News

Since 12 August 2026, Regulation (EU) 2025/40 on packaging and packaging waste (the “Packaging and Packaging Waste Regulation” – PPWR) has been directly applicable in all Member States of the European Union.

The new Regulation comprehensively revises the requirements for packaging and the placing of packaging on the EU market. Its objectives include reducing packaging waste, strengthening the circular economy and establishing more harmonised requirements for economic operators throughout the European Union.

 

The Regulation generally affects companies that place packaging or packaged goods on the market. Depending on the individual supply and distribution structure, companies may, in particular, be considered manufacturers, importers, distributors or producers within the framework of extended producer responsibility.

 

This may be particularly relevant for companies that:

 

– import goods from third countries into the European Union,

– make packaged goods available on the market for the first time in an EU Member State,

– market products under their own name or trademark,

– manufacture or use packaging, or

– distribute goods across different EU Member States.

 

Depending on the respective role of the company and the type of packaging concerned, the PPWR may entail a range of obligations. These may include, for example, requirements relating to packaging compliance, technical documentation, labelling, registration under extended producer responsibility schemes, as well as further information (disposal) and record-keeping obligations.

 

Particularly in the context of international trade, we therefore recommend that you review at an early stage which role your company assumes within the respective supply chain and which obligations may arise from this role. Especially where goods are imported from third countries, a careful assessment of the responsibilities of manufacturers, importers and other economic operators involved may be required.

 

Please note that the specific legal classification will always depend on the individual business and supply structure as well as on the nature of the packaging concerned.

 

With this information, we would like to draw your attention to the new legal framework at an early stage and encourage you to review your internal processes accordingly. Where necessary, we recommend seeking qualified legal or specialist advice.