The new EU Packaging and Packaging Waste Regulation (PPWR): What businesses need to know now

The European Union stands at a crucial juncture in its environmental policy, and the EU Packaging and Packaging Waste Regulation (PPWR) is a central component of this transformation. It supersedes the previous Packaging Directive and marks a paradigm shift in the circular economy for packaging. For businesses in the EU and beyond, this entails far-reaching adjustments. This article provides a comprehensive overview of the key aspects of the PPWR, its objectives, the PPWR timeline for its introduction, and the crucial differences between EU packaging law and national packaging laws.

Introduction to the PPWR: Objectives and significance for the EU internal market

The PPWR is not just another EU packaging law; it is a directly applicable regulation. This shift from a Directive to a Regulation is of fundamental importance: while directives must be transposed into national law by member states, allowing for variations, a regulation applies directly and harmonises rules across the EU. The aim is to create an almost fully harmonised internal market, thereby reducing legal uncertainties for investment decisions.

The overarching objectives of the PPWR are clearly defined:

• Reduction of packaging waste: The regulation sets ambitious reduction targets of 5% by 2030, 10% by 2035, and 15% by 2040 (based on reported packaging waste per capita from 2018).
• Harmonisation of the internal market: Uniform rules are intended to enable fair competition and prevent the free movement of goods from being hindered by differing national regulations.
• Transition to a circular economy: The PPWR promotes the reuse and high-quality recycling of packaging and incentivises sustainable packaging solutions.

This is a decisive step for the EU Packaging and Packaging Waste Regulation to make the EU more resilient to external shocks and reduce dependence on virgin raw materials. 

Procedure and PPWR timeline of the EU Packaging and Packaging Waste Regulation

The legislative process of the PPWR has been complex, progressing through several stages:

• November 30, 2022: The European Commission published its proposal.
• October 24, 2023: The European Parliament’s Environment Committee voted on its report.
• November 22, 2023: The European Parliament adopted its position in plenary.
• December 18, 2023: The Council (Environment) agreed on a general approach.
• February 5, 2024 & March 4, 2024: The first two trilogue sessions led to a provisional overall agreement.
• April 24, 2024: Parliament’s decision.
• November 27, 2024: Final adoption by the European Parliament.
• December 16, 2024: Council approval.
• January 22, 2025: Publication in the Official Journal of the European Union.
• February 11, 2025: Entry into force of the regulation.
• August 12, 2026: The PPWR timeline for application begins on this date (Art. 71)

The EU Packaging and Packaging Waste Regulation (PPWR) is very comprehensive, with 71 articles, 13 annexes, and 124 pages. Numerous concretisations through 24 implementing acts, guidelines, and standards are still planned, which will make implementation highly complex for businesses.

Key changes between EU packaging laws and national packaging laws

Although the EU Packaging and Packaging Waste Regulation and national packaging laws (like the German Packaging Act – VerpackG) are partly similar in their system and terminology, there are significant deviations that companies must carefully review.

1. Direct Applicability vs. National Transposition: The most significant difference is the aforementioned shift from a Directive to a Regulation. National packaging laws are national legislation transposing the former EU Packaging Directive. The PPWR, however, will apply directly in all Member States from August 12, 2026. This aims to end inconsistent implementation in Member States and ensure greater harmonisation.
2. Parallel Application of EU and National Law: Nevertheless, the PPWR still leaves considerable scope for national regulations. A national implementing act for the EU Packaging and Packaging Waste Regulation is expected in Germany (a draft bill is anticipated for September 2025), meaning that European and national law will apply in parallel in the future. A challenge here is the mid-year application of the PPWR on August 12, 2026, with Germany striving for a solution for the broadest possible implementation by January 1, 2027, to maintain contract terms and reporting periods.
3. Definitions and Scope of Obligations: The PPWR contains 71 legal definitions. While the “packaging concept” itself largely corresponds to national versions (e.g., service packaging, outer packaging, transport packaging, e-commerce packaging, composite packaging), there are clear deviations regarding the “obligated parties.” The PPWR introduces the umbrella term “economic operator,” encompassing producers, suppliers, importers, distributors, authorised representatives, final distributors, and fulfilment service providers. A distinction is also made between “producer” (who manufactures packaging or packaged products and is responsible for conformity assessment/technical documentation) and “manufacturer” (who first places packaging on the market in a Member State and is responsible for registration and extended producer responsibility). Definitions of “consumer” and “final user” also broadly correspond to national terms. Precise scrutiny of these definitions is essential, as the scope of respective obligations depends on them.

The EU Packaging and Packaging Waste Regulation is a highly complex piece of legislation, whose implementation requires precise knowledge of the new provisions. For companies operating in the EU internal market, it is crucial to familiarise themselves with the details at an early stage to ensure compliance and seize opportunities in transitioning to more sustainable packaging solutions.

Stay tuned for the continuation of our blog series, where we will delve deeper into the specific material requirements of the PPWR.