EU packaging and packaging waste regulation—what international corporate groups should know

The PPWR replaces Directive 94/62/EC on packaging and packaging waste (Packaging Directive), subject to limited transitional carve-outs, and introduces a directly applicable product-law regime for packaging design, substance restrictions, labelling, conformity documentation, traceability, recyclability, reuse, recycled content and extended producer responsibility (EPR).

Because the PPWR is directly applicable and replaces the Packaging Directive and the national laws that transposed it, businesses could in principle benefit from a single EU packaging framework instead of the previously fragmented national requirements.

However, diverging national law remains a central part of the compliance landscape: registration, reporting, fees, authorizations, market surveillance and penalties continue to be governed by member state rules, and national implementation is at markedly different stages.

Germany, for example, has adopted the Packaging Law Implementation Act (Verpackungsrecht-Durchführungsgesetz), which replaces the Packaging Act (Verpackungsgesetz) and applies alongside the PPWR from August 12, 2026, largely preserving the existing national compliance infrastructure, including the LUCID packaging register.

In practice, legal, compliance, procurement, packaging development, logistics and tax/finance teams will need a coordinated governance model covering both harmonized EU product rules and country-specific obligations.

Download our full report below for our analysis of what international corporate groups should know about the PPWR.