Since August 12, 2026, the 2025 EU Regulation on Packaging and Packaging Waste (Packaging and Packaging Waste Regulation, PPWR) has been in effect. It aims to reduce the amount of packaging waste and strengthen the circular economy – goals supported by the German Chamber of Commerce and Industry (DIHK). However, many unanswered questions particularly burden small businesses with cross-border activities.

Background

The PPWR aims to provide uniform requirements for companies in the European Union. However, many technical requirements, such as those for labelling, recyclability, and conformity assessments, are still outstanding. At the same time, it is not always clear to companies who should provide information and evidence along the supply chain. Different national registers, languages and procedures further complicate cross-border trade. The DIHK proposes five changes to better align environmental goals with a functioning internal market:

DIHK Proposals

• Simplify documentation requirements: The DIHK recommends locating obligations where the necessary product and conformity information is available. A uniform packaging data sheet, standardized templates and fewer multiple evidences could reduce the effort.
• Create a digital point of contact: A central portal should consolidate registrations, evidence, and reports. According to the "once-only" principle, companies should only have to provide data once. For small quantities and occasional deliveries to other member states, the European Union should also examine uniform de minimis thresholds. As a guideline, the DIHK mentions 500 kilograms of packaging material per member state and year.
• Establish legal certainty early: Technical requirements should be published early. There should be a lead time of at least twelve months between their publication and mandatory application. Roles and responsibilities should be standardized across the EU; from the DIHK's perspective, non-binding guidelines alone are not sufficient.
• Protect stock and enable transitions: Packaging and stock goods lawfully placed on the market should continue to be usable until sold. Companies should not have to retrofit or destroy existing stocks retrospectively.
• Ensure harmonization: The DIHK opposes additional national labelling, registration, and reporting obligations. Registers, fees, and evidence formats should be as standardized as possible, and evidence should be mutually recognized.

Download

Read the details in the DIHK paper dated October 9, 2026
(only available in German)