The New European Packaging Regulation (PPWR)

Many companies that import goods into the European Union will face new obligations, particularly importers of packaging or packaged goods. It is important to take the new reporting and documentation requirements into account well in advance. In the future, a distinction must be made between “producers” and “manufacturers” of packaging or packaged goods.

We would like to inform our customers about the most important initial points through our FAQs and provide them with guidance:

FAQ on the EU Packaging and Packaging Waste Regulation (PPWR)

1. What is the PPWR?

The PPWR (Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40) is the new European packaging regulation. Its objective is to reduce packaging waste, promote the reusability and recyclability of packaging, and establish harmonized packaging requirements across the European Union. Certain provisions of the Regulation will apply from 12 August 2026, while additional obligations will be introduced gradually over the coming years.

2. Does the PPWR affect my company?

In principle, the Regulation affects all companies that manufacture, import, distribute, or use packaging. The specific obligations applicable to a company depend on its role within the supply chain and the types of packaging it places on the market or uses.

3. Which requirements enter into force on 12 August 2026?

From that date, packaging may generally only be placed on the market if the PPWR requirements are met and the necessary conformity assessments and documentation are available. At the start of application, the most relevant requirements concern restrictions on certain substances, particularly heavy metals (Article 5 PPWR) and PFAS substances, where applicable.

4. What is considered packaging?

In general, packaging includes any item used for the containment, protection, handling, delivery, or presentation of goods. This includes, among others:

• Stretch and shrink wrap films
• Cardboard boxes and layer pads
• Labels
• Adhesive tapes
• Strapping materials
• Pallets
• Wire mesh containers (gitter boxes)
• Other transport and protective packaging

This list is not exhaustive. In case of doubt, all materials used to package, secure, protect, or transport goods should generally be regarded as packaging within the meaning of the PPWR.

5. Which documents are typically required?

Depending on the type of packaging, the following documents are commonly required:

• Declarations of Conformity regarding compliance with PPWR requirements
• Evidence of compliance with heavy metal limits under Article 5 PPWR
• PFAS declarations, where relevant
• Technical data sheets
• Other supplier confirmations and manufacturer declarations

6. Can DACHSER provide a PPWR Declaration of Conformity for all packaging used by DACHSER?

DACHSER is generally not the manufacturer of the packaging materials used. The required conformity information is typically provided by the respective packaging manufacturers or suppliers. Therefore, DACHSER can only pass on information that has been provided by the original manufacturers or suppliers. DACHSER has requested the relevant documentation for all packaging materials procured by DACHSER. For packaging materials procured directly by customers, the customer is responsible for obtaining the necessary supporting documentation.

7. Does DACHSER assume responsibility for the accuracy of the forwarded Declarations of Conformity?

No. Where DACHSER forwards documentation received from manufacturers or suppliers, this is done solely on the basis of the information provided to DACHSER. The forwarding of such documentation does not constitute an independent guarantee, warranty, contractual quality commitment, certification, or legal assessment by DACHSER.

8. Will packaging have to be labelled in the future?

Yes. The PPWR introduces various labelling requirements. For many types of packaging, identification markings and additional information will become mandatory. Certain details are still subject to further specification through implementing acts and delegated acts of the European Commission.

9. Must all existing packaging be replaced immediately?

No. Many PPWR obligations will only become applicable gradually over the coming years. In addition, numerous technical requirements still depend on implementing measures and guidance documents that have yet to be adopted by the European Commission.

10. How is DACHSER preparing for the PPWR?

DACHSER is actively preparing for the implementation of the PPWR. Key activities include:

• Collecting relevant documentation and Declarations of Conformity from suppliers
• Monitoring and analyzing new publications issued by the European Commission
• Coordinating with industry associations and subject matter experts
• Preparing internal processes for documentation and compliance management
• Supporting customer inquiries regarding packaging materials used by DACHSER

11. Who should I contact if I have further questions?

Please contact your usual DACHSER representative. We will be pleased to support you with questions relating to packaging materials used by DACHSER and the related documentation available to us.

However, the assessment of company-specific requirements and the legal evaluation of your individual obligations under the PPWR remain the responsibility of your company and its legal advisers.