EU Packaging Regulation, PPWR and German VerpackDG – Everything you need to know

The Packaging Regulation (PPWR) is a new EU directive concerning packaging and packaging waste. It applies in all EU countries.  

The aim of the regulation is to expand the circular economy and better protect the environment and climate. To this end, packaging waste is to be reduced, recycling and reuse promoted, waste separation made easier, and uniform rules established for the EU market.

The requirements apply to all types of packaging, regardless of whether they are made of plastic, paper, glass or metal. It is important that the entire product life cycle is taken into account – from manufacturing to disposal.

The PPWR therefore applies, amongst others, to:

• Retail packaging
• Outer packaging
• Transport packaging

All terms at a glance:

• EU Packaging Regulation = Packaging and Packaging Waste Regulation (abbreviation: PPWR), Regulation (EU) 2025/40
• VerpackDG (short for German: Verpackungsrecht-Durchführungsgesetz) = Packaging Law Implementation Act, also called Packaging Act

The difference between the PPWR and the Packaging Act is that the PPWR sets out requirements across the EU, whilst the nationally applicable Packaging Act applies these requirements throughout Germany. The Packaging Act therefore implements the EU regulation in practice. It regulates responsibilities, processes and the financing of waste management systems.

Producers must therefore design their packaging in accordance with EU requirements whilst complying with German processes.

When do these regulations come into force?

• PPWR: entered into force on 11 February 2025, must be implemented from 12 August 2026
• VerpackDG: at draft stage since February 2026, is intended to apply from 12 August 2026 as a supplement to the PPWR

The key provisions of the PPWR summarized: Packaging can only be placed on the market if it is recyclable and made from as little material as possible.

The PPWR focuses on waste prevention, reuse and recycling. Unnecessary or purely marketing-driven packaging is to be avoided, making ‘design for recycling’ a requirement. Furthermore, reuse and refill systems will become mandatory.

This results in the following specific requirements for producers:

• Packaging design must be recyclable
• Unnecessary or oversized material is not permitted  
• Plastic must contain a minimum proportion of recycled material  
• Reusable and refill solutions must be used more widely
• Packaging must be clearly and uniformly labelled (material, disposal)  
• Documentation processes and reporting requirements are being expanded
• Participation in the system is mandatory
• Registrations, volume reporting and approval requirements for packaging

Overall, packaging must therefore be simpler, more sustainable and more traceable, which means that supply chains, design and processes must be adapted. Only in this way can producers remain competitive and avoid fines and sales bans.

All companies that produce, import, manufacture, distribute or fill packaging in the EU are affected. This includes producers, manufacturers, sellers and importers, all of whom must comply with the new requirements.