The new EU Packaging Regulation (PPWR) represents one of the most comprehensive regulatory changes for the European economy.
The goal is a systematic shift away from the traditional linear economy toward closed-loop systems. Although many companies are already grappling intensively with this issue, serious misconceptions persist in practice.
Misconception 1: “Packaging compliance is solely the manufacturer’s responsibility.”
The reality:
The PPWR holds the entire value chain accountable. All so-called “economic operators” – including importers, distributors, online retailers, and fulfillment service providers – bear independent legal responsibility. What matters is not the physical production, but the placing on the market or making available of packaged goods on the EU market.
Anyone who has products packaged under their own brand or imports them is legally liable as a producer and must provide proof of compliance.
Misconception 2: “Switching to a different material solves the problem.”
The reality:
Simply replacing the material is not enough. As of the effective date, the PPWR requires complete proof of compliance. Companies must request detailed material data from their suppliers, document pollutant limit values, and maintain official documentation.
Without a transparent, digital database, legally compliant distribution of goods becomes impossible – regardless of what material the packaging is made of.
Misconception 3: “Using only recycled materials automatically guarantees compliance.”
The reality:
Simply using recycled materials or paper is not enough on its own. The first compliance requirements for packaging will take effect as early as August 2026 (e.g., for pollutant limits).
Starting January 1, 2030, the rules will become significantly stricter: All packaging must be recyclable and meet the criteria for new performance levels (Classes A through C, with a minimum recyclability rate of 70%). Packaging below Class C will lose its market authorization.
In addition, strict packaging minimization requirements will apply: weight and volume must be demonstrably reduced to the functional minimum (e.g., through strict limits on empty space). For transport and e-commerce packaging, there is also a strict limit on empty space of no more than 50 percent.
Those who focus solely on the material overlook these mandatory requirements.
Conclusion
The biggest hurdle of the PPWR usually lies not in the design of the packaging itself, but in adapting internal processes and managing the required data. The transition requires a profound transformation across the entire product lifecycle.
Are you already PPWR-ready or do you need help with implementation? Contact us!
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