New EU packaging rules (PPWR): from classification to conformity

The Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40) applies from 12 August 2026, replacing the old Packaging Directive with a single set of rules that apply directly in every member state. Its general application date is 12 August 2026, but many of its heavier duties phase in later, running out to 2038. It reaches almost everyone who puts a packaged product on the EU market: producers, manufacturers, importers and distributors all take on obligations, and packaging that does not comply cannot be placed on the market.

This session is moderated by Anthony Buckley. Speakers: Prof Hans-Michael Wolffgang, Partner at AWB Tax GmbH and Janina Bary, Associate at AWB Law GmbH.

Topics covered include:

• how PPWR replaces the old Packaging Directive, and why a directly applicable regulation changes things for business;
• the scope of "packaging", and why one item can fall into several categories at once;
• packaging categories: sales, grouped, transport and e-commerce;
• the staged timeline, from entry into force in 2025 to the recyclability, recycled-content and reuse milestones running to 2038;
• sustainability requirements: recyclability, minimum recycled content, substance restrictions and the ban on "perceived volume" tricks such as false bottoms;
• minimisation, empty-space limits and the prohibited formats under Annex V;
• reuse, refill and takeaway obligations, with their 2027 to 2040 targets;
• the economic operators and who is responsible for what: producers, manufacturers, importers, distributors, suppliers and fulfilment service providers;
• when an importer or distributor is treated as a manufacturer, and the micro-enterprise exception that can leave the supplier responsible instead;
• conformity assessment, the EU declaration of conformity and the technical documentation kept on file for audit.