With the publication of the PPWR guidance and the accompanying FAQ from the European Commission, important orientation aids for companies are now available. At the same time, numerous national developments show that the implementation of European requirements remains closely intertwined with country-specific rules. Overall, the regulatory dynamics surrounding packaging are continuing to increase shortly before the deadline of 12 August 2026. We go into more detail in our blog, take a detour to the topic of recycling rates and tell you what is important now.
1. PPWR: New Guidance and FAQ from the European Commission
The European Commission has published two key documents for the implementation of the Packaging and Packaging Waste Regulation: comprehensive guidance (guidelines) and an FAQ document. Both are intended to support companies and member states with interpretation and practical implementation.
You can view and download the guidance and the FAQ document here:
Particularly relevant are the clarifications on term definitions and roles, for example regarding manufacturers, producers and importers. The concept of packaging is also further defined. This gives companies more guidance on which obligations apply along the supply chain.
PFAS
A further focus is on PFAS (per- and polyfluoroalkyl substances) in food-contact packaging. The new restrictions apply from 12 August 2026. For non-compliant stocks, no general sell-off period is currently provided for. Which specific packaging formats are affected, which thresholds apply, and how a risk-based conformity assessment can be achieved are explained in detail in our article “PFAS in the PPWR – A Risk-Based Approach to Compliance”.
BP Consultants Assessment:
The guidance creates more clarity, but does not replace company-specific review. Companies should now systematically analyse their packaging portfolio, identify data gaps and clarify roles, evidence and responsibilities along the supply chain.
2. Country Developments: National Rules Remain Relevant
In addition to the PPWR applicable to the entire EU, numerous national requirements are also continuing to develop. Companies should therefore not only keep an eye on the EU regulation, but also review local implementation steps and special rules.
Germany passed the new national Packaging Act (VerpackDG) in the Bundestag on 11 June, thereby aligning national law with EU Regulation 2025/40. The resolution expands producer responsibility and affects, among other things, registration, recycling, reporting, deposit systems, use of recyclates, and reuse obligations for certain single-use food and beverage packaging. Ecomodulation in the area of EPR costs also becomes mandatory.
The draft resolution for the Act on Adapting Packaging Law and Other Areas of Law to Regulation (EU) 2025/40 is available here as a pdf. Note: This is the draft resolution and not yet the final act.
Denmark is planning changes to packaging requirements and extended producer responsibility. These include maximum fees for municipal packaging waste, adjusted producer payments, density factors calculated on a weight basis, and new information obligations.
Italy is proposing requirements for biodegradable and compostable packaging. Certain single-use plastic packaging will be required to meet additional specifications in the future; exceptions and sanctions are provided for.
Finland is planning regulations on producer compensation for certain single-use plastic products for the period 2026 to 2028. Nicotine pouches are also to be covered as plastic articles.
Further non-European developments concern, among others, Chile, India, the USA, California and Georgia. Topics include recyclate content, recycling claims, EPR systems, deposit systems, food contact materials and stricter requirements for labelling and traceability.
BP Consultants Assessment:
Harmonisation through the PPWR reduces national fragmentation, but does not eliminate it entirely. For internationally active companies, continuous regulatory monitoring remains indispensable.
3. End-of-Life and Recycling Rates: Caution with Interpretation
The discussion around the “end-of-life” of packaging is increasingly shifting from formal recycling rates to real recycling outcomes. What then becomes decisive is no longer solely whether packaging waste is sent for recycling, but what quantities are actually materially recycled after sorting and process losses.
The PPWR stipulates that for recycling targets, the weight of packaging waste that actually enters the recycling process is generally decisive. Sorting losses and subsequent rejections must be taken into account.
An example illustrates the relevance: for plastic packaging, the EU27 recycling rate in 2023 was 42.1 percent according to Eurostat. Taking into account average German loss factors, this value is calculated to reduce to 33.8 percent. This figure is significantly closer to the rate of 34.6 percent reported by the EU’s Joint Research Centre.
Discrepancies also arise with other materials. Paper, glass, steel and aluminium have different loss rates. Process losses can particularly strongly influence the actually recycled quantity in the case of aluminium.
In addition to these discrepancies comes the factor of “mismanaged waste”. This includes, for example, uncollected waste, open burning, improper landfilling or discharge into waterways. For plastic packaging waste, the share of improperly managed waste is cited in various sources as several percentage points. Reliable data for other materials are largely lacking.
BP Consultants Assessment:
Recycling rates should not be viewed in isolation. For design decisions, sustainability communication and PPWR readiness, it will be crucial in the future whether packaging is sorted, recovered and recycled to a high standard under real conditions.
4. Interpack 2026: PPWR Compliance in the Industry’s Focus
At Interpack 2026, it became clear that PPWR compliance and digital packaging data management are important topics for the industry. Various software companies presented solutions for managing and analysing packaging data, as well as new functions for PPWR-compliant declarations of conformity and technical documentation.
Particularly at the SPOTLIGHT Forum “Chances & Risks of PPWR”, it became clear that companies need practical tools to implement regulatory requirements efficiently.
BP Consultants Assessment:
The demand for digital compliance solutions is increasing. Those who capture packaging data in a structured way today gain a clear advantage for PPWR, EPR, recyclability, recyclate content and supplier documentation.
Conclusion for Companies
The PPWR will be operationally effective from 12 August 2026. The new guidance and FAQ documents provide important orientation, but also show: many requirements need to be translated on a company-specific basis. Companies that still need to establish comprehensive processes and supporting documentation at short notice can use our “PPWR Late Starter Package – Fast, Pragmatic and Structured” (<LINK>) as a practical starting point for implementation.
What is now decisive:
- Structure and assess the packaging portfolio.
- Prioritise PFAS risks and heavy metals on a risk-based basis.
- Close data gaps along the supply chain.
- Prepare technical documentation.
- Establish declarations of conformity per packaging type.
- Continue monitoring national developments.
- Assess recyclability not just formally, but in a way that reflects reality.
The PPWR is therefore not only a regulatory obligation, but a driver for better data, more robust supply chains and future-proof packaging design.
