Less waste, more recycling, unified rules in the European single market: the goals of the new EU Packaging Regulation sound promising. However, businesses now face a demanding practical test. Numerous new requirements are met with unanswered questions of interpretation, lack of specifics, and tight implementation timelines.

New Rules Across the Entire Value Chain

Since 12 August 2026, the Packaging and Packaging Waste Regulation (PPWR) applies in all EU member states. Some regulations are already in effect, while others will be implemented gradually. It fundamentally covers packaging of all materials and obliges all companies along the entire value chain. Depending on their role—such as producer, manufacturer, importer, or distributor—businesses must demonstrate the conformity of their packaging and have technical documentation and declarations of conformity ready. Additionally, new requirements regarding recyclability, recycled content, packaging minimization, labelling, and extended producer responsibility will come into effect in the coming years.

What might look like EU-wide harmonization on paper means, in practice, profound changes for businesses: packaging designs, material usage, procurement, product data, IT systems, and contractual relationships need to be reviewed and, in some cases, reorganized. On top of this, a new, complex distribution of roles emerges. For example, a company might take on multiple roles for different packaging and therefore bear differing obligations. A business that, for example, imports goods from third countries, sells them under its own brand, and additionally ships them to customers must comply with various packaging requirements. This complicates the assignment of responsibilities and increases the need for reliable information and close coordination within the supply chain. Moreover, there are liability risks if information is not provided completely or in a timely manner.

Practical Check – Inadequate

Particularly critical for many businesses are the new rules concerning the appointment of representatives abroad in Europe. In the future, manufacturers who market packaging in another EU member state without a local branch will generally need to appoint an authorized representative. This person will take on responsibilities connected to extended producer responsibility. Especially smaller businesses that have so far operated cross-border within the EU single market without complications now face new market entry barriers. This could lead to increased costs and withdrawal from individual markets—a contradiction to the core idea of the PPWR to strengthen the single market with unified rules.

Planning Security Comes too Late

Furthermore, many details still need to be specified through delegated legal and implementing acts. As long as definitions, calculation methods, or proof formats are missing, businesses cannot plan investments and adjustments with certainty. This affects not only the packaging industry: almost every company that packages, imports, or distributes goods must engage with the new regulation.

There is also the risk of a regulatory patchwork. While the PPWR is designed to strengthen the single market, it still permits national procedures for registration and extended producer responsibility. If additional national special regulations are introduced, the aim of unified European rules will again be missed.

What Must Happen Now

The objectives of the PPWR—less packaging waste, high-quality recycling, and functional material cycles—are fundamentally correct. However, their implementation must be practical, proportionate, and consistent across Europe. Businesses need early, binding, and comprehensible guidelines. Specific legal acts, guidelines, and standards must be available well in advance of the respective obligation dates, and appropriate transitional solutions must be offered, if necessary.

Existing proofs and digital infrastructures should be utilized, redundant reporting should be avoided, and registration procedures should be standardized across Europe through digital one-stop-shop solutions. Proportionality is also needed in inspections and sanctions: during the introductory phase, information and support should take precedence, provided companies are visibly working on the implementation. 

For further information and practical assistance regarding the implementation of the PPWR, the German Chamber of Commerce and Industry (DIHK) offers the event PPWR in the Practical Check on 13 October 2026, focusing on the practical implications of the regulation and current questions from business practice.