On 22 January 2025, the new EU Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40) (PPWR) was published.
It entered into force on 12 February 2025.
1. Background and timeline
📅 Most provisions will apply from 12 August 2026, following a transitional period of 18 months.
📈 Further requirements will be phased in progressively until 2040.
The PPWR replaces the previous EU Packaging Directive and has direct effect in all EU Member States – without the need for national transposition measures. In Germany, large parts of the existing Packaging Act (VerpackG) will be repealed or adapted to the new Regulation by August 2026.
2. What are the key changes?
a) Design for Recycling
From 2030 onwards, only packaging that is fully recyclable in accordance with strict EU criteria may be placed on the market.
b) Minimum recycled content
Plastic packaging will be required to contain a prescribed minimum proportion of recycled material, with quotas increasing over time.
c) Reduction of packaging waste
By 2040, packaging waste per capita is to be reduced by 15% EU-wide compared to 2018 levels.
d) Reuse and refill systems
From 2030, e-commerce companies will be required to meet certain reuse targets or participate in equivalent systems.
e) Ban on oversized and unnecessary packaging
From 2030, the empty space ratio in shipping packaging may not exceed 50%. Single-use packaging will be prohibited in specific sectors.
f) Ban on harmful substances
Packaging in contact with food may not contain PFAS or comparable harmful substances.
g) Harmonised labelling
All packaging will be required to bear standardised symbols and information on material composition and disposal (e.g. pictograms, QR codes).
h) Extended Producer Responsibility (EPR)
Producers, importers and distributors must register with a national EPR register in each EU country where they place packaging on the market – including financing the collection, sorting and recovery of packaging waste.
4. How is Extended Producer Responsibility (EPR) changing?
EPR obligations will be harmonised and expanded across the EU. They include:
- Obligation to register in each individual EU Member State where packaged goods are marketed,
- Obligation to appoint an authorised representative if no establishment exists in the destination country,
- Increasing reporting requirements (material type, quantities, recycled content),
- Full cost coverage for collection, sorting and recovery,
- New labelling obligations with symbols or QR codes.
Conclusion: Prepare now – secure regulatory and commercial advantages
The new PPWR will bring profound changes, particularly for e-commerce businesses – but also opportunities to implement sustainable packaging solutions.
The earlier you adapt your packaging strategy and processes, the better you can avoid delivery stoppages, fines, and compliance risks.
Grau Rechtsanwälte PartGmbB offers legal support in your daily business, especially for foreign companies that operate subsidiaries in Germany or are suppliers of German companies – the entire spectrum of German commercial law, starting with corporate law, through distribution law, labour law, insolvency law and claims management.
If you have any further questions, please contact our law firm on +49 (0) 40 180 364 020 or kontakt@graulaw.eu.
