrality claims resting solely on carbon offsetting will be prohibited. Claims about the whole product that relate only to one aspect are also inadmissible. What remains permitted are concrete, verifiable, product-related statements — “30 % recycled content” with the evidence on file, for example.

Legally sound environmental claims need a complete, verifiable data basis: concrete figures instead of blanket terms, evidence from the supply chain (recyclate certificates, chain-of-custody documents), recognised calculation methods for carbon figures, and audit-proof filing that stands up to inspection. What matters is that every claim can be traced back to a robust document. That is exactly where a structured data platform comes in — it links claim and evidence so that marketing and compliance work from the same set of facts.

Under the EmpCo Directive, environmental labels may only be used where they rest on a recognised certification scheme or were introduced by a public body. Self-awarded or unclear “sustainability seals” without independent verification will be prohibited. For packaging that means: only certified claims (recognised recyclability or recyclate certificates, for example) are robust. Companies should review their label portfolio and put every seal used on a verifiable footing.

Sustainability pays off where it is credible, measurable and communicable. Companies that record their packaging data in a structured way can not only meet regulatory duties (PPWR, EmpCo, CSRD) efficiently but also communicate their progress confidently in the market — without greenwashing risk. The key is a central, robust data basis from which both compliance evidence and marketing statements are fed. We are happy to show you in a conversation how to turn your sustainability data into a communicable advantage.

The EmpCo Directive — formally the “Directive on Empowering Consumers for the Green Transition”, Directive (EU) 2024/825 — is an EU directive intended to strengthen consumers for the green transition. It amends the Unfair Commercial Practices Directive (2005/29/EC) and the Consumer Rights Directive (2011/83/EU) and takes targeted action against misleading environmental claims and greenwashing. At its core: consumers should receive reliable, transparent information about the environmental properties and durability of products — and be protected from green pretence.

The EmpCo Directive entered into force in March 2024. EU member states must transpose it into national law by 27 March 2026; the new rules apply from 27 September 2026. From that point the tightened requirements against misleading environmental claims apply directly to dealings with consumers. Companies should use the remaining time to review their product and packaging communication and put it on a robust evidence footing.

The EmpCo Directive extends the “black list” of prohibited commercial practices (Annex I of the UCP Directive) to include, among others: general environmental claims without evidence of outstanding environmental performance, climate-neutrality claims resting on carbon offsetting, sustainability seals without a recognised certification scheme, claims about the whole product that concern only one aspect, and presenting features required by law anyway as a special characteristic. In addition, practices of planned (premature) obsolescence and concealing durability or repair restrictions are prohibited.

Both address greenwashing but bite differently: the EmpCo Directive has already been adopted and prohibits certain misleading environmental claims and practices in principle (the “whether”). The Green Claims Directive is a supplementary act intended to set detailed requirements on how explicit environmental claims must be substantiated, calculated and independently verified (the “how”). Together they form the EU framework against greenwashing. For companies that means: the EmpCo ground rules apply first, and the evidence requirements will be fleshed out further with the Green Claims Directive.

Packaging is a main carrier of environmental claims — which is exactly where the EmpCo rules bite. Print statements such as “100 % recyclable”, “made from sustainable materials” or “climate neutral” will have to be concrete, product-related and evidenced. Blanket eco-claims and self-awarded seals on packaging become inadmissible. Combined with the PPWR labelling duties that means: every environmental and material statement on the packaging needs a documented, verifiable basis. Anyone recording their packaging data in a structured way can derive compliant claims and avoid greenwashing risks.

The three regimes interlock: the PPWR supplies the operational packaging data (materials, recycled content, recyclability), the EmpCo Directive governs how these properties may be communicated to consumers, and the CSRD requires disclosure of the same sustainability data in the company report. A single, consistent data basis therefore serves all three requirements — compliance, consumer communication and ESG reporting. Set the data capture up in a fragmented way and you risk contradictions between the print on the packaging, the DoC and the sustainability report.

Recommended steps before application in September 2026: systematically record existing environmental claims on packaging, on the website and in marketing material and check them for substantiability; remove or make concrete any blanket and unsubstantiable claims; trace the seals you use back to recognised certification schemes; and build a central, audit-proof data basis that links claim and evidence. That is exactly where we support you: from taking stock of your green claims to a robust data structure. Get in touch — we will show you how to be EmpCo-compliant in good time.