EU Packaging Regulation – Assessing the requirements and ensuring legal compliance

EU Packaging Regulation – How can the new requirements be assessed and implemented in a legally compliant manner?

The new PPWR sets out targets and obligations relating to sustainability, recyclability and digital documentation for packaging and packaging waste. While previous legislation allowed greater scope for national implementation, the Regulation establishes a harmonised framework across the EU for the first time. This guest article by tec4U-Solutions explains the specific requirements of the PPWR and how compliance officers can implement them in good time and in a legally compliant manner.

As part of the European Green Deal and the EU’s objective of achieving climate neutrality by 2050, the Packaging and Packaging Waste Regulation (PPWR 2025/40) is primarily aimed at reducing the steadily growing volume of packaging, using resources more efficiently and systematically strengthening the circular economy. Packaging is no longer considered in isolation but is regulated throughout its entire life cycle. From design and use through to disposal, new requirements are being introduced that affect companies in almost every sector. This is particularly significant because the PPWR applies to all packaging, regardless of the material used or the distribution channel. In future, this will therefore also fully encompass e-commerce and international supply chains.

Recyclable and resource-efficient packaging

One of the key changes concerns packaging design. Under a timeline extending to 2040, companies will have to ensure that their packaging is recyclable and uses resources as efficiently as possible. Oversized packaging is to be avoided, while mandatory minimum requirements for the use of recycled content, particularly in plastics, are being introduced. Chemical aspects are also becoming increasingly important, including new limits for PFAS, although the PFAS restrictions apply specifically to food-contact packaging.

Introduction of reuse targets and more sustainable use of materials

At the same time, greater emphasis is being placed on reuse, with clearly defined reuse targets being introduced for certain packaging formats. For specific sectors, such as the hospitality industry, the Regulation establishes concrete requirements for refill and reuse systems. This will require not only new packaging concepts, but also the development of logistical return systems, cleaning solutions and digital tracking mechanisms. Companies will need to look beyond their own operations and develop collaborative models across the supply chain.

The PPWR also addresses the use of bio-based raw materials in plastic packaging, thereby creating a regulatory framework for the use of renewable resources. The aim is to gradually reduce dependence on fossil-based raw materials while ensuring transparency regarding the origin and sustainability of the materials used.

New roles bring additional obligations

The Regulation redefines the various economic operators along the supply chain and assigns specific tasks and obligations to each of them. A particular challenge is that responsibilities are no longer determined solely by the traditional origin of a product, but increasingly by who actually places packaging on the market and who has organisational control over it.

In practice, this creates considerable uncertainty between suppliers and producers in particular when determining regulatory responsibility. It is often assumed that the company physically producing the packaging automatically bears all obligations. However, the requirements frequently relate not to physical production, but to the first making available on the market or to the use of packaging under a company’s own brand. Companies therefore need to clearly establish whether they act as a supplier, producer, importer, distributor or manufacturer. Further complexity arises because economic operators may perform several roles within the supply chain. For example, a company may act as an importer while also distributing packaging under its own brand, thereby assuming the obligations of a producer, and simultaneously acting as a supplier. For companies, this means not only greater regulatory responsibility, but above all considerable pressure to adapt throughout the entire value chain.

Greater transparency and digital documentation through extended producer responsibility

Another key element of the Regulation is the expansion of extended producer responsibility. In this context, the economic operator regarded as the manufacturer is the party responsible for first placing the packaging on the market in the Member State in which it becomes packaging waste. Companies will be required to take greater responsibility for the collection, sorting and recovery of their packaging and to provide financial support for the relevant systems. At the same time, requirements relating to transparency and documentation are becoming significantly more demanding. Packaging must be clearly labelled, and information on materials, recyclability and origin is increasingly expected to be available digitally. Standardised symbols and sorting instructions are intended to help consumers dispose of packaging correctly and support the circular economy. Digitalisation therefore plays a central role, as it provides the basis for traceability and efficient reporting.

A reliable data foundation and active supplier communication are essential

Implementing the PPWR is therefore not simply a packaging issue. It presents companies with complex challenges because technical, organisational and legal aspects are closely interconnected. Many companies are initially faced with the task of establishing transparency across their existing packaging structures. Without a reliable data foundation, it is impossible to properly assess risks or derive targeted measures. At the same time, supply chains need to be reassessed, as compliance with the requirements can often only be achieved through close coordination with suppliers and business partners.

Prepare early and seize the opportunities

By 12 August 2026 at the latest, affected companies will need to comprehensively adapt their packaging processes in order to demonstrate compliance. The starting point is a complete inventory of all packaging used, together with comprehensive digital records of all packaging components, including clear allocation of materials and economic operator roles. Companies that fall within the obligations applicable to producers must maintain reliable supplier declarations, particularly regarding material composition and critical substances such as heavy metals or PFAS in food-contact packaging. In addition, the PPWR requires comprehensive technical documentation, including component drawings, technical specifications and details of the harmonised standards applied. It is also essential that every type and variant of packaging can be clearly identified by means of type, batch or serial numbers.

Despite these challenges, the PPWR also offers significant opportunities. Companies that act at an early stage can not only minimise regulatory risks, but also strengthen their strategic position in the market. Sustainable packaging solutions are increasingly becoming a point of differentiation and are in growing demand among both business partners and end customers. More efficient packaging concepts can also lead to long-term cost savings, for example through reduced material consumption or optimised logistics processes.

How to achieve timely and legally compliant implementation within your company

A systematic approach is recommended for successful implementation. In principle, PPWR implementation should be regarded as a cross-functional task requiring close cooperation between the various departments within an organisation. The first step is a comprehensive assessment of the current situation in order to evaluate existing packaging solutions in terms of their compliance and future viability. The requirements should then be integrated into internal company processes as well as into existing and future supplier contracts, for example through a Material Compliance Specification. Data collection remains a critical success factor in compliance management. The use of effective communication software for obtaining information on PPWR compliance throughout the supply chain is therefore essential. Based on this data, companies should systematically develop their packaging strategies further, with the principle of “Design for Recycling” playing a central role. At the same time, it is advisable to assess reusable packaging options at an early stage and initiate pilot projects in order to gain practical experience. Equally important is the development of robust data and compliance structures that enable companies to efficiently meet the increasing documentation and reporting requirements.

Overall, the PPWR is far more than just another regulatory requirement. It acts as a catalyst for a fundamental transformation of the packaging industry and requires companies to rethink their established approaches. Companies that address this challenge at an early stage and use it strategically can not only meet the regulatory requirements, but also gain long-term competitive advantages and actively contribute to the development of a functioning circular economy.