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PPWR explained simply – the new EU Packaging Regulation

by Birgit Kraus & Marcus Mayr

The new regulation will already come into force on 12 August 2026....

What the new EU Packaging Regulation means – and how we at Ströbel are preparing

The new EU packaging regulation, PPWR (Packaging and Packaging Waste Regulation), will change the packaging industry over the coming years.
Many companies are currently asking similar questions:

  • What exactly is the PPWR?
  • Who does it affect?
  • From when will it apply?
  • And what does that mean in concrete terms for our day-to-day business?

As a supplier of packaging solutions within the meaning of the PPWR, Ströbel is actively addressing these topics. In this article, we provide an overview of the PPWR, explain the key roles along the supply chain—and show how we are aligning our internal processes to make relevant information available.
Note: The measures described are for general information purposes and relate to our internal processes. They are not an assessment, approval, or legal advice for specific products or customer applications and do not replace an individual legal review by the party placing the product on the market.

What is the PPWR?

The PPWR (Packaging and Packaging Waste Regulation) is the new EU packaging regulation “Regulation (EU) 2025/40”, which replaces the previous directive. It applies uniformly and directly in all EU Member States and aims to reduce packaging waste, strengthen recycling, and promote the circular economy.

The focus is on:

  • reducing packaging waste
  • improving recyclability
  • using recycled materials
  • clear labelling and information obligations

In short: packaging is expected to become more resource-efficient, more recycling-friendly, and more transparent.

Which packaging does the PPWR cover?

The PPWR applies to nearly all packaging placed on the market in the EU—regardless of the material (plastic, paper, composites, etc.).

Ströbel products that are excluded include, for example:

  • desiccants
  • transport monitoring
  • humidity indicator cards / indicator strips
  • rust removers
    These product groups are currently not covered by the regulation.

 

When is a product considered packaging under the PPWR?


Packaging is an item that “can be categorised by packaging type on the basis of its function, material and design”. Material and design are therefore key criteria for its mandatory classification into the relevant packaging type.

A product is considered packaging if it serves to:

  • protect another product,
  • hold it together,
  • enable transport or sale, or
  • present the product at the point of sale.

Important: material or reusability do not matter—what matters is the purpose alone.

Which roles exist under the PPWR—and why does it matter?

Why roles matter

The PPWR clearly defines who is responsible for which obligations in the packaging process—and these do not necessarily align with a company’s title or function. From a compliance perspective, it is crucial to understand your role correctly, because it determines who must provide which data, prepare which documents, and fulfil which obligations.

Key roles at a glance

1) Supplier
A supplier produces packaging elements or components and supplies them to a producer or manufacturer.

Typical tasks:

  • providing material and recycling data
  • sharing information along the supply chain

2) Manufacturer
A "manufacturer" manufactures packaging or has it manufactured, or assembles packaging elements into a packaging unit. By filling the packaging, they give it its final form. According to the PPWR classification system, this generally applies only to sales and outer packaging. In the case of transport packaging (as well as service and primary production packaging), the producer of the empty packaging is already considered the manufacturer, provided that dimensionally stable packaging formats such as crates or pallets already take on their final form when empty. Only in the case of flexible formats (e.g. pallet wraps, bags) is the filler/user the manufacturer.

Tasks:

  • ensuring the packaging meets the requirements
  • passing relevant product data to the manufacturer
  • preparing the declaration of conformity

3) Producer
The manufacturer places the finished packaging or the packaged product on the market for the first time. The ‘producer’ within the meaning of the PPWR is a role derived from waste legislation under the Extended Producer Responsibility (EPR) scheme. Their obligations include registration, reporting quantities and paying EPR fees (Articles 44–47 of the PPWR). The producer does not issue a declaration of conformity.

Tasks:

  • registration
  • where applicable, paying extended producer responsibility (EPR) fees

👉 Many companies can hold several roles at the same time. Each role comes with its own obligations and must be clearly distinguished under the PPWR.

 

When does the PPWR apply? – Understanding the timeline

The PPWR will be introduced gradually and further developed through 2030.
12 August 2026 – Application of the regulation begins (first binding requirements).
Initially, this is not about comprehensive requirements such as recyclability, but about clearly defined individual points.
At Ströbel, the focus is on flexible packaging - in particular:

  • the confirmation of compliance with heavy metal limit values in accordance with the PPWR
  • and – for food packaging – compliance with PFAS limit values

These requirements form the basis for the first declarations of conformity by the respective responsible market participants. Important: Comprehensive requirements such as recyclability will only apply at a later date (from 2030).

This means:
At the start of the regulation, the main focus is on being able to demonstrate targeted substance requirements – not on complete assessment or recycling dossiers.

From 2028 – further requirements (e.g. technical specifications, material classifications).
By 2030 – all packaging should generally be recyclable; minimum standards, recycled content and design requirements will be further specified or tightened.
This makes it clear: The regulation does not enter into full force on a single date, but establishes a multi-year framework for adaptation and implementation.

How is Ströbel preparing for the PPWR?

1. Analysing and optimising our packaging

We systematically review our packaging solutions with regard to:

  • material composition
  • recyclability
  • potential for material reduction

Our goal is to provide reliable data and technical information that our customers can use to meet their own obligations.

2. Close collaboration with suppliers & customers

A reliable and transparent data base is the foundation of a PPWR-compliant supply chain. That is why we work closely and in partnership with our suppliers.

In practical terms, this means:

  • We request relevant material and recycling data from our suppliers in a targeted manner.
  • We review evidence of recycled content carefully and transparently.
  • We structure and prepare the information so it is clearly and efficiently available to our customers.

An open exchange with our customers is just as important to us. Only through close cooperation can responsibilities be clearly defined and each role within the PPWR be determined unambiguously. We actively support our customers and are available to advise them.

Our call to action:

Contact us early. Together, we will clarify requirements, roles, and data needs and develop tailored solutions for your PPWR-compliant packaging concepts.

In addition, we are a member of the Industrievereinigung Kunststoffverpackung e. V. Through close collaboration within the association, we stay technically up to date and incorporate this knowledge directly into our customer projects.

Handling of Data and Information
When sharing information, we consciously maintain a balanced level of transparency.
This means: We provide all data necessary to fulfill the respective requirements – while at the same time ensuring that sensitive know-how is protected. Not every technical detail must automatically be disclosed. For example, exact formulations or specific layer thicknesses are generally not part of the mandatory information required under the PPWR. Our approach is therefore based on the principle of data minimization: We provide information in a way that is sufficient and reliable for our customers – without disclosing unnecessarily sensitive details.

3. Documentation, monitoring & information obligations

Our measures include:

  • building technical documentation for data sharing
  • preparing internal systems for upcoming information requirements
  • ongoing monitoring of technical detailed rules (e.g. exemptions, verification obligations, delegated acts)

4. Labelling [& customer information

Where it makes sense, we ensure:

  • clear product and packaging labelling
  • easy-to-understand guidance on use and data interpretation
  • additional information on the website and in customer communications

5. Training [& internal knowledge

Training already completed and ongoing ensures that our team communicates about the PPWR confidently, consistently, and transparently.

What does the PPWR mean in practice for our customers?

Above all, the PPWR leads to more information and evidence obligations for companies placing products on the market, manufacturers, and retailers. However, it can also be seen as an opportunity to make packaging more sustainable and future-proof.

We support our customers by:

  • providing robust material and recycling data
  • technically classifying packaging solutions
  • providing guidance on data sharing along the supply chain
  • defining roles within the PPWR together

Our aim is to be a reliable supplier and a competent point of contact—within our clearly defined role under the PPWR. Feel free to get in touch!

 

Conclusion: PPWR as a shared journey

The PPWR presents the packaging world with new challenges, while at the same time creating clear guardrails for more sustainable packaging solutions.
At Ströbel, we continuously work on further developing our products, processes, and information in line with the PPWR—transparently, in a structured way, and step by step.

 

Disclaimer:
This blog post reflects the status of the PPWR at the time of publication and is intended solely for general information purposes. It does not claim to be complete or permanently up to date.

Changes, additions, or new interpretations of the PPWR that take effect or become known after this article is published are not part of this post and will not be added retroactively.

This post is not updated or maintained on a regular basis. The applicable legal provisions and official publications by the competent authorities are always decisive.

This article does not replace legal or regulatory advice and does not create any liability or obligation.

 

📚 Sources [& further information on the PPWR

 

💡 Note for the article

The sources listed are provided for further information and reflect the status of public discussion and legislation at the time of publication.

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+49 (0)9101 99 420

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