PPWR after the initial shock: What is really urgent now

In a nutshell: The EU Packaging and Packaging Waste Regulation PPWR has applied since 12 August 2026, and the initial panic is over. Now reality sets in: the PPWR is not a one-off rush effort but will accompany companies for years. It applies from the very first carton, for B2B and B2C alike, regardless of company size. In the Webinar, Max Haschke explains why clean data and clearly defined roles in the supply chain are now more important than actionism. He shows who within the company should drive the topic, and why the greatest pressure currently comes not from regulatory authorities but from companies' own customers.

Around 50 days after the launch: Where do companies stand, and who is affected by the PPWR?

Max: It has not turned out quite as bad as I feared. The world keeps turning, and most companies are gradually finding their role. But now reality is hitting hard: the PPWR was not a one-off rush effort in the summer of 2026. It will stay with us for years. The first milestone on 12 August was about taking stock of your own data and organisation. On top of that came the first hard requirements, such as producer labelling and proof regarding heavy metals and, in the case of food contact, PFAS.

Everyone is affected. There is no longer any distinction between B2B and B2C packaging, and there are no de minimis thresholds. You are in from the very first carton and the very first pallet, regardless of the size of your company. That also applies to the start-up selling jam from a garage.

What is the most important step right now?

Max: Cleaning up the data, and doing so through communication rather than pressure. At the moment there is a great deal of chaos: customers are requesting all packaging data from suppliers, in their own Excel formats or SaaS platforms, sometimes even parameters that will not become relevant until 2030. There is no uniform standard, and that is causing a lot of frustration. The twentieth follow-up email saying "Otherwise we will delist you" does not work.

You need to sit down at a round table and clarify roles first. Those roles can even change depending on the product and the supply chain. In principle, I need to look at every single shipment: What route does it take, and who has influence over the packaging design? Only then do I know what information I need from whom, when, and in what format.

Who takes care of this within the company?

Max: Until now, it has usually been someone from warehousing, logistics or supply chain management, supported by procurement. Packaging was a C-item that was supposed to run itself and cost nothing. That is changing: packaging is becoming an integral part of the product. PPWR enquiries are suddenly landing in customer service or sales and need to be passed on internally to IT, master data management and procurement. If these functions do not work together cleanly, enquiries get lost in an inbox loop. Those who communicate proactively, on the other hand, can even gain a competitive advantage.

Questions from the chat

Participants asked many questions in the chat, which Max answered live. We have summarised the most important ones here.

Note: The answers are based on Max's professional expertise and experience and do not constitute legal advice. For specific individual cases, he recommends seeking individual counsel with legal backing.

I exclusively reuse second-hand shipping cartons. Does that mean I am exempt?

Max: The overarching goals of the PPWR are packaging reduction and waste minimisation. Reusing cartons is a commendable thing to do. The problem is traceability along the supply chain. What matters is when the packaging was first placed on the market. If the cartons were already in circulation within the European Economic Area in a packaged state, there is a Solution that allows you to step out of the responsibility. You record that once in your own documentation. If, on the other hand, the cartons come from containerised goods from Asia, you may already be under an obligation as an importer. That has to be assessed case by case, and there will certainly be further clarifications from the European Commission. In any case, you must document.

As an end consumer, I see no changes on my parcels. Have I misunderstood something?

Max: That depends on the role you have in the setup. Producer labelling has applied since 12 August. Anyone subject to the producer obligation must print certain information on the packaging. For cartons that were already in stock before 12 August and placed on the market, there was a kind of transitional protection. In those cases, the labelling can still be handled via accompanying documents such as the delivery note. Everything newly placed on the market requires a unique identifier, i.e. a clear material identification: Which corrugated box, which film, which edge protection is this? In addition, producer labelling is required, including name, address and a digital point of contact. in the simplest case, an email address.

Anyone ordering standard cartons without their own branding from an online retailer is generally not the producer but the retailer. In that case, I review the cartons and document this internally in a conformity assessment procedure. So please take a step back before revising print artwork, and clarify carefully for each setup when you are in the producer role. The classic fulfiller role does not trigger the producer role. You only need to ensure that you do not degrade the packaging. Anyone who does not repackage or re-pick is in the clear.

We have many shipping cartons custom-made. Does that make us the producer?

Max: If you definitively specify what the packaging should look like, i.e. the dimensions, design or closure of the corrugated box, then I would classically see you in the producer role.

Does the PPWR also apply to inner packaging, for example plastic bags for small parts?

Max: Yes. Think carefully about everything attached to a pallet or a small parcel. From the label to the printing ink to the adhesive holding the label to the carton: every component that ultimately goes to market is part of the packaging. Exceptions exist only in certain areas, for instance regarding reuse quotas.

What is the situation for pharmaceutical products, and how is the fill level calculated?

Max: The fill level calculation is coming later. Focus on what has applied since 12 August. For pharma and medtech, exceptions already exist. Packaging sizes there are often prescribed, there are already many mandatory labelling requirements and little space. Labelling can then also be handled via accompanying documents. The specific exceptions are well described in the legislative text.

What will the sustainability calculation look like, and what data is needed for it?

Max: That is still being worked on, as are the minimum standards for the recycling calculation. Many companies therefore say: We cannot do anything yet. And you do not have to yet. Use the time instead to improve your packaging portfolio and reduce costs, so that the PPWR measures also make financial sense. The key point is: a clean data foundation is the prerequisite for being able to get started later.

Many pouch packaging products come from China. Will the PPWR reverse that?

Max: Anyone who places pre-packaged goods from a third country on the EU market for the first time is obliged as an importer to ensure PPWR compliance. Whether you can obtain the necessary information, such as a declaration of conformity or technical documentation, is a different question. Within the 27 EU member states, suppliers are obliged to provide the information upon request. For suppliers from the USA, Taiwan or China, you have no official entitlement to it, unless it is stipulated in your contracts, which very few companies have done so far. Otherwise, you are left relying on the goodwill of the supplier. But you must still verify.