The new Packaging and Waste Regulation (PPWR): What to expect
More sustainability, more responsibility – and a host of new obligations: The EU Packaging and Packaging Waste Regulation (PPWR) comes into effect in August 2026. Here’s what retailers need to know. (Ad)
The new EU Packaging and Packaging Waste Regulation, or PPWR for short, introduces a range of new requirements for retailers, manufacturers, and fulfilment service providers. We’ve compiled the most important questions retailers are currently asking.
Who counts as a producer?
The PPWR defines a producer in Article 3, paragraph 1, item 13 as any person who manufactures or has manufactured a packaging or packaged product under their own name or trademark. What matters is not who physically produces the packaging, but whose name or brand appears on it.
For retailers, this means in practice:
- Custom shipping packaging with your own logo: Anyone ordering boxes printed with their own company branding is considered a producer.
- Own-brand products: Anyone selling and packaging goods under their own brand is the producer of that product packaging.
- Standard shipping boxes from a German supplier: There is an important relief here. Anyone buying unbranded standard boxes from a German supplier and shipping exclusively within Germany will in many cases no longer be considered a producer – responsibility then lies with the packaging supplier.
Exception for micro-enterprises: Anyone with fewer than 10 employees and an annual turnover below two million euros is not considered a producer – provided the packaging manufacturer is based in the same EU member state.
What obligations do producers have?
Producers may only place packaging on the market that meets the requirements of the PPWR. From August 12, 2026, this includes:
- Labelling the packaging with name, trademark, postal address, and electronic contact details (a QR code is permitted as an alternative)
- A unique identity marking (e.g. batch or serial number)
- An EU declaration of conformity referencing technical documentation and applicable standards
The obligation to include an identity marking follows from Article 15 of Regulation (EU) 2025/40: if direct labelling is not possible due to the size or nature of the packaging, the information may instead be provided in accompanying documents – such as the delivery note.
Does the labelling requirement also apply to tape and bubble wrap?
According to the strict wording of the regulation: yes. Adhesive tape, bubble wrap, and similar packaging materials are also considered packaging and must be licensed. In practice, however, this does not mean that every individual piece of tape needs to carry a label – realistically, the actual manufacturer will apply this marking once.
Whether retailers who are themselves considered producers can apply a single collective label to the packaging as a whole remains a matter of interpretation. The enforcement legislations that member states are supposed to pass by August may provide further clarity.
What applies to used packaging?
Many retailers use shoe boxes, moving boxes, or other second-hand materials to ship orders – a resource-conscious approach that would seem to align with the spirit of the regulation. Legally, however, it is more complicated. The key question is: has this packaging already been licensed once?
Retailers have previously been advised to license used packaging themselves as a precaution, since proving prior licensing is nearly impossible in practice. Who can demonstrate that a particular shoe box was actually registered with any registered dual system provider? Without such proof, the retailer risks being treated as the first person placing the packaging on the market – with all the consequences that entails: LUCID registration, system participation, and from August 2026 also the obligation to carry out a conformity assessment and issue an EU declaration of conformity.
Used packaging can therefore still be used – but in most cases, retailers will need to fulfil all producer obligations themselves.
EU-wide shipping: authorised representatives for every member state
Anyone selling goods across the EU will need a separate authorised representative for each member state. Finding suitable service providers is time-consuming, and the options available are often expensive and hard to come by.
For retailers shipping across the EU, this represents yet another bureaucratic hurdle. Händlerbund is offering a complete solution in cooperation with Interzero: shipping volumes and country-specific requirements are assessed, and an appropriate authorised representative is appointed for each country. Further information and registration are available directly at Händlerbund.
Author: Hanna Hillnhütter – Hanna keeps an eye on legal developments, focusing on warnings, competition law and current EU regulations.. Find more of her writing on OnlinehaendlerNews.This article is a blend of several articles published in German on OnlinehaendlerNews between April and May 2026.
