The PPWR redefines Extended Producer Responsibility: in future, the role within the value chain will count, rather than just that of the traditional producer. Retailers selling own-brand products are automatically considered ‘producers’ and bear responsibility for the packaging; passing this on to suppliers is not permitted. In the case of imports without an intermediary, the retailer also becomes the responsible scheme participant. In future, therefore, companies must not only ensure recycling financing but also register all packaging with a dual system prior to distribution. The effective date is 12 August 2026. There is no transition period, and failure to achieve full compliance may result in a sales ban.
Focus on data management and supply chain transparency
Incorrect or incomplete quantity reports can financially impact recycling and disposal systems and complicate the planning of sorting and recovery capacities, thereby jeopardising recycling targets. Accurate reporting of volumes and corresponding contract adjustments require precise details on packaging weights and materials, which includes end-to-end documentation of all packaging data. Retailers are therefore also required to adapt their processes, ensure transparency regarding packaging flows, and keep registrations, brand names and reporting data up to date and consistent at all times. Close cooperation with suppliers is essential here, as complete and reliable packaging and product data form the basis for compliance with legal requirements in the retail sector.
Companies must take action now: conclude system participation agreements, capture data within the supply chain, update registrations and reports, and establish audit-proof documentation. Timely action prevents sales bans and ensures compliance with legal obligations.
Clarifying roles and expertise as key factors for successful PPWR implementation
The conclusion is clear: the PPWR is not a theoretical regulatory issue but an operational obligation with immediate economic implications. Retailers and producers should therefore invest specifically in expertise to gain a clear understanding of their roles. So do not miss the kick-off workshop of our trade-e-bility workshop series on 28 May 2026 on the topic of roles and responsibilities under the new Regulation (EU) 2025/40 on packaging and packaging waste (definitions, distinctions and duties of “manufacturers” and “producers”).
By understanding your specific obligations across the whole value chain, you can avoid legal uncertainties and systematically reduce risks.
Obtain the expert knowledge needed to help your company meet the new EU regulations
Reserve your spot at the PPWR workshop today!
Please note: If you book all sessions, you will receive one of them free of charge! VERE members also save an additional 25 euros per workshop. You can request the promo code at info@vereev.de. Not yet a VERE member? Then sign up now! Please feel free to share this offer with your business partners and colleagues.
Do you already have specific questions about the EU Packaging Regulation? trade-e-bility is happy to assist you at +49 40/750687-300 or send us an email.
