At a glance

The key facts of the PPWR at a glance, checked on 15 October 2026.

ItemStatus
Legal basisRegulation (EU) 2025/40 of 19 December 2024 (PPWR)[1]
In force since11 February 2025[1]
Applies since12 August 2026, directly in all EU member states (Art. 71)[1]
ReplacesDirective 94/62/EC, repealed with effect from 12 August 2026; individual provisions continue to apply on a transitional basis (Art. 70)[1]
Key rolesManufacturer, supplier, importer, distributor, producer, authorised representative (Art. 3)[1]
Implementation in GermanyVerpackDG; LUCID register at the Central Agency Packaging Register (ZSVR)[3]
Official fees for LUCID registrationnone[13]
Consequences of infringements in GermanyAdministrative offences under § 66 VerpackDG; applicable to PPWR infringements from 12 February 2027[9][10]
Open proposalSuspension of the authorised representative obligation for EU businesses until 1 January 2035: not adopted[6]

What is the PPWR – and what does it not regulate?

PPWR stands for Packaging and Packaging Waste Regulation, in German EU-Verpackungsverordnung (EU Packaging Regulation). As a regulation, it applies directly in every member state, without transposition into national law (Art. 71)[1]. It replaces the Packaging Directive 94/62/EC, which each country had transposed differently[2].

What is new above all is that the requirements for the packaging itself are the same across the EU: substances, recyclability, recycled content, labelling and evidence. Many of them only take effect from 2028 or 2030[2]. According to the Austrian Ministry of the Environment, 18 implementing acts and 17 delegated acts of the Commission were still outstanding in June 2026[11]. They set out details, such as criteria for recyclability.

What the PPWR does not create: an EU-wide register, an EU-wide licence or uniform fees. Producers register in every member state in which they first make packaging available (Art. 44(2))[1]. The Commission has yet to set uniform formats for registration and reporting; member states then have 18 months to adapt their registers[5].

In Germany, the VerpackDG replaced the Verpackungsgesetz (German Packaging Act, VerpackG) on 12 August 2026[3]. It adds the national rules to the PPWR: registration in LUCID, participation in a dual system (compliance scheme), data reports, deposits and administrative offences. Our guide to the German Packaging Act and VerpackDG explains what has changed compared with the old law.

Who is affected? The role decides

The PPWR affects every business that manufactures, fills or imports packaging or trades in packaged goods. Which obligations apply depends on the role under Art. 3. A business can hold several roles at once[1].

  • **Manufacturer** (Art. 3(1), point 13): manufactures packaging or packaged products, or has them designed or manufactured under its own name or trademark. Example: a cosmetics label that has its cream filled by a contract filler. The manufacturer is responsible for conformity[1].
  • **Supplier** (point 16): supplies packaging or packaging material to a manufacturer, such as a cardboard box maker. It must hand the manufacturer all documents needed to demonstrate conformity (Art. 16)[1].
  • **Importer** (point 17): a business established in the EU that places packaging from a third country on the market. Goods from another EU country do not make anyone an importer[1][12].
  • **Distributor** (point 18): makes packaging available in the supply chain without being the manufacturer or importer, such as a retailer selling branded goods[1].
  • **Producer** (point 15): bears extended producer responsibility (EPR) in a specific member state, i.e. registration, reporting and financing of recycling. A producer can be a manufacturer, importer or distributor[1].
  • **Authorised representative for extended producer responsibility** (point 20): fulfils the producer obligations in a country on behalf of a producer that is not established there. This is distinct from the **authorised representative** under point 19, who takes over tasks of a manufacturer[1].

For Germany, the ZSVR sums up how the role is determined in two principles. Brand priority: whoever has goods manufactured under their own brand is manufacturer and producer. Domestic priority: the producer is the first business in the domestic supply chain; for deliveries from abroad directly to end users, it is the foreign business[3].

Your situationRole under the PPWRWhat follows
You have products made under your own brand and sell them in your country of establishmentManufacturer and producerProof of conformity plus registration in your country of establishment[1][3]
You buy branded goods from a supplier in the same country and resell them unchangedDistributorCheck that the producer is registered and the packaging is labelled (Art. 19)[1]
You import packaged goods from a third country, such as ChinaImporter, usually also producer in your own countryBefore placing them on the market, make sure the manufacturer has completed the conformity assessment and documentation (Art. 18)[1]
A Dutch webshop delivers directly to consumers in GermanyProducer in GermanyRegistration in LUCID, system participation, authorised representative in Germany[3][4]
An Austrian brand stores goods with a fulfilment service provider in Germany and delivers to German end usersManufacturer of the product packaging; producer in GermanyObligations in Germany; the fulfilment service provider must check your registration (Art. 45(7) and (8))[1][4]
You sell via an online marketplace directly to consumers in another EU countryProducer in the consumer's countryRegistration there; the marketplace asks for your registration and a self-certification (Art. 45(4))[1]
A Swiss business delivers directly to end users in the EUcan be the producer in the respective destination countryRegistration in the destination country; for third-country businesses, the member state decides whether an authorised representative is also needed; in Germany it is mandatory (§ 5 VerpackDG)[1][7]

A logo or imprint is an indication, not an automatic rule. What matters is whether the packaging or the product is designed or manufactured under your name or your brand[1]. Storage and shipping alone do not make a fulfilment service provider the producer of your product packaging. If it assembles the shipping packaging itself, it can be the manufacturer of that packaging[4]. If it unpacks goods, it can be the producer for the removed packaging (Art. 3(1), point 15(e))[1][12].

Does the PPWR also apply to micro-enterprises?

Yes. There is no general exemption based on company size. Micro-enterprises have fewer than ten employees and an annual turnover or balance sheet total of no more than EUR 2 million[4]. The PPWR provides certain relief for them[1]:

  • Manufacturer role: if a micro-enterprise has packaging made under its own brand, the supplier counts as the manufacturer under Art. 3(1), point 13(b), if it is established in the same member state. Art. 15(12) and Art. 21, by contrast, only require a supplier established in the Union[1].
  • Reuse targets: a micro-enterprise that makes no more than 1,000 kg of packaging available in a member state in a calendar year is exempt from the targets of Art. 29 (Art. 29(13))[1].
  • Reuse offer in hospitality: micro-enterprises are exempt from the obligation under Art. 33[1].

The relief on the manufacturer role is only certain if the supplier is established in the same member state. If a business supplies from another EU country, the legal position is open because of the differing wording. A supplier from a third country is not covered[1]. Registration, system participation and substance limits apply regardless of size.

What the PPWR regulates and from when

The requirements for packaging are set out in Articles 5 to 12 and apply in stages. Many later dates move back if the Commission adopts the necessary acts later. In that case, the later date applies[1].

AreaCore of the ruleFrom whenWhat you do now
Substances (Art. 5)Lead, cadmium, mercury and hexavalent chromium together no more than 100 mg/kg; PFAS limits for food-contact packaging: 25 ppb per PFAS, 250 ppb in total, 50 ppm total PFAS[1]since 12 August 2026[1]Request evidence from your supplier; for food contact, ask explicitly about PFAS
Conformity (Art. 15, 38, 39)Conformity assessment, technical documentation under Annex VII, EU declaration of conformity[1]since 12 August 2026[1]Draw up the documents for your own brands
Extended producer responsibility (Art. 44, 45)Registration per country, financing, authorised representative[1]since 12 August 2026; harmonised registers later[5]Check registrations per destination country
Labelling (Art. 12)Uniform label on material composition for waste sorting[1]from 12 August 2028 or 24 months after the implementing acts, whichever is later[1]Change print artwork only once the acts are available
Recyclability (Art. 6)Only recyclable packaging of performance grades A, B or C[1]from 1 January 2030 or 24 months after the delegated acts, whichever is later[1]Avoid composites and hard-to-separate materials in new developments
Recycled content (Art. 7)Minimum shares in plastic, e.g. 35 % for most non-contact-sensitive plastic packaging[1]from 1 January 2030 or three years after the implementing act, whichever is later[1]Ask suppliers about recycled-content options
Minimisation and empty space (Art. 10, 24)Reduce weight and volume to what is necessary; no more than 50 % empty space in grouped, transport and e-commerce packaging[1]from 1 January 2030; for empty space, three years after the implementing act at the latest, if that is later[1]Plan box sizes to match your product range
Format restrictions and reuse (Art. 25, 29)Ban on certain single-use formats under Annex V; reuse targets, e.g. 40 % for certain transport packaging[1]from 1 January 2030[1]Check whether your formats are listed in Annex V

Important for webshops: the reuse targets under Art. 29(1) to (3) do not apply to boxes made of paperboard or cardboard[1]. Nor does the empty-space limit under Art. 24(1) apply where the sales packaging also serves as shipping packaging; in that case the minimisation obligation under Art. 10 applies[1]. Until the new labelling rules take effect, the existing rules on material marking remain authoritative (Art. 70)[1][11].

Declaration of conformity and technical documentation

Since 12 August 2026, a manufacturer may only place packaging on the market that meets the requirements of Articles 5 to 12. Beforehand, it carries out the conformity assessment under Annex VII and draws up the technical documentation (Art. 15(2))[1]. Once conformity has been demonstrated, it issues an EU declaration of conformity. With it, the manufacturer takes responsibility for the packaging complying with the Regulation (Art. 39(4))[1].

  • Retention: documentation and declaration for five years for single-use packaging, ten years for reusable packaging (Art. 15(3))[1].
  • Information on the packaging: name or trademark, postal address and, where available, electronic contact details of the manufacturer, also via a QR code (Art. 15(6))[1].
  • Language in Germany: the signed declaration of conformity is kept in German or English, at your choice; at the authority's request, it must be translated (§ 62 VerpackDG)[8].
  • Supply chain: suppliers must hand the manufacturer the necessary information and documents (Art. 16). Importers keep a copy of the declaration available (Art. 18(7))[1].

An authorised representative appointed under Art. 17 can keep documents and cooperate with authorities. Drawing up the technical documentation, however, remains the manufacturer's task[1]. Our article PPWR declaration of conformity: who must draw it up shows which retailers need their own declaration.

Register, producer and authorised representative

Producers bear extended producer responsibility for packaging they first make available in a member state (Art. 45(1)). They may only make packaging available there once they or their authorised representative are entered in the register (Art. 44(4))[1]. In Germany, the register is LUCID; registration is free of charge[13]. The producer registers itself, even if it has an authorised representative[7][15]. Our guide to registration in the LUCID packaging register describes the process.

**Authorised representative for extended producer responsibility:** if you deliver directly to end users without an establishment in the destination country, you appoint an authorised representative there in writing. This follows from Art. 45(3) in conjunction with Art. 3(1), point 15(c) and (d)[1]. It applies to businesses from other EU countries and from third countries. Germany regulates the appointment in § 5 VerpackDG; the mandate must be granted in writing and in German[7][15].

**Status of the proposal:** on 10 December 2025, the Commission proposed suspending this obligation for producers established in the EU until 1 January 2035, COM(2025) 982. Parliament's Environment Committee voted on 5 October 2026; the provisional plenary date given is 19 October 2026[6]. The proposal has not been adopted; the obligation applies. For producers from third countries, such as Switzerland, nothing would change under the proposal[16]. Pending the decision, the Commission has called on member states to enforce the obligation pragmatically and to refrain from sanctions[5]. Our article EPR authorised representative: what drives the costs in each EU country explains how the costs of an authorised representative are made up in each country.

**Online platforms and fulfilment:** marketplaces obtain from producers their registration in the consumer's country and a self-certification (Art. 45(4))[1]. Fulfilment service providers check the same information when concluding the contract and suspend their services if the producer does not correct it (Art. 45(7) and (8))[1]. The Commission states that platforms must request the registration number as soon as the harmonised national registers are in place[5]. For Germany, the ZSVR states that platforms and fulfilment service providers must already check LUCID registration today[4].

Step by step: what businesses do now

The date of application has passed. The review therefore also covers packaging you already use.

  • **Determine the role per product and country:** own brand, import from a third country, resale or direct delivery abroad. Record in which countries you are the producer[1][3].
  • **Create a packaging list:** sales, grouped and shipping packaging with material, weight, supplier and destination country. You need this data for conformity, registration and reporting[4].
  • **Request supplier documents:** evidence on heavy metals and, for food contact, on PFAS. Suppliers are obliged to provide them (Art. 16)[1].
  • **Document as a manufacturer:** carry out the conformity assessment, draw up the technical documentation and the EU declaration of conformity, and keep them for five or ten years respectively[1].
  • **Register and participate as a producer:** in every country where you are the producer. In Germany: LUCID, system participation, data report and, where applicable, an authorised representative[3][7].
  • **Plan for 2028 and 2030:** when reordering printed materials and cardboard packaging, take labelling, recyclability, recycled content and empty space into account[1].

No fees are charged for registration in LUCID[13]. The other steps involve internal effort and, where applicable, costs for testing or an authorised representative.

Deadlines and timeline 2025 to 2040

The table separates fixed dates from dates that depend on the adoption of further acts, and from the open proposal.

DateWhat appliesStatus
11 February 2025PPWR entered into force[1]adopted
12 August 2026Date of application: roles, substance and PFAS limits, conformity, producer responsibility, authorised representative[1]applies
12 February 2027Member states must have adopted rules on penalties (Art. 68); in Germany, PPWR infringements can be prosecuted as administrative offences from then on[1][10]adopted
12 February 2028Food service businesses selling takeaway food and beverages must offer a reuse option (Art. 33)[1]adopted
12 August 2028Harmonised label on material composition (Art. 12(1))[1]at the earliest; depends on implementing acts
1 January 2029Member states ensure 90 % separate collection of single-use plastic beverage bottles and metal beverage containers up to 3 litres, in principle through deposit and return systems (Art. 50)[1]adopted
1 January 2030Recyclability grades A to C, recycled content, minimisation, 50 % empty space, format bans under Annex V, reuse targets[1]partly depends on acts
1 January 2035Recyclability also "at scale" (Art. 6)[1]depends on implementing acts
1 January 2035End of the proposed suspension of the authorised representative obligation for EU businesses[6]proposal, not adopted
1 January 2038Only recyclability grades A or B (Art. 6)[1]adopted
1 January 2040Higher recycled content, e.g. 65 % for single-use plastic beverage bottles (Art. 7(2))[1]adopted

Costs and consequences of infringements

The PPWR does not set fee levels. Costs arise nationally and within your business.

  • **Registration:** registers may charge cost-based fees (Art. 44(11)(d))[1]. In Germany, LUCID registration is free of charge[13].
  • **System participation:** the fees are set by the national schemes, in Germany by the dual systems. Our guide to the packaging licence explains what participation costs.
  • **Eco-modulation:** the PPWR requires contributions to be graduated by recyclability in future; this takes effect 18 months after the acts on recyclability (Art. 6(8))[1]. How large the graduation will be has not yet been determined.
  • **Authorised representative:** appointing an authorised representative involves costs; you agree the amount with the authorised representative[15].
  • **Relief:** for small producers – the Commission cites less than 10 tonnes per year – member states can waive registration fees and provide for flat-rate fees[5]. Whether a country does so must be checked there.

**Consequences of infringements:** the manufacturer may not place non-compliant packaging on the market (Art. 15(1)), and distributors do not make it available (Art. 19(3))[1]. A producer without registration may not make packaging available in the country concerned (Art. 44(4))[1]. Each member state sets its own penalties by 12 February 2027 (Art. 68)[1]. In Germany, infringements of the PPWR are administrative offences under § 66(2) VerpackDG; the provision applies from 12 February 2027 (§ 68(17))[9][10]. Missing registration or system participation have already been administrative offences under § 66(1) VerpackDG since 12 August 2026[9][10].

Common mistakes

  • **"The PPWR replaces the licence in every country."** Registration and participation remain national. Check each destination country separately[1].
  • **Confusing manufacturer and producer.** The manufacturer is liable for conformity; the producer pays in the country where the waste arises. Determine both roles separately[3].
  • **Reading "importer" too broadly.** Goods from another EU country do not make you an importer, but they may make you a producer[1][12].
  • **Waiting for the Commission proposal.** The authorised representative obligation applies as long as the proposal has not been adopted[6].
  • **Treating the shipping box as uncritical.** Whoever assembles cardboard, tape and filling material into shipping packaging is, in the ZSVR's view, manufacturer and producer[4].
  • **Changing labels in advance.** The harmonised label will only be fixed with the implementing acts[1].

For businesses from the Netherlands, Austria and Switzerland

Country of establishment, destination country and role must be checked separately. Deliveries to Germany are subject to the German obligations, regardless of where you are established[4].

**Netherlands:** the PPWR applies directly. Since 12 August 2026, Verpact has used the PPWR definition of producer to determine who reports in the Netherlands; for most packaging, a reporting threshold of 50,000 kg applies[12]. This reporting covers packaging first made available in the Netherlands[12]. If a Dutch webshop delivers directly to end users in Germany, it is the producer there and needs an authorised representative[4][7].

**Austria:** the PPWR applies directly. According to the Ministry of the Environment's information sheet of 10 June 2026, the participation obligation of primary obligated parties under § 13g AWG 2002 (Austrian Waste Management Act) remains unchanged for the time being. Adjustments are to follow with a planned amendment to the AWG; the EDM system will be adapted from 2028 at the earliest[11]. Foreign mail-order sellers have needed an authorised representative in Austria since 1 January 2023 (§ 16b Verpackungsverordnung 2014, the Austrian Packaging Ordinance)[14]. More on this in our guide to the EDM portal.

**Switzerland:** the PPWR does not apply in Switzerland. Swiss businesses that deliver directly to end users in the EU can be the producer in the respective destination country. For third-country businesses, whether an EPR authorised representative must also be appointed depends on the rules of the respective member state; in Germany this obligation exists[1][7]. The suspension proposal would not change this[16]. Our article EPR obligations in other EU countries and our guide to extended producer responsibility (EPR) give an overview of obligations in several countries.

For PPWR questions about your own brand, imports or supply chains across several countries, we clarify your set-up in a personal conversation.

Status and changes

As of 16 October 2026. We checked the Official Journal text of Regulation (EU) 2025/40 and the VerpackDG on gesetze-im-internet.de. We also checked the pages of the ZSVR, the European Commission and the BMUKN (German Federal Environment Ministry), the Austrian PPWR information sheet and Verpact. We checked the status of COM(2025) 982 in Parliament's Legislative Observatory. We update this page when the proposal on the authorised representative obligation has been decided or the Commission adopts the acts on labelling, register and recyclability. Changes: 15 October 2026, first version; 16 October 2026, technical clarifications after expert review (authorised representative for businesses from Switzerland). Translated from the German version of 16 October 2026.

Frequently asked questions

Where can I find the PPWR legal text in English?
You can find the official text of Regulation (EU) 2025/40 in every EU language, including English and German, on EUR-Lex, the EU's legal portal, under the number 2025/40. The version published in the Official Journal is binding. The German implementing rules are in the VerpackDG on gesetze-im-internet.de. Further aids to interpretation are the European Commission's guidelines and FAQ, which are not legal norms.
Does the German Packaging Act (Verpackungsgesetz) still apply?
No. The German Packaging Act applied until 11 August 2026. Since 12 August 2026, the PPWR and the Packaging Law Implementation Act (VerpackDG) apply in Germany. Registration in LUCID, system participation and data reporting continue; who is obliged, however, is now determined by the PPWR roles.
As a small online shop using neutral standard boxes, am I a manufacturer?
That depends on what you do with the boxes. If you assemble cardboard, tape and filling material into shipping packaging yourself, the ZSVR considers you manufacturer and producer. If you buy complete shipping packaging without your brand from a domestic supplier and do not alter it, that supplier is responsible for the producer obligations.
Do I have to register in every EU country I deliver to?
Yes, in every country where you are the producer. That is usually the case if you deliver directly to end users there. If you sell to a retailer in the destination country who is the first to make the goods available there, that retailer is usually the producer. Check this per country and sales channel.
Does the declaration of conformity have to be in German?
Not necessarily for Germany. Under the VerpackDG, the signed declaration can be kept in German or English. If the competent authority requests a German version, you must translate it. For other countries, the language prescribed by the respective member state applies.
Will the PPWR make licence fees more expensive?
That cannot be quantified today. The PPWR requires contributions to be graduated by recyclability in future, and Germany has announced regulations for this. How much easily recyclable packaging will be relieved and poorly recyclable packaging burdened has not yet been determined.

Sources

  1. [1]Verordnung (EU) 2025/40 über Verpackungen und Verpackungsabfälle (PPWR), Amtsblatt-Fassung (accessed 15 Oct 2026)
  2. [2]BMUKN: Europäisches Recht über Verpackungen und Verpackungsabfälle, Stand 26.06.2026 (accessed 15 Oct 2026)
  3. [3]ZSVR: PPWR und VerpackDG – das gilt seit dem 12. August 2026 (accessed 15 Oct 2026)
  4. [4]ZSVR: Versand- und Onlinehandel – was ändert sich durch die PPWR? (accessed 15 Oct 2026)
  5. [5]Europäische Kommission: Extended Producer Responsibility – guide for Small Businesses under the PPWR (accessed 15 Oct 2026)
  6. [6]Europäisches Parlament, Legislative Observatory: Verfahren 2025/0395(COD), COM(2025) 982 (accessed 15 Oct 2026)
  7. [7]§ 5 VerpackDG – Beauftragung Dritter und Bevollmächtigung (accessed 15 Oct 2026)
  8. [8]§ 62 VerpackDG – Sprache der EU-Konformitätserklärungen (accessed 15 Oct 2026)
  9. [9]§ 66 VerpackDG – Bußgeldvorschriften (accessed 15 Oct 2026)
  10. [10]§ 68 VerpackDG – Übergangsvorschriften (accessed 15 Oct 2026)
  11. [11]BMLUK: Merkblatt zur EU-Verpackungsverordnung, 10.06.2026 (accessed 15 Oct 2026)
  12. [12]Verpact: Jouw verpakkingen – producent onder de PPWR en drempelwaarden (accessed 15 Oct 2026)
  13. [13]ZSVR: So registrieren Sie sich im Verpackungsregister LUCID (accessed 15 Oct 2026)
  14. [14]RIS: Verpackungsverordnung 2014, § 16b Bevollmächtigter für ausländische Versandhändler (accessed 15 Oct 2026)
  15. [15]ZSVR: Alles auf einen Blick – die Bevollmächtigung (accessed 15 Oct 2026)
  16. [16]Europäisches Parlament, Legislative Observatory: Zusammenfassung des Vorschlags COM(2025) 982 (accessed 15 Oct 2026)