🇪🇺 EU PPWR applies in full with no grace period; German VerpackDG in force same day
12 Aug · European Union / Germany · Confidence: Official text
What happens
The Packaging and Packaging Waste Regulation (PPWR) applies in full from 12 August 2026, with no grace period. Obligations applying from that date include: (1) the recyclability requirements of Article 6; (2) extended producer responsibility (EPR): producers must register separately in each country of sale and pay annual fees based on packaging material weight, with no exemption for micro or small enterprises, and the obligation also covers non-EU exporters selling directly to EU consumers via e-commerce; (3) PFAS limits for food-contact packaging: 25 ppb for any individual PFAS, 250 ppb for the sum of targeted PFAS and 50 ppm for total PFAS including polymeric PFAS; (4) the EU declaration of conformity (DoC). In addition, the combined concentration of the four heavy metals lead, cadmium, mercury and hexavalent chromium must not exceed 100 mg/kg, technical documentation must be kept for five years, and economic operators must be identified on the packaging. Labelling obligations under the harmonised labelling implementing act do not apply in full until 12 August 2028. Suppliers that cannot provide Annex VII technical documentation leave their downstream partners unable to sign the DoC. From the same date, Germany requires foreign companies to appoint an authorised representative, with no exemption.
What to do
(1) Packaging suppliers and contract manufacturers should prepare a standard PPWR Annex VII compliance dossier template (six elements) so that downstream parties can sign the DoC. (2) For shipments to Germany, the Central Agency Packaging Register (ZSVR) explicitly determines the importer on the basis of Incoterms: under DAP/DDP terms the exporter is treated as the importer under German law and assumes the related obligations. Companies should review their choice of trade terms (e.g. EXW/FCA/FOB) when contracting.
Source
Reg (EU) 2025/40 · ZSVR
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