PPWR – New Packaging Laws Are Coming

“Design for Recycling is becoming mandatory — and thus a strategic product decision.”

Introduction

On August 12, 2026, the PPWR (Packaging and Packaging Waste Regulation) will become legally binding. With the Packaging Law Implementation Act passed by the Federal Cabinet on February 11, 2026, Germany is implementing the European regulation at the national level and replacing the previous Packaging Act.

This creates a concrete need for action for companies along the value chain.

What is PPWR?

The PPWR is the new EU Packaging Regulation and part of the European Green Deal under the Circular Economy Action Plan. Unlike the previous Packaging Directive, it applies directly in all EU member states, thereby ensuring uniform requirements across the European single market.

The regulation’s objectives are to:

• Significantly reduce packaging waste
• Strengthen recycling across Europe
• Establish binding standards for recyclability
• Increase resource efficiency and transparency

The PPWR applies to all packaging—regardless of whether it is used as end-use or transport packaging.

An overview of the most important changes

Mandatory recyclability: In the future, packaging must meet uniform EU-wide criteria for recyclability. “Design for Recycling” thus becomes a legal requirement.

This applies, among other things, to:

• Material combinations
• Separability of individual components
• Labeling and sortability

Non-recyclable packaging will eventually be phased out of the market.

Minimum recycled content requirements: Mandatory recycled content quotas will be introduced for certain types of plastic packaging. Companies must demonstrate the actual percentage of post-consumer recycled material used.

This requires:

• Reliable supply chains
• Verified material quality
• Transparent documentation

Reusable packaging and waste reduction targets: The PPWR defines specific reduction targets for packaging waste. In addition, mandatory reusable packaging quotas will be introduced in selected sectors, such as the beverage, transportation, and e-commerce sectors. Companies must assess whether existing single-use systems will still be permitted in the future.

Extended producer responsibility: The requirements for registration, information obligations, and supporting documentation are being significantly expanded. Manufacturers, producers, and suppliers must be able to provide detailed information on:

• Material composition
• Recyclability
• Recycled content

Missing or incorrect information may result in market restrictions or sanctions.

Criticism from the Business Community—Justified or Outdated?

Representatives from industry and commerce have, in some cases, expressed criticism of the new implementing law.

The following issues are cited:

• Rising bureaucratic costs
• Unclear responsibilities
• Lack of investment incentives
• Uncertainties regarding transition periods

At the same time, the European direction is clear: The transition to a circular economy has been politically decided and is enshrined in regulations.
Regardless of specific criticisms, companies are facing clear pressure to adapt.

Strategic Action Required for Companies

The PPWR is not purely a legal issue—it affects product development, procurement, logistics, sustainability strategy, and compliance in equal measure.

Companies should now:

• Systematically review packaging portfolios
• Assess recyclability
• Ensure the availability of recycled materials
• Establish internal data structures and documentation processes
• Clearly define responsibilities

Those who focus early on PPWR compliance, circular design, and robust data structures reduce regulatory risks and can build sustainable competitive advantages. There is a strategic need for action, particularly for manufacturers, producers, and suppliers—including with regard to ESG reporting and supply chain requirements.