Requirements of the EU Packaging Directive for Industrial Companies

As of August 12, 2026, the EU Packaging and Packaging Waste Regulation (PPWR—Regulation (EU) 2025/40) is generally applicable in all EU member states. It replaces the previous Packaging Directive 94/62/EC in accordance with the established transition and repeal provisions and affects not only consumer goods manufacturers but also numerous industrial companies.

Production, transport, repackaging, and shipping packaging are particularly relevant. The specific obligations a company must fulfill depend, among other things, on the type of packaging, its role in the supply chain, and the applicable regulations. In addition to requirements already in effect, companies must also keep an eye on future deadlines and transitional provisions.

For industrial companies, this means that packaging must increasingly be considered from the perspective of resource efficiency, recyclability, and traceability. Companies that establish transparency regarding materials, suppliers, and packaging processes early on can reduce regulatory risks and better plan for necessary adjustments.

The PPWR is an EU regulation and, in principle, is directly applicable in the member states. Unlike a directive, it does not first need to be fully transposed into national law. This results in a more harmonized European legal framework. However, national implementing regulations, differences in enforcement, and rules on extended producer responsibility remain relevant.

The central objective of the regulation is to prevent packaging waste, reduce material consumption, and strengthen the circular economy. To this end, the PPWR sets out requirements for packaging design, material use, reuse, recyclability, and proof of compliance.

For industrial companies, this means that end-of-life disposal is not the only decisive factor. The relevant requirements must be taken into account as early as the selection of packaging materials, the design of transport packaging, and the development of reusable systems.

Even packaging that is not directly supplied to end consumers may fall under the regulation. This includes, for example, packaging for spare parts, industrial components, or machinery. The specific obligations that apply in each case depend on the type of packaging and the applicable regulations.

The PPWR distinguishes between various economic operators, in particular manufacturers, producers, suppliers, importers, and distributors. These terms are not legally synonymous. The role a company plays and the obligations that result from it are determined by the definitions in Article 3 and the other relevant provisions of the regulation.

The producer is specifically responsible for the conformity of the packaging and the associated documentation. The manufacturer, as defined by the PPWR, is primarily subject to extended producer responsibility, for example with regard to registration and financing of waste disposal. Both roles may be fulfilled by a single company.

Even companies that do not produce packaging themselves may be affected. For example, importing packaging, supplying packaged products, or using a proprietary brand may trigger certain obligations. Whether a company is considered a manufacturer or a producer—or is subject to other obligations—must be determined based on the specific circumstances of supply and market distribution.

In practice, companies may assume multiple roles simultaneously. For example, a business may manufacture packaged goods, import packaging from a third country, and act as a distributor at the same time. Different requirements may apply to each scenario.

A systematic analysis of roles and packaging is therefore a sensible first step in implementing the PPWR. In doing so, companies should document the types of packaging they use, where they come from, and the resulting responsibilities.

Technical documentation serves as an essential basis for demonstrating conformity. It is intended to provide a clear account of how the relevant requirements are assessed and met.
Depending on the packaging and requirements, this may include, for example:

• Information on materials, components, and packaging design
• Technical specifications and information on the intended use
• Appropriate test reports and technical evaluations
• Evidence of relevant material properties and recycled content
• Supplier information and declarations regarding the materials used
• Information on recyclability and the assessment methods used

Which documents are required in a specific case depends on the applicable regulations. Supplier declarations can support the documentation process but do not automatically replace the responsible producer’s own conformity assessment.

Suppliers of packaging or packaging materials are required to provide the producer with the information and documentation needed to demonstrate compliance. This includes the relevant technical specifications for materials and packaging components. The supplier’s obligation to provide information does not replace the conformity assessment and EU Declaration of Conformity issued by the responsible manufacturer.

For industrial companies with many packaging variants and part numbers, a structured documentation system is therefore recommended. Purchasing, product development, quality management, and logistics should be assigned clearly defined responsibilities. This allows missing information to be identified early on and technical evidence to be provided efficiently when needed.

The PPWR imposes restrictions on certain substances in packaging. This generally includes a total limit of 100 mg/kg for lead, cadmium, mercury, and hexavalent chromium. The relevant provisions and possible exceptions apply.

In addition, the regulation imposes restrictions on PFAS—per- and polyfluoroalkyl substances—in food contact packaging. This group of substances may be relevant, for example, in certain water- and grease-repellent materials. However, the regulation should not be interpreted broadly as a blanket ban on PFAS for all industrial and transport packaging.

Industrial companies should therefore first verify which substance restrictions actually apply to their packaging and intended uses. Coated, laminated, or multi-layered packaging may be particularly relevant.

Compliance can be documented on a case-by-case basis using appropriate supplier information, technical documentation, and, where applicable, analytical test reports. Safety data sheets can be helpful in this regard but are not universal proof of a packaging’s full compliance with substance requirements.

To ensure planning certainty, it is also important to distinguish between requirements that are already applicable and detailed specifications that have yet to be finalized. Delegated acts and implementing acts may establish further technical details. Guidelines and FAQs from the European Commission provide guidance but are not equivalent to binding legal provisions.

The PPWR is gradually introducing stricter requirements regarding the recyclability of packaging and the use of recycled plastics. It is therefore in companies’ best interest to begin exploring potential adjustments to materials, packaging design, and supplier agreements today.

Starting in 2030, the relevant “design for recycling” requirements will generally take effect. Packaging must then meet the applicable criteria for recyclability. Beginning in 2035, an additional assessment will be required to determine whether packaging can be recycled on a large scale (“at scale”). The specific requirements and transitional provisions must be taken into account in each case. The effective dates may be postponed accordingly due to the deadlines for supplementary EU legislative acts set forth in Article 6.

For plastic packaging, Article 7 of the PPWR stipulates minimum percentages of recycled plastic. These vary by packaging category and scope of application. For 2030, for example, the following minimum percentages are specified:

• 30% for certain PET-based food-contact plastic packaging
• 10% for other food-contact plastic packaging
• 35% for other plastic packaging

By 2040, the minimum percentages will increase to 25%, 50%, or 65%, depending on the category. When conducting a specific assessment, statutory exemptions and special provisions, as well as the relevant implementing provisions, must be taken into account. According to Article 7(5)(b), plastic components are exempt from the minimum recycled content requirements if they account for less than 5% of the total weight of the entire packaging unit.

Changes are also planned for repackaging, transport, and e-commerce packaging. Article 24 generally stipulates a maximum void ratio of 50% for the packaging in question. The requirement takes effect on January 1, 2030, or three years after the relevant implementing act enters into force, whichever is later. Companies should therefore check whether their packaging sizes, cushioning materials
Companies should therefore check whether their packaging sizes, cushioning materials, and shipping processes comply with future requirements.

Article 29 generally requires a reusable rate of at least 40% for certain transport packaging, such as pallets and crates, starting in 2030; stricter reuse requirements apply to certain transport scenarios. Packaging custom-designed for large machinery, equipment, or raw materials, in particular, may be exempt (Article 29(4)(b)). The requirements for such an exemption must be assessed on a case-by-case basis and documented in a transparent manner with appropriate supporting documentation.

The real challenge begins long before the respective deadlines: packaging designs, supplier contracts, material availability, and internal data processes cannot be changed on short notice. Companies that integrate recyclability and recycled content into their procurement and development processes early on improve their planning certainty and can identify potential bottlenecks in a timely manner.

Non-compliant packaging may, under the applicable regulations, lead to corrective actions by regulatory authorities and, if necessary, to restrictions or bans on its placement on the market. An early transition therefore not only helps ensure compliance with legal requirements but can also improve resource efficiency and competitiveness.

PPWR is not merely a legal issue for the legal department. It affects numerous operational areas of the company.

The purchasing department must obtain relevant material information and appropriate documentation from suppliers. Product development should consider recyclability, material combinations, and packaging minimization at an early stage. Quality management can coordinate documentation and conformity assessment. Logistics should assess the implications for packaging sizes, void space, transport capacity utilization, and reusable systems.

For industrial companies, a systematic review of the entire packaging portfolio is recommended. In particular, the following questions should be addressed:

• What packaging materials, formats, labels, adhesives, and coatings are used?
• Which packaging items consist of multiple materials or layers of material?
• What information and documentation can the respective suppliers provide?
• Which packaging is suitable for reuse or improved recycling?
• What future requirements apply to the respective types of packaging?
• How are technical documentation and responsibilities managed internally?

Assessment systems such as RecyClass can help companies systematically evaluate the recyclability of plastic packaging and identify potential weaknesses. However, they do not replace the need to review legal requirements and the relevant assessment methods.

At the same time, companies should develop a recycled material strategy. This includes assessing material availability, coordinating with suppliers, entering into long-term procurement agreements where appropriate, and maintaining transparent internal documentation.

The national level also remains relevant. In Germany, the Packaging Law Implementation Act (VerpackDG) supplements the European legal framework. It contains provisions on national enforcement and aspects of producer responsibility. Companies must therefore take into account not only the PPWR but also the German provisions applicable to them, particularly with regard to registration, participation in recycling systems, and reporting requirements. The specific obligations in each case depend, among other things, on the type of packaging and the company’s role.