PPWR in Fulfillment: What companies need to know about the EU Packaging Regulation in 2026

The PPWR defines clear responsibilities along the supply chain. The roles determine which obligations apply to your company:

• Manufacturer (Art. 3(1)(13)): the PPWR's conformity role. The manufacturer is not necessarily the company that physically produces the packaging, but regularly the actor that has packaging or a packaged product developed or produced under its own name or trademark. Supplementary indicators under the Commission guidance — above all for unbranded packaging: who orders the packaging, and who makes the design and specification decisions?
• Producer (Art. 3(1)(15)): the PPWR's EPR role. The producer is the manufacturer, importer or distributor that first makes packaging or packaged products available in the respective member state — or unpacks packaged products there without being an end user. As a rule of thumb, this is usually the actor that opens the supply chain in the country where the packaging will later become waste; what is legally decisive, however, is the first making available. This entails registration, volume data and financing of collection, sorting and recovery.
• Supplier (Art. 3(1)(16)): anyone who supplies packaging or packaging material to a manufacturer, in practice the company that makes or trades packaging in the upstream supply chain. The supplier provides the material evidence (e.g. PFAS test reports, recycled-content shares, recyclability assessments) that manufacturers and fulfillment service providers build on.
• Importer (Art. 3(1)(17)): anyone who imports packaging from a third country into the EU.
• Distributor (Art. 3(1)(18)): anyone who resells or passes on packaging within the EU.
• Final distributor (Art. 3(1)(21)): anyone who delivers packaged products to end users — consumers or professional end users — including re-use and refill.
• Fulfillment service provider (FSP) (Art. 3(1), third subparagraph, PPWR in conjunction with Art. 3(11) of Regulation (EU) 2019/1020; obligations: Art. 20): anyone who provides at least two of the services warehousing, packaging, addressing or dispatching without owning the goods. The specific PPWR role follows from the activity: a 3PL is often a purely operational service provider, but can trigger obligations of its own if it selects or fills packaging, provides it under its own name or in a white-label model, unpacks imported goods or repacks them into smaller shipments.

For fulfillment service providers, this makes clean role, data and evidence clauses in customer contracts essential.

This classification follows the Commission guidance on Regulation (EU) 2025/40. Legally binding are the PPWR itself and its subsequent interpretation by the competent authorities and courts.

Packaging, under Art. 3(1)(1) PPWR, is an item, regardless of material, that an economic operator intends to use for the containment, protection, handling, delivery or presentation of products to other economic operators or end users. What matters is function and intended purpose, not merely whether an item is made of paper, cardboard, plastic or textile.

Packaging material, by contrast, is the substance or component a packaging item is made of: for example cardboard, paper, plastic film, adhesive, coating, inlay, cushioning or filling material. Materials or individual components are not automatically packaging. They become relevant under the PPWR when they are part of a packaging unit or fulfill a packaging function themselves.

For fulfillment practice: a shipping carton, a mailing bag or a filled service container is regularly packaging. A raw paper web, a film roll or an adhesive starts out as packaging material. Inlays, labels, bags, coatings and filling material still need to be considered, because they can affect the conformity, recyclability, PFAS assessment and material labeling of the packaging as a whole.

The PPWR is an EU regulation and applies directly in all member states. The German Packaging Act (VerpackG) remains authoritative for national implementation until the transition periods expire. After that, it will be replaced step by step by the PPWR.

What stays similar: the system participation obligation, registration with the Central Agency, the principle of product responsibility.

What changes: EU-wide harmonized empty-space limits (previously unregulated at national level), binding recycled-content quotas with concrete phased schedules, harmonized QR-code labeling obligations, extended producer responsibility (EPR) from 2027 with registration required in each relevant EU member state. Important: until the PPWR registers launch, the existing national registration obligations remain in force — in Germany the LUCID registration under the VerpackG. EPR (Extended Producer Responsibility) obliges the producer within the meaning of the PPWR to bear the costs of collecting, sorting and recovering its packaging.

For operational practice: companies that already work VerpackG-compliant have a solid foundation, but need to upgrade significantly in the areas of empty space, material documentation and labeling.

The PPWR separates responsibility by role. The manufacturer under Art. 3(1)(13) is responsible for the packaging's conformity with sustainability and labeling requirements, in particular for technical documentation, conformity assessment and the EU declaration of conformity. The producer under Art. 3(1)(15) bears the EPR responsibility in the respective member state, i.e. registration, volume reporting and financing of collection, sorting and recovery.

EPR financing covers the waste phase of the packaging, i.e. what happens after it becomes waste at the end customer:

• Collection: collecting the used packaging (e.g. Germany's yellow bag/bin, collection schemes)
• Sorting: separating the collected volume into material fractions (paper, PET, film …)
• Recovery: material recycling or energy recovery

Fulfillment service providers (3PLs) are not automatically liable for every customer's packaging. They can, however, incur obligations of their own if a 3PL selects, fills or brands packaging itself, unpacks imported goods or repacks them into smaller units. Under the Commission guidance, logistics companies that repack goods can even be the producer of the transport packaging, even if they do not own the products.

New from 12 August 2026 — evidence requirement in B2C fulfillment (Art. 45(7)–(9)): producers offering to consumers in the EU must provide their fulfillment service provider with their EPR registration information and a self-certification when the contract is concluded. The fulfillment service provider must use its best efforts to verify this information — and suspend its services for that producer if the information is missing and is not supplied. For brands and retailers this means: without valid registration(s), a fulfillment partner may not work for you from the deadline onwards. Clarify registration numbers and responsibilities before August 2026.

In practical terms: it is not only "who places it on the market?" that needs clarifying, but who makes the design decisions, who fills or uses the packaging, in which member state the packaging is first made available, and who supplies the evidence. Depending on the arrangement, conformity evidence (e.g. PFAS test reports, recycled-content shares, recyclability assessments) must be able to flow in both directions: if the 3PL selects the packaging itself (manufacturer role), it hands the evidence over to its client. If the client purchases or specifies the packaging itself, it provides the evidence to the 3PL; the 3PL should request it as a matter of due diligence anyway.

The PPWR itself does not set uniform fine levels. Art. 68 of Regulation (EU) 2025/40 obliges the EU member states to enact effective, proportionate and dissuasive penalties at national level by 12 February 2027.

In Germany, the Packaging Law Implementation Act (VerpackDG) will implement the PPWR and is set to replace the VerpackG. The Federal Government adopted the cabinet draft on 11 February 2026; entry into force is scheduled for 12 August 2026, with the parliamentary procedure still ongoing (as of June 2026).

A penalty is usually preceded by a staged procedure (Art. 62): if the declaration of conformity is missing or incomplete, market surveillance authorities first require corrective action; if the deficiency persists, the packaging can be taken off the market (sales ban, withdrawal, recall). A valid declaration of conformity is therefore effectively a precondition for market access.

Consequences to expect in case of violations:

• Fines under the VerpackDG draft: tiered by violation, up to €500,000, plus the disgorgement of economic benefits
• Sales bans for non-compliant packaging and the products it contains
• Public listing with the German Central Agency Packaging Register (LUCID) for repeated violations
• Exclusion from tenders and B2B supply relationships that require PPWR conformity as a mandatory criterion

Operational risks often arise even before any official sanction, for instance when wholesalers or platforms such as Amazon require PPWR conformity evidence as a listing prerequisite.

What matters is not the production or storage date, but whether the packaging was already first placed on the market before the deadline — that is, first made available on the Union market (Art. 3(9)/(10)):

• Already placed on the market — for example goods a retailer took over from its supplier before the deadline: grandfathered; they may continue to be made available and sold off.
• Not yet placed on the market — for example produced but not yet supplied goods held by the manufacturer or importer, even if they are physically sitting in a logistics warehouse: from the deadline, the requirements applicable at that time apply, in particular the substance restrictions under Art. 5.

Important: there is no full-conformity cliff — the obligations phase in over time (PFAS from 2026, harmonized labeling from 2028, recyclability and recycled content from 2030). For practice: document for each stock item when and to whom it was first supplied — this evidence decides whether grandfathering applies. Where the conformity status is unclear, higher-risk packaging should not be used for the time being.

From 2026, two requirements take priority: the restriction of hazardous substances and traceability:

• PFAS limits (from 12 August 2026): certain PFAS may only be present in very low concentrations, with limits for individual substances and for the sum of several PFAS. If the total fluorine content exceeds a threshold, polymeric PFAS must also be taken into account.
• Manufacturer attribution (from 12 August 2026): the packaging must be clearly attributable to its manufacturer (Art. 15): via a type, batch or serial number plus the manufacturer's trade name or trademark and contact details. This information can also be provided digitally, for example via a QR code.

QR-code labeling comes later and in stages: harmonized material labeling from 12 August 2028 (Art. 12(1)) and, for reusable packaging, re-use information from 12 February 2029 (Art. 12(2)). It is therefore not a requirement for 2026.

The PPWR does not prescribe any particular material across the board. From 2026, the first priority is complying with the limits for substances of concern. By 2030, it also becomes relevant whether the material is resource-efficient and recyclable. The packaging should:

• be separately collectable, sortable and recyclable at scale,
• use as little material and take up as little volume as possible,
• contain no non-permissible or heavily restricted substances,
• for plastics, meet the required minimum recycled content.

Suitable options therefore include recyclable paper, cardboard or plastic packaging, packaging with verifiable recycled content, or reusable solutions. Ultimately, the intended use decides.