Packaging and Packaging Waste Regulation(PPWR): Roles, Responsibilities, Deadlines

Regulation (EU) 2025/40 on packaging and packaging waste has replaced the Packaging Directive 94/62/EC and has been directly applicable in all Member States since August 12, 2026. In Germany, it is supplemented by the German Packaging Law Implementation Act (VerpackDG), which was published in the Federal Law Gazette on July 17, 2026.

For companies, this means a shift in the regulatory framework: Packaging is no longer treated solely under waste management laws, but as a product. There is a conformity assessment, an EU declaration of conformity, technical documentation, and labeling requirements—with one economic operator responsible for all of these. 

The crucial question comes at the beginning and is often asked too late: In what capacity are you involved? The PPWR distinguishes between producers, manufacturers, suppliers, importers, and distributors—and these roles do not correspond exactly to their colloquial meanings. If you misidentify your role, you may fulfill the obligations of one while overlooking those of another.

To complicate matters further, the roles must be determined for each packaging product line, not for each company. The same company may be a manufacturer of folding cartons and merely a purchaser of pallet wrap.

If this classification is not clarified, the following risks may arise:

• Fines of up to 200,000 euros under the Packaging Act (VerpackDG)
• Distribution barriers because distributors are not allowed to provide packaging if the manufacturer is not properly registered
• Additional claims and disputes in the supply chain if compliance documentation is missing
• Recall and withdrawal orders issued by market surveillance authorities in cases of ongoing nonconformity
• Failure to provide evidence to customers who, in turn, request documentation of conformity

The PPWR requires companies to do something that is new in packaging law: establish a robust allocation of responsibilities and maintain documentation that can withstand regulatory scrutiny. To this end, we use structured tools—role matrices for each product line, verification tools for declarations of conformity, and template clauses for supply contracts.

The PPWR does not provide any sector-specific exemptions for individual industries. This applies not only to packaging manufacturers but to any company that places packaged products on the market for the first time in a member state—even if it merely purchases the packaging and fills it.

Does this sound familiar? 
Then let’s start by clarifying the role—it determines everything else. To do this, we use a role matrix for each packaging product line and use it to define the specific scope of responsibilities.