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trade-e-bility News and Press Releases

PPWR: Do I need an EU Declaration of Conformity for my packaging?

Please note: From 12 August 2026, packaging must be covered by a declaration of conformity before the relevant goods or products can be imported into or placed on the EU market. The EU Packaging and Packaging Waste Regulation (PPWR) requires a separate declaration of conformity to be drawn up for packaging within its scope. This requirement applies not only to sales packaging but also to transport packaging.
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PPWR labelling: How should I label my packaging?

The EU Packaging and Packaging Waste Regulation (PPWR) introduces new labelling and information requirements for packaging, which will be phased in across the European Union. These requirements are intended to make it easier for consumers to correctly sort packaging waste, promote the circular economy, and establish harmonised packaging labelling standards across Europe.
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PPWR sanctions: What fines apply under the EU Packaging and Packaging Waste Regulation and the VerpackDG?

The EU Packaging and Packaging Waste Regulation (PPWR) introduces new packaging requirements across Europe from 12 August 2026. In Germany, the current Packaging Act (VerpackG) will be replaced by the Packaging Law Implementation Act (VerpackDG), which will implement the PPWR at national level and set out the applicable sanctions and fines for non-compliance. For businesses, the key question is: What fines and other sanctions can be imposed for breaches of the PPWR and the VerpackDG?
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Digital Product Passport: The clock is ticking

With the gradual introduction of the Digital Product Passport (DPP) as a requirement, businesses that do not comply may face serious repercussions. Among the risks involved are sales bans, fines, product recalls, and considerable damage to one’s reputation. Thus, companies should stop postponing the development of their DPP strategy.
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Digital Battery Passport: New risks and duties from 2027

The countdown is on: starting in 2027, the Digital Battery Passport will be compulsory, posing a significant compliance challenge for numerous companies. Data that is incomplete or incorrect could put market access at risk, disturb supply chains, and weaken competitiveness. It is essential for producers and retailers to take action now, since market success will rely on both the battery and the quality and completeness of its digital information.
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Right to Repair: New obligations for retailers and producers

In 2026, the right to repair will materialise, leading to a fundamental transformation of the duties of producers and retailers. New repairability requirements, longer warranty periods, stricter regulations on the availability of replacement parts, and the implementation of the Digital Product Passport will increase the pressure on product development, after-sales service, and compliance. Companies that do not adjust their processes in a timely manner risk facing legal repercussions, substantial costs, and a loss of competitive edge.
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PPWR: Who is considered the manufacturer for retailers’ private labels?

Answer: “When [RETAILER] sells [BRANDED PRODUCT/THIRD-PARTY BRAND], then [BRAND MANUFACTURER] is deemed to be the manufacturer. When [RETAILER] sells its own brand, [RETAILER’S OWN BRAND], then [RETAILER] is deemed to be the manufacturer, even if the filler is different from [RETAILER]. It may even be [BRAND MANUFACTURER] that packages a variety of [PRODUCT] for [RETAILER] exclusively under the brand [RETAILER’S OWN BRAND].” In this context, the term “manufacturer” refers to the economic operator responsible for packaging conformity, while the role of the “producer” relates separately to Extended Producer Responsibility (EPR) and the financing of packaging waste recovery. This interpretation is based on the European Commission’s official guidelines and has been coordinated with the Federal Ministry for the Environment, Climate Action, Nature Conservation and Nuclear Safety (BMUKN) and the German Environment Agency (UBA).
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Please note: Increased PPWR customs inspections in Poland

Companies that ship goods to Poland or place them on the Polish market for the first time should expect increased customs inspections starting on August 12, 2026. According to a Polish customs agency, BDO registration and the required proof of packaging compliance will be subject to more rigorous checks. For retailers, producers, and importers, these inspections may directly affect customs clearance and disrupt supply chains if the required documentation is not in place.
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Does your packaging labelling comply with legal requirements?

Ensure your packaging labels comply with current legal requirements and are prepared well in advance for upcoming regulations such as the PPWR and EmpCo.
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Batteries must be replaceable from 2027

From February 2027, producers of headphones, laptops, e-readers, and gaming consoles will be required to use batteries that users can replace themselves. Companies that still rely on built-in batteries may need to make significant changes to their production processes. Even major tech companies are already adapting to the new EU regulations, as repairability becomes a mandatory standard. The rules apply, among other products, to headphones, e-readers, portable gaming consoles, and laptops.
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