Expert consulting on the implementation of the PPWR (EU packaging regulation)

Understanding the EU Packaging and Packaging Waste Regulation (PPWR)

The newly introduced EU Packaging and Packaging Waste Regulation (PPWR) presents significant challenges for companies, particularly for medium-sized enterprises, requiring substantial adjustments. To support you, we have summarized the key requirements of the PPWR and offer tailored consulting – helping you ensure compliance with legal obligations while optimizing your packaging and waste management practices.

Which companies are affected by the PPWR regulation?

The PPWR generally affects all companies involved in the production, distribution, or use of packaging. The extent of its impact varies depending on the industry, product type, and business model. Sectors particularly impacted include:

• Packaging manufacturers
• Fast-moving consumer goods (FMCG) companies
• Recycling and waste management firms
• Retailers with private-label products

To help you better understand the specific implications for your business, our PPWR Impact Matrix offers a detailed overview of how the regulation affects different industries:

Overview of key PPWR content

The Packaging and Packaging Waste Regulation (PPWR) came into force on February 11, 2025, and will fully replace the previous Packaging Directive 94/62/EC as of August 12, 2026. The regulation governs the production, use, reuse, recycling, and disposal of packaging throughout the EU. Companies are required to implement the new PPWR requirements progressively and on schedule. However, certain exemptions apply – notably for medical devices and products sensitive to contact.

Requirements due by August 2026:

• PPWR conformity assessment: Implementing new rules for packaging conformity, including preparing technical documentation and issuing an EU Declaration of Conformity.
• Information, notification, and reporting duties: Informing consumers about packaging refill options in line with PPWR requirements.
• Labeling obligations: Marking packaging with identification features and contact details, such as QR codes, to ensure traceability and consumer transparency.
• Substance restrictions: Ensuring that packaging materials meet specified substance limit values as defined under the PPWR.
• Reuse and refilling: Participating in reusable packaging systems and providing consumers with relevant usage information.

Additional requirements from 2027 to 2030:

• Compostability
• Extended Producer Responsibility (EPR)
• Bio-based plastics
• Deposit and return systems
• Recyclability
• Minimum recycled content requirements
• Minimizing packaging quantities
• Packaging formats (“cheat packs”)
• Reduction of packaging waste

Although the deadlines provide some leeway, starting PPWR implementation early is crucial to ensuring future supply security.

Companies must prepare for significant challenges, such as maintaining packaging quality while adapting to new requirements – changes that may result in additional costs. Investments in new technologies by packaging manufacturers are expected, with cost increases likely cascading through the supply chain. Furthermore, non-compliance could lead to a ban on the use of packaging or fines, which may potentially be accompanied by significant losses in revenue and reputational damage.

How should companies prepare for the PPWR requirements?

Early and structured preparation for the PPWR is key. Companies should promptly assess their packaging portfolios to identify necessary adjustments and understand the regulation’s impact. This analysis provides the basis for prioritizing PPWR requirements and defining appropriate action plans.

The next phase involves piloting short-term measures, using these early experiences to build expertise and prepare for the more complex medium- and long-term requirements. Although the deadlines for some requirements are extended, their complexity demands immediate strategic planning and early action to ensure full compliance.

How can we support you in meeting the PPWR requirements?

Our specialized consulting services focus on the following key areas:

• PPWR Readiness Check: Identification of affected packaging and analysis of compliance gaps to ensure full alignment with PPWR requirements.
• PPWR Roadmap: Development of a structured, actionable roadmap that prioritizes necessary measures based on regulatory requirements and business impact.
• PPWR Piloting: Design and implementation of pilot projects to address both short-term requirements and prepare for complex long-term requirements.