With the EU Packaging and Packaging Waste Regulation (PPWR*), the transition from a directive to be transposed into national law to directly applicable EU law will take effect in August 2026. This will establish technical requirements for packaging that are binding and harmonized across the EU for the first time. For manufacturers, packaging developers, and distributors, this means far-reaching changes throughout the entire product lifecycle. The previous Packaging Directive (94/62/EC) defined targets but left considerable leeway for national implementation.
The new Packaging Regulation now contains detailed technical specifications, including on:
• Packaging design
• Material composition
• Recyclability
• Conformity assessment
This will largely replace national special regulations. A key technical requirement is that all packaging must be recyclable. Packaging that does not meet these criteria may no longer be placed on the market. For plastic packaging, the regulation introduces mandatory minimum content levels of post-consumer recycled material (PCR). These quotas will increase gradually through 2040. The regulation will limit the permissible amount of empty space, particularly in shipping and outer packaging. Consequently, oversized packaging will no longer be considered compliant with regulations. A new requirement is the obligation to provide an EU declaration of conformity for packaging.
Manufacturers must maintain technical documentation that includes, among other things:
• Material data sheets
• Recyclability assessment
• Evidence of recycled content
• System and functional descriptions
Packaging is thus subject to a regulatory regime more akin to product law (comparable to CE marking). For companies in the Federal Republic of Germany, this means an amendment to the German Packaging Act through an Implementation Act for Packaging Law. This regulates, among other things, manufacturer registration and sanctions for non-compliance.
For companies, this means a shift in responsibilities toward product development, quality assurance, and regulatory affairs. Companies that develop or place packaging on the market must adapt their technical specifications, supply chains, and documentation systems at an early stage.
In our revised DataCross module for the Packaging Regulation—similar to the module for the Packaging Directive—compliance with the cumulative limit value for heavy metals is checked. Additionally, starting in August 2026, the new requirement regarding PFAS in food packaging will also be taken into account.
*REGULATION (EU) 2025/40 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of December 19, 2024 on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC