Packaging Ordinance
Packaging Regulation (PPWR) 2025/40: Obligations, Recyclability & Implementation
Scope of the Packaging and Packaging Waste Regulation (PPWR) and Objectives
Scope for packaging (sales, grouped, and transport packaging)
The Packaging and Packaging Waste Regulation (PPWR) 2025/40 establishes the EU-wide framework for the design, use, and disposal of packaging and replaces existing regulations such as the Packaging Directive, the Packaging Ordinance (VerpackV), and national laws such as the Packaging Act (VerpackG). It affects all manufacturers, distributors, importers, and producers of packaging, regardless of material or type, including plastic packaging, paper, or composites. The objective is to reduce packaging waste, promote a circular economy, and ensure that packaging is recyclable, reusable, and appropriately labeled. Companies must design their products to comply with requirements regarding recyclability, recycled content, and recovery, while consumers receive clear information on proper disposal.
Circular Economy, Recovery, and Recycling Rates in the EU
The Packaging Regulation aims for a functioning circular economy in which packaging is efficiently collected, sorted, recovered, and, where possible, reused. Member States implement recycling rates that must be complied with by all manufacturers, importers, and distributors. Single-use packaging and materials that are difficult to recycle are being reduced, while multi-use packaging and reusable transport packaging are being promoted. The objective is to minimize waste throughout the entire supply chain and ensure the recovery of high-quality materials so that packaging and packaging waste remain within the cycle in a resource-efficient manner.
Roles, Producer Responsibility, and Obligations
Manufacturers, distributors, importers, producers – tasks & responsibilities
Under the Packaging Regulation, manufacturers, distributors, importers, and producers bear full responsibility for the packaging they place on the market. Extended producer responsibility includes compliance with technical and regulatory requirements, ensuring recyclability, minimizing packaging volumes, and participating in take-back and recovery systems. Companies must implement processes that enable sustainable reuse and high-quality recovery of packaging. These obligations apply to all packaging materials and extend across the entire life cycle, from design and use to recovery.
Producer Register (VerpackG/Packaging Act) and Registration in Member States
Prior to placing products on the market, companies must register in a producer register, as is the case in Germany via the Packaging Act (VerpackG). The PPWR harmonizes registration at the EU level, ensuring that quantity reports, recycling rates, and obligations are documented in a traceable manner. Incorrect or missing registration can lead to market bans, whereby manufacturers, importers, and distributors bear a significant compliance risk.
Design and Recyclability Requirements
Minimum Requirements, Recycled Content, and Recyclable Packaging Materials
The PPWR mandates that packaging must be designed to be sortable, recoverable, and recyclable. The use of standardized materials and defined recycled content targets, particularly for plastic packaging, is mandatory. Companies must verify whether their sales, grouped, and transport packaging comply with these requirements. The integration of recycled content supports the circular economy, increases the recovery rate, and reduces the generation of packaging waste.
Labeling of Packaging and Consumer Information
Packaging must be clearly labeled to inform consumers about material composition, recyclability, and disposal routes. Manufacturers and distributors bear the responsibility for ensuring that disposal errors are minimized and the quality of recovery is maintained. Labeling is also relevant for market surveillance to demonstrate compliance with obligations throughout the entire supply chain.
Reuse and Multi-use Requirements
Reusable and Multi-use Packaging: Goals, Requirements, and Systems
The PPWR promotes the reuse of packaging in order to reduce the volume of single-use packaging. Companies are required to establish systems that enable the return and reuse of multi-use and reusable transport packaging. These requirements affect both the design and the logistical cycles, ensuring that packaging remains within functioning multi-use loops and that the circular economy is strengthened.
Industry and Product-Specific Requirements (Plastic and Transport Packaging)
For specific sectors, such as e-commerce or food, special requirements apply to plastic packaging and transport packaging. Companies must reduce the use of materials, increase recyclability and promote reusable solutions. The EU Commission’s specifications on recycled content, labeling and reuse must be complied with, while the Member States monitor implementation.
Single-use Packaging, Restrictions, and Bans
Reduction targets, requirements for single-use packaging & secondary packaging
The Packaging Regulation defines reduction targets for single-use packaging and unnecessary secondary packaging. Manufacturers, distributors, and importers must demonstrate that packaging is reduced to a minimum in order to optimize resource use and decrease waste volumes. Consumers benefit from clear structuring and easier separation of packaging waste.
Product-/Material-related Restrictions and Alternatives
Certain packaging formats and materials that are difficult to recycle are being restricted or banned. Companies are required to develop functional alternatives that are recyclable, reusable, and compliant with EU specifications. Requirements regarding recycled content, labeling, and recovery must be observed in the process.
Collection, Recovery, and Recycling of Packaging Waste
Obligations along the value chain, recycling rates & recovery
Manufacturers, distributors, and importers are obliged to ensure the collection, recovery, and reuse of packaging throughout the entire value chain. Packaging must be sortable, recyclable, and economically viable for recovery. Compliance with recycling rates is regularly monitored and forms the basis for achieving EU targets in the circular economy.
Member State Systems, Economic Operators, and Market Surveillance
Member States operate national systems for the recording and monitoring of packaging streams. Economic operators must report quantities, prove recyclability, and make their processes transparent. Market surveillance ensures that packaging complies with PPWR requirements and that the circular economy is strengthened.
Compliance & Evidence (Our Services)
Testing of recyclability, recycled content & material analytics
Companies must test the recyclability of their packaging and provide proof of defined recycled content. Material analytics and recyclability tests are necessary to ensure compliance with national and EU authorities and to ensure that placing products on the market is legally compliant.
Documentation/Compliance Checks, Labeling and Registration Support
Professional support helps companies fulfill their documentation obligations, correctly complete registrations in the producer registers, and ensure that packaging is labeled properly. This minimizes regulatory risks and ensures the efficient implementation of PPWR requirements.
Interfaces to Regulation/Directive & National Regulations
PPWR vs. Packaging Directive/VerpackV/VerpackG – Transitions & Implementation
The PPWR harmonizes existing regulations such as the Packaging Directive, VerpackV, and VerpackG and regulates transition periods for companies. During this phase, existing processes must be reviewed and adapted, and new requirements such as recycling rates, reuse, and labeling must be integrated to ensure long-term legal compliance.
EU Commission, delegated acts, requirements & updates
The EU Commission is specifying the PPWR through delegated acts, guidelines, and regular updates. These specifications define requirements for design, recyclability, labeling, recycled content, and reporting obligations. Companies must continuously monitor these requirements to comply with the obligations of the PPWR and the Member States.
