The new EU packaging regulation (PPWR) brings with it far-reaching requirements for mechanical and plant engineering.
The new EU Packaging Regulation (PPWR) brings with it far-reaching requirements for mechanical and plant engineering – from specifications regarding the conformity of packaging to specifications in the area of extended producer responsibility.
The EU Packaging and Packaging Waste Regulation (PPWR)
2025/40 came into force on February 11, 2025 and will replace the previous EU Packaging Directive 94/62/EC from August 2026. As almost all products in mechanical and plant engineering are packaged and a wide variety of packaging types are used, the industry is affected by the new requirements.
On 24 June 2025, ProduktionNRW and VDMA Nord organized a virtual information event on the regulation. The aim was to give the participating companies a compact overview of the most important content, innovations and requirements of the PPWR.
The new EU packaging regulation
Andre Koring, VDMA Environment & Sustainability Officer, presented the main features of the PPWR. Uniform regulations are intended to strengthen the EU internal market and promote environmental goals such as the circular economy. Key elements include requirements for recyclability, the reduction of packaging materials and the reusability of packaging. In contrast to the previous EU directive, the regulation applies directly in all EU member states. The German Packaging Act (VerpackG) must be amended before the PPWR comes into force – particularly with regard to the structure of the requirements in the area of extended producer responsibility and the sanction regulations.
Central requirements of the PPWR at a glance:
Conformity assessment procedure and EU Declaration of Conformity: In future, producers of packaging must carry out a conformity assessment procedure before placing packaging on the market and, as a result, submit an EU Declaration of Conformity confirming compliance with the PPWR requirements.
- The requirements relevant to placing packaging on the market include the following points:
- Pollutant limits: among other things, packaging must not exceed defined pollutant limits for substances of concern.
- Recyclability and minimum recyclate content: Packaging must be recyclable in future. From 2030, only packaging with a specific classification in accordance with the “Design for Recycling” criteria may be placed on the market. At the same time, the requirements for the minimum recyclate content in plastic packaging will increase.
- Minimization of packaging: From 2030, it must be ensured that packaging placed on the market is designed in such a way that its weight and volume are reduced to the minimum necessary to ensure its functionality, taking into account the shape and material of the packaging.
- Reusable packaging: Packaging placed on the market from 2025 is considered reusable if it meets certain requirements.
- Labeling requirements: From 2028, packaging must be marked with EU-wide harmonized symbols to facilitate correct disposal. QR codes can also be used. Reusable packaging requires separate labeling.
The PPWR significantly extends the obligation to reuse. From 2030, binding reusable quotas will apply for numerous types of packaging – especially for industrial and transport packaging. However, for some types of packaging, such as pallet wrapping or strapping, the technical requirements still pose a challenge at present.
Obligations that are not relevant to the conformity assessment procedure but which must be fulfilled by all economic operators relate to the following points:
- Avoidance of excessive packaging: From 2030, economic operators filling non-reusable secondary packaging, transport packaging or packaging for e-commerce must ensure that the void ratio is a maximum of 50%.
- Restrictions on the use of certain packaging formats: From 2030, economic operators will not be allowed to place packaging on the market in the formats and for the purposes listed in Annex V of the PPWR.
The new roles for economic operators are accompanied by new responsibilities: the regulation introduces new definitions for economic operators. In future, companies will have to check whether they are considered manufacturers, producers, importers, distributors or suppliers – because different obligations arise depending on the role, for example with regard to registration in manufacturer registers or carrying out the conformity assessment procedure.
Discussion and exchange of experience
An essential part of the event was the exchange of views on the challenges and points of criticism regarding the new EU Packaging Regulation. Many companies expressed concerns that the extensive requirements represent a considerable burden, particularly for mechanical and plant engineering. In addition, the strong B2C focus of the regulation was criticized, which takes insufficient account of the specific requirements of the B2B sector, for example in industrial and transport packaging.
Overall, the new EU packaging regulation brings far-reaching changes along the value chain. Many detailed regulations still need to be fleshed out in secondary legislation. Companies are therefore well advised to familiarize themselves with the new requirements at an early stage and adapt their processes if necessary.
Further information
The EU Packaging Regulation can be found here.
- Further VDMA information can be found here.
- Background information on packaging waste can be found here.
Organizer
The event was organized by ProduktionNRW. ProduktionNRW is the cluster for mechanical engineering and production technology in North Rhine-Westphalia and is organized by VDMA NRW. ProduktionNRW sees itself as a platform for networking, informing and marketing companies, institutions and networks with each other and along the value chain. Significant parts of the services provided by ProduktionNRW are funded by the Ministry of Economic Affairs, Industry, Climate Protection and Energy of the State of North Rhine-Westphalia.