European law on packaging and packaging waste

On 11 February 2025, Regulation (EU) 2025/40 on packaging and packaging waste (also referred to as the Packaging Regulation or PPWR) entered into force. It takes effect from 12 August 2026.

The Regulation introduces a number of new requirements that were not in the EU Packaging Directive (see below). The new provisions apply directly to economic operators. For example, from 12 August 2026, food-contact packaging with a PFAS concentration above specified limit values may no longer be placed on the market. From this date, various new definitions also take effect and must be observed by those applying the law in the Member States. Other requirements will be applicable from a later date. For example, in future packaging must be recyclable and plastic packaging must contain a specified percentage of recycled content. From 2030, the EU Packaging Regulation also envisages mandatory re-use targets in various sectors, for example beverage containers. It also requires Member States to reduce their generation of packaging waste. All Member States must reduce their packaging waste per capita by 5 percent by 2030 and by 15 percent by 2040 compared to 2018.

To align national packaging law with the EU Packaging Regulation, the Federal Environment Ministry drafted a packaging law implementation act. This act will also enter into force on 12 August 2026.

The website of the central packaging register ZSVR (Zentrale Stelle Verpackungsregister) provides information on important changes arising from the new provisions of the EU Packaging Regulation. Those placing packaging on the market must comply with these new rules from 12 August 2026. This is particularly relevant for determining who is considered a manufacturer and producer of packaging in future, for example in the case of retailers’ own brands.

In addition, an EU Commission guidance document and FAQs give tips on applying and interpreting various provisions of the EU Packaging Regulation.

The Directive on packaging and packaging waste (EU Packaging Directive) was adopted by the European Parliament and Council in 1994. Its goal is to harmonise the diverse national measures in the Member States concerning the management of packaging and packaging waste, and to provide a high level of environmental protection. The Packaging Directive has since undergone a number of revisions. For example, recovery targets were raised to improve the recycling of packaging waste in Europe. It also gives the Member States options for reducing the use of lightweight plastic carrier bags. On the basis of this amendment, Germany imposed a ban on placing certain types of plastic carrier bags on the market.

One key element of the Packaging Directive is extended producer responsibility. As packaging generally has a short lifetime and quickly becomes waste, producers of packaging are responsible for the collection and disposal of packaging waste and must bear the associated costs. From 12 August 2026, most of the EU Packaging Directive will be repealed and replaced by the EU Packaging and Packaging Waste Regulation. Core provisions and instruments of the Directive, such as extended producer responsibility, will be taken on and further developed in the Regulation.