Many companies have been dealing with issues such as LUCID registration, participation in schemes and extended producer responsibility (EPR) for years. These obligations remain in place in principle. What is new, however, is that packaging is now viewed more comprehensively across its entire life cycle, and companies will in future have to provide more extensive evidence that packaging complies with the applicable requirements.
However, anyone who views the PPWR solely as a regulatory issue is missing the bigger picture. Above all, the new requirements highlight just how important transparent packaging data, clearly defined responsibilities and structured processes will become for eCommerce, logistics and international distribution models in the future.
What is already changing for businesses today
Not all of the PPWR’s requirements apply immediately. Many other provisions will only become relevant in the coming years. Nevertheless, new issues are already arising for businesses.
Depending on a company’s role within the supply chain, it may become increasingly important in future to be able to provide traceable documentation regarding:
What packaging is used
What materials the packaging is made of
What evidence and documentation is available
What roles are undertaken within the supply chain
What compliance and product information is available
How packaging information is managed and maintained
The issue of responsibilities is coming increasingly into focus, particularly in relation to own-brand products, international supply chains and the import of goods.
Producers or manufacturers: Who takes on which role?
One of the key issues relating to the PPWR concerns the different roles within the supply chain.
Among other things, the Regulation distinguishes between the producer of packaging and the manufacturer within the framework of extended producer responsibility (EPR). The specific role a company plays depends on the particular supply chain, the packaging used and the distribution model.
Depending on the individual case, this may result in different requirements regarding documentation, evidence, registration or the organisation of extended producer responsibility.
It is therefore becoming increasingly important for companies to document their own role within the supply chain in a transparent manner and to review it regularly, particularly in the case of international distribution structures or complex supply chains.
Own-brand products: Often more responsibility than expected
Many retailers see themselves primarily as sellers of their products. However, when it comes to own-brand products, the requirements can be significantly more complex.
Anyone who distributes packaging or packaged products under their own name or brand may, depending on the specific circumstances, be classified as a producer within the meaning of the PPWR. Key factors here include the supply chain, contractual relationships and the role of the economic operators involved.
Depending on this classification, additional requirements may apply:
Documentation
Conformity
Record-keeping
The obligations that apply in a specific case should always be assessed on the basis of the individual circumstances.
Goods from the EU and imports from third countries
When it comes to commercial goods, too, it is worth taking a closer look at the respective responsibilities within the supply chain.
Anyone distributing products from a European manufacturer does not automatically assume the same obligations as the original manufacturer. At the same time, simply distributing a product does not necessarily mean that no requirements apply. The specific role of the company in question remains the decisive factor.
Particular attention is often required for imports from non-EU countries. In such cases, additional requirements relating to conformity, technical documentation, traceability and evidence may apply. The obligations that arise from this depend on the specific circumstances.
Dropshipping and online marketplaces
Even in the case of dropshipping or selling via online marketplaces, responsibilities cannot be assigned across the board to any one party.
Rather, the specific supply chain, the marketing of the products, the companies involved and the respective sales markets are the decisive factors. Depending on the arrangement, different roles and requirements may arise.
The key question is therefore often not:
‘What packaging should I use?’ but rather,‘What responsibility do I assume within the supply chain?’
Cross-border sales: When an authorised representative may become relevant
For businesses with cross-border distribution models, the issue of authorised representatives may play a greater role in future.
The PPWR stipulates that, in certain circumstances, manufacturers must appoint an authorised representative if they operate in a Member State in which they are not themselves established. Whether this requirement applies in individual cases, however, depends on the specific distribution structure and the respective role within the supply chain.
As practical implementation continues to be influenced in part by national requirements and further developments at European level, companies with cross-border distribution should review their structures at an early stage.
It may be particularly useful to address this issue at an early stage in the case of own-brand products, direct sales abroad or sales via international marketplaces.
What happens in the event of breaches of the PPWR and the VerpackDG?
The PPWR and the VerpackDG establish a framework for the management of packaging and packaging waste. At the same time, the regulations contain various requirements regarding documentation, obligations to provide evidence, registrations and responsibilities.
If requirements are not met, different consequences may arise depending on the circumstances. In addition to potential fines, other consequences may include, for example, complaints from supervisory authorities, restrictions on the marketing of certain products, or additional testing and verification requirements.
For companies, therefore, the question is often less about potential sanctions and more about the organisational implementation of the requirements. In practice, challenges frequently arise where information on packaging, materials, suppliers or responsibilities is not fully documented or is difficult to access.
Particularly in the case of larger product ranges, own-brand products or international distribution structures, it can therefore be advisable to centrally record packaging data, supporting documentation and areas of responsibility at an early stage and to document them in a traceable manner.
The specific assessment of potential consequences always depends on the individual case, the regulations actually applicable and the specific circumstances.
Why the PPWR is, for many companies, primarily a data issue
In many companies today, packaging-related information is scattered across ERP systems, Excel files, supplier documents or emails.
As soon as evidence is required, a time-consuming search for the correct information often begins.
However, the PPWR does not specify in which system packaging data must be managed. What is crucial, rather, is that relevant information is available, traceable and documented.
Companies that manage packaging data centrally and link it to product information can provide information more quickly whilst also laying the groundwork for future requirements.
Which packaging details may become particularly important in future
In e-commerce projects in particular, it is often the case that whilst packaging information is available, it is not maintained in a structured manner.
The information and supporting documentation that companies should pay closer attention to in future include, amongst other things:
Mandatory | Relevant data |
|---|---|
Packaging description | Type of packaging |
Material declaration | Material, composite material |
Weight information | Packaging weight |
Dimensions | Internal and external dimensions |
Recycling information | Recycled content |
Supplier details | Manufacturer or supplier |
Declaration of conformity | Documents and declarations |
Record-keeping | Validity and test dates |
The information that is actually required depends on the packaging, the product and the supply chain. The sooner data is collected in a structured manner, the easier it will be to assess and implement future requirements.
What many retailers underestimate when it comes to empty space
From 2030 onwards, limiting empty space in certain types of packaging will be a particularly relevant issue for eCommerce.
The PPWR stipulates a maximum void space ratio of 50 per cent for outer packaging, transport packaging and e-commerce packaging.
For online retailers, this means one thing above all: in future, box and packaging sizes will need to be tailored more closely to the actual product dimensions.
It may therefore be advisable for online retailers to review their packaging sizes, dispatch processes and the filling materials they use at an early stage.
Wichtige Zeitpunkte und geplante Entwicklungen
Die PPWR enthält zahlreiche Regelungen mit unterschiedlichen Anwendungszeitpunkten. Einige Vorgaben gelten bereits seit dem 12. August 2026, weitere Anforderungen sind nach aktuellem Rechtsstand für die kommenden Jahre vorgesehen. Dabei ist zu berücksichtigen, dass einzelne Regelungen noch von ergänzenden europäischen Rechtsakten abhängig sein können.
Since 12 August 2026
The PPWR is generally applicable.
The Packaging Act supplements the European requirements in Germany.
Registration, participation in the system and data reporting remain in place.
Technical documentation and proof of conformity are becoming increasingly important.
Importers and distributors are subject to additional testing obligations.
From 12 February 2028
- Further requirements regarding reusability, compostability and labelling will be introduced gradually.
From 1 January 2030
Recyclability requirements are to become mandatory.
For certain types of plastic packaging, minimum recycled content levels of between 30 and 35 per cent apply, depending on the type of packaging.
The maximum void space ratio of 50 per cent becomes relevant.
Further ‘design for recycling’ requirements will come into force.
From 1 January 2035
- The criterion of recycling is also a factor on a large scale.
From 1 January 2038
For performance level B, a minimum of 80 per cent is required.
From 1 January 2040
The proportion of recycled material will increase to between 50 and 65 per cent, depending on the type of packaging.
New obligations that are often overlooked
The Packaging Act brings with it further changes that many businesses have not yet picked up on.
These include, amongst others:
Extended producer responsibility for certain B2B packaging
No general exemption for small businesses
Higher recycling targets
Additional requirements regarding recyclability and the use of recycled materials
Smaller retailers in particular should therefore check whether their previous assumptions regarding exemptions or exemption thresholds still actually apply.
PPWR Check: Identifying the need for action at an early stage
The greatest burden often arises not from the regulation itself, but from unclear responsibilities, a lack of information and scattered data.
As part of a PPWR Check, we work with you to examine:
roles within the supply chain
Existing packaging data
existing documentation and evidence
organisational data gaps
potential impacts on Shopware, ERP or PIM systems
The result is a structured overview of existing information and process gaps, as well as potential areas for action for further assessment.
Would you like to know what the PPWR specifically entails for your product range, packaging and systems?
Together, we’ll identify areas where action is needed, review existing data structures and highlight the measures required to ensure a legally compliant and future-proof implementation of the PPWR.
Conclusion
With the PPWR and the VerpackDG, the requirements relating to packaging are continuing to evolve. Regardless of individual legal assessments, it is already clear today that packaging data, documentation and traceable processes will play a greater role in the future.
Many requirements will only be introduced gradually. Companies can use the time remaining to create transparency regarding existing packaging data, responsibilities and processes, and to prepare for potential future requirements.
Those who establish an overview of packaging information, data sources and responsibilities at an early stage not only facilitate internal collaboration but also frequently improve the quality of master data, product information and logistics processes.
For many online retailers, the PPWR will therefore become less of a purely packaging-related issue and more of a data and organisational one.
Note
This article is intended solely to provide general information on current developments relating to the PPWR and the VerpackDG and does not constitute legal advice. The actual requirements depend on numerous factors, including the type of packaging, product category, supply chain, distribution model and target market. Furthermore, individual provisions may be subject to further European implementing or delegated acts. For a legal assessment of your specific situation, we recommend consulting qualified legal advisers or specialist compliance service providers.
Sources and further information
Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) eur-lex.europa.eu
Packaging Law Implementation Act (VerpackDG), Federal Law Gazette 2026 I No. 207 gesetze-im...nternet.de
Central Packaging Register (ZSVR): Information on the PPWR and the VerpackDG
European Commission: Packaging and Packaging Waste Regulation (PPWR) baumann-re...nwaelte.de], [taylorwessing.com
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