The transition from the German Packaging Act (VerpackG) to the new EU Packaging Regulation (PPWR) will bring far-reaching changes for companies.
What will happen on August 12, 2026?
From this date onwards, the EU Packaging Regulation (PPWR) will apply directly in all member states.
Who will officially be considered a “manufacturer” in 2026?
- It will be the party who first makes the packaged goods available in the respective EU country.
New: Anyone sending goods directly to end customers in the EU from a non-EU country must have an authorized representative in the destination country who assumes EPR liability.
Can I still use up my old cardboard boxes in 2026?
Stocks that were already “placed on the market” (i.e., made available for sale) before August 12, 2026, may be sold off. Purely stock items in your own warehouse that are not yet registered as goods packaging units could become critical.
This is because everything newly produced after that date must meet strict design-for-recycling criteria.
Will there be a ban on “empty space” in 2026?
Yes, “shipping air” will become expensive and illegal. The 50% empty space quota applies to shipping packaging in e-commerce and to collective packaging.
Important: The ban on artificially inflating volume with fillers (air cushions, paper) is a key point in material minimization.
Which types of packaging will be completely banned in 2026?
The new PPWR requirements do not mean that all affected packaging will be completely banned as early as 2026. Instead, the regulation takes a step-by-step approach.
Areas that will be affected early on:
- Catering: Single-use packaging for food and beverages consumed on site is considered avoidable and will therefore be addressed particularly early on. However, the complete bans will take effect gradually, not abruptly in 2026.
- Hotels: Small single-use cosmetic packaging such as mini shampoos or soaps will also be reduced gradually. Many requirements are already in place today, with further tightening to follow in stages.
- Retail: Exceptions remain for fruit and vegetable bags (“lightweight plastic carrier bags”) – for example, for very thin, compostable bags for hygiene reasons. Here, too, the regulation will not take the form of a complete ban from 2026, but will be implemented through graduated requirements.
Will my packaging have to contain a minimum proportion of recycled plastic (recyclate) from 2026?
- Not immediately from August 2026, but the course will be set then. The PPWR stipulates binding recycled content quotas that will apply from January 1, 2030 (e.g., 35% for most plastic packaging).
Why this is important: Anyone planning new packaging lines in 2026 must ensure now that their suppliers are able to use certified post-consumer recycled material (PCR). The documentation requirement for this begins with the 2026 declaration of conformity.
What will happen to waste separation labeling (disposal instructions)?
- The PPWR introduces EU-wide harmonized labeling.
- Packaging must be marked with pictograms that show consumers which bin the packaging belongs in. The same symbols must then also be found on waste containers in public spaces.
- Critical: For companies, this means that almost all sales packaging layouts will have to be revised by 2026/2027 and supplemented with the new EU icons. National initiatives (such as the French Triman labeling) are to be incorporated into this in the long term.
What is the “digital product passport” (QR code)?
From 2026: Packaging must gradually be provided with a QR code.
The labeling requirement (QR code) will start in 2026, and the full scope of the digital passport (including recycled content verification) will be detailed in delegated acts of the EU in the following years (until around 2028).
Do I have to register separately in each EU country?
- The PPWR aims to harmonize this.
- There is no central EU register for licensing (yet). Registration must still be carried out in each country where you sell.
What is the “declaration of conformity” for packaging?
From August 2026, manufacturers must prove that each piece of packaging meets the PPWR requirements (technical documentation).
Although there are exceptions for specific recycled content quotas or take-back systems for very small companies (often with fewer than 10 employees or below certain turnover thresholds), the registration requirement and the ban on empty space apply in principle to anyone who puts packaging into circulation.
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