The New EU Packaging Regulation: What Really Matters from August 2026

Regulation (EU) 2025/40 – PPWR for short, the Packaging and Packaging Waste Regulation – was adopted by Parliament and Council at the end of 2024, published in the EU Official Journal on 22 January 2025, and entered into force 20 days later, on 11 February 2025. Unlike the previous Packaging Directive, the PPWR is a regulation – meaning it doesn't first have to be transposed into national law, but applies directly and uniformly across all 27 member states. Until it fully takes effect, Germany's existing Packaging Act (Verpackungsgesetz) remains the relevant law for now.

What it's about in substance can be summed up simply: less packaging waste, better recyclability, and more genuine circular economy instead of just on paper.

The key date

After an 18-month transition period, the regulation becomes applicable in large part on 12 August 2026. That doesn't mean the matter is settled, though – some requirements run until 2028, others until 2030, 2035 or even 2040. So the PPWR isn't arriving all at once, but in several waves.

One practical point here: for existing packaging stock, what generally counts is the point at which it was placed on the market – not the later delivery date. Anyone still holding larger quantities in storage should take a closer look at this distinction.

Who does this actually affect?

The regulation clearly distinguishes between different roles: producers, suppliers, importers, distributors, final distributors – and fulfillment providers too. In principle, the PPWR applies regardless of company size; there's no general de minimis threshold. For micro-enterprises – fewer than ten employees, annual turnover or balance sheet total under two million euros, sourcing packaging from the same EU member state – there is, however, a special rule for role allocation: here, the packaging manufacturer remains the producer, rather than that obligation passing to the micro-enterprise. This doesn't exempt them from the registration requirement as such, though.

That makes sense when you look at where many of the relevant decisions are actually made: in the choice of box, the amount of filling material, the packaging itself – in other words, exactly where goods are picked and made ready for shipping. For retailers, this means one thing above all: it's worth talking to your logistics partner early on, rather than scrambling just before the deadline.

Who is the manufacturer, who is the producer – and what does LUCID have to do with it?

Besides the basic question of which role applies, a very practical question arises for most businesses: registration in the LUCID packaging register. This affects not only companies that manufacture packaging, but in principle everyone who uses it commercially and places it on the market – even purely transport or reusable packaging such as pallets isn't automatically exempt.

How much effort this involves depends on which role you take on. Anyone who simply buys packaging neutrally, without their own logo or brand, generally remains responsible for registration, while the packaging manufacturer is responsible for the technical details. But as soon as your own branding appears on the packaging – for example your own logo on the shipping box – or the packaging is sourced from abroad, you slip into the manufacturer role yourself and take on additional documentation obligations, for instance regarding materials or quantities. Especially for online retailers with their own branding on shipping packaging, it's worth taking a close look at where the boxes actually come from and who is officially considered the manufacturer.

The Central Packaging Register Agency (Zentrale Stelle Verpackungsregister, ZSVR) now provides practical examples and decision-making aids on this – a good starting point if your own situation isn't clear at first glance.

What's changing in substance

One point that's directly noticeable in e-commerce: shipping packaging may in future only contain a limited amount of empty space – according to the regulation, no more than 50 percent relative to the actual product volume. That spells the end for the oversized box full of air and filling material.

When it comes to material choice, recyclability becomes mandatory rather than optional: from 2030, packaging must consist of at least 70 percent recyclable materials, with later stages from 2035 and 2038 tightening this further. For certain plastic packaging – such as stretch film or strapping tape in logistics – minimum recycled content requirements will also apply from 2030.

Anyone who manufactures or uses packaging with food contact must also prepare for stricter limits on PFAS and certain heavy metals, which already apply from August 2026. A uniform, EU-wide labelling system for material composition – partly digital, via QR codes – won't arrive until later, at the earliest from 2028.

And finally: for certain packaging, especially that used commercially, the regulation will in future provide for binding reusable packaging quotas, supplemented by a ban on certain single-use packaging formats from 2030 – for example portion packaging in the hospitality sector.

What makes sense to do now

The starting point is usually an honest stock-take: which materials and formats are currently in use, and where are the sticking points with recyclability or material separation? After that, it's worth looking at your own role in the supply chain – this is where the specific obligations arise from. Anyone with packaging suppliers should involve them early, especially when it comes to labelling and material composition. And for existing stock, the rule is: better to plan realistically than to be forced into a short-notice changeover.

"The PPWR doesn't just affect manufacturers and brand owners – it explicitly affects us as a fulfillment provider too. For our customers, that means: anyone who engages with the new requirements now can adapt their packaging processes early, instead of acting under time pressure later. We see this as an opportunity to develop more efficient, future-proof solutions together with our customers."

Raimund Bergler, Managing Director of bergler industrieservices GmbH

And what does this mean for our customers?

We at bergler are part of this supply chain ourselves and are accordingly already working on the new requirements now – from material selection to the empty-space ratio in shipping packaging. If you'd like to know what the PPWR specifically means for your packaging and shipping processes, feel free to get in touch.