PPWR and VerpackDG: what packaging projects need to consider now

A new European framework

Regulation (EU) 2025/40 on packaging and packaging waste entered into force on 11 February 2025 and has applied since 12 August 2026. However, many individual requirements take effect at different times or are further specified by additional legal acts.

In Germany, the Packaging Law Implementation Act, or VerpackDG, accompanies implementation. The obligations applicable to a company depend on factors including its role, the type of packaging, the market and the date on which the packaging is placed on the market.

Relevant questions for new folding cartons

Among other things, the PPWR strengthens packaging prevention, recyclability, labelling and documentation. For new projects, it is worth clarifying early which data and evidence are needed along the supply chain.

• Has the packaging been reduced to the necessary dimensions and material?
• Can the construction be recycled in the intended material streams?
• Which coatings, adhesives and finishes are used?
• Which product and material data must be documented?
• Which labelling rules apply at the planned market entry date?
• Who assumes which responsibilities in the supply chain?

Assess each project rather than making blanket assumptions

Not every provision applies immediately and in the same way to every type of packaging. Companies should therefore consult current original sources and, where appropriate, qualified legal advice. This article provides technical orientation, not legal advice.

HvC supports structural design, material selection and the provision of agreed packaging data. The legal assessment of the packaged product and the obligations of the party placing it on the market remain with the respective responsible company.