Packaging and Packaging Waste Regulation (PPWR) and the Automotive Industry

1. What is the PPWR about?

The Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, has established rules that are directly applicable to all packaging and packaging waste in the EU since it entered into force on February 11, 2025. The first "wave" of PPWR obligations applies from 12 August 2026 onwards and includes, especially, comprehensive labelling, documentation, as well substance requirements .

The PPWR's goal is to prevent packaging waste, increase reuse and recycling, and thereby contribute to a circular economy and climate neutrality by 2050. To this end, certain economic operators also in the automotive industry are required to comply with the regulations. In practice, the PPWR creates a harmonised legal framework that reshapes how packaging is designed, used, and managed across the entire value chain. For companies, this means that packaging‑related responsibilities are no longer a purely "downstream" waste issue, but affect strategic decisions on product development, supply chains, and compliance management throughout the life cycle of packaging .

2. How does it affect the automotive industry?

The PPWR applies in principle to all packaging that is used to contain, protect, handle, deliver or present a product, regardless of its size or where it is used. This also covers products and components used in the automotive industry. Typical examples include VCI corrosion‑protection films, ESD packaging and protective adhesive films for cockpit displays.

Even if current solutions are technically advantageous, companies must comply with the PPWR and, where necessary, adapt or redesign their packaging concepts. In doing so, they need to pay particular attention to restrictions on certain packaging formats (single‑use plastic), the use of recyclable materials and the requirement to minimize empty space in packaging. Under Article 10, the empty space ratio in grouped, transport and e-commerce packaging used for supply of products to final distributors or end users shall not exceed 50% .

From 1 January 2030, all packaging must meet minimum recyclability performance grades (A, B or C), with packaging below grade C prohibited from market placement. From 1 January 2038, only grade A or B will be acceptable .

3. What are the obligations of the players in the automotive industry?

The PPWR breaks down legal duties into four primary categories based on the role in the delivery chain. In the automotive sector, a single company can hold different roles depending on where a specific part or packaging material originates, or how it is finally placed on the market.

3.1 Manufacturer

Under Article 2(1) Nr.13 PPWR, a manufacturer is any natural or legal person that produces packaging or a packaged product. This also covers companies that have packaging or packaged products made under their own name or trademark; in these cases, they are regarded as the manufacturer even if other brands appear on the packaging. As such, the manufacturer is broadly responsible for the packaging over its entire life cycle: it must ensure that the design requirements are met, carry out the necessary conformity assessment procedures and, where needed, take corrective action to bring non‑compliant packaging into line with the PPWR .

The European Commission clarifies that, within the meaning of the Regulation, there is only one manufacturer at EU level for each packaging or packaged product, regardless of the complexity of the supply chain .

3.2 Importer

Under Article 2(1) Nr. 17 PPWR, an importer is any natural or legal person established in the EU that places packaging from a third country on the Union market. In this role, the importer must in particular ensure that the required conformity assessment has been carried out, that the packaging meets the PPWR requirements and that all mandatory markings and documentation are correctly and completely in place before the packaging is made available in the EU .

3.3 Producer

The producer has a more detached role and can, in principle, be any economic operator in the distribution chain. In essence, the producer is the actor who first makes packaging available from within the territory of a Member State and on that same territory, Article 2 (1) Nr.15 PPWR .

Once this is the case, the producer becomes subject to extended producer responsibility under Articles 44 et seq. PPWR. The core idea of extended producer responsibility is that the producer is responsible for the collection, sorting and recycling of packaging and must bear the associated costs in line with the polluter-pays principle. In other words: whoever places packaging on the market must also ensure that it is effectively taken back from the market .

The concept of producer is determined on a Member State‑by‑Member State basis and refers to the economic operator (whether manufacturer, importer or distributor) that makes packaging or packaged products available for the first time in the territory of a given Member State.

3.4 Distributor

Under Article 2 (1) Nr.18 PPWR, a distributor is any natural or legal person in the supply chain, other than the manufacturer or importer, that makes packaging available on the market. In practice, distributors must in particular verify that the packaging they supply complies with the PPWR requirements and ensure that storage and transport conditions do not compromise that compliance (for example, by damaging reusable packaging or labels that are required for correct sorting and recycling) .

4. Which authorities are competent (in Germany)?

Under the PPWR, enforcement is decentralised. As it is an EU regulation, rules are unified across Europe, but each of the 27 Member States appoints its own authorities to check compliance, inspect sites and impose fines .

In Germany, the Central Packaging Register Foundation (ZSVR) is the main contact point for companies. It checks the data reported by businesses (such as quantities, weights and material types of packaging) and verifies whether the required quotas are met. The German Environment Agency (Umweltbundesamt – UBA) supervises the ZSVR from a legal and technical perspective and is responsible for starting and handling administrative fine procedures in case of violations. Beyond this, authorities in the federal states in Germany will review packaging compliance .

The Packaging Implementation Act (VerpackDG), which aligns German law with the PPWR, entered into force on August 12, 2026 . The LUCID packaging register remains in place, but regulations governing the register will be amended to ensure consistency with the PPWR's definitions.

5. What happens in case of non-compliance?

Member States must, under the PPWR, put in place effective sanction mechanisms for breaches of the Regulation. In Germany, this role is fulfilled by the VerpackG, which defines specific administrative offences and allows for significant fines in the approximate range of EUR 10,000 to EUR 200,000. However, the consequences are not limited to monetary sanctions: packaging that does not comply with the PPWR and the VerpackG is, in principle, barred from being placed on the market. In addition, non‑compliant companies expose themselves to unfair competition actions, as competitors may pursue cease‑and‑desist claims to stop the marketing of non‑conforming packaging .

There is no transition period. If system participation is not adjusted in time, a distribution ban will be placed on packaged products from 12 August 2026 onwards .

6. What are the consequences?

As the VerpackG is the national framework of the PPWR, knowledge on the PPWR is a "must" for all stakeholders in manufacturing companies, and particularly in the automotive sector. Stakeholders should carry out a gap analysis comparing their current level of knowledge and existing packaging‑related processes with the requirements arising under the PPWR, with their suitability also under VerpackG.

In many cases, adjustments and additions will be unavoidable: the VerpackG is not merely the "interface" between the PPWR and the German authorities, but also imposes additional national obligations on the automotive industry for example the obligation to register with the LUCID Packaging Register and to participate in the system for sales packaging, as well as detailed obligations to provide information, documentation, and data reporting to the Central Packaging Register Office .

Significant changes under the new regulations include:

• The obligation to participate in the system will apply to a significantly wider range of packaging, including primary production packaging and transport packaging

• Manufacturers of packaging not subject to mandatory system participation will need a license from the Central Packaging Register

• New definitions of "manufacturer" and "producer" create uncertainty and require companies to promptly assess their classification

7. What needs to be done now?

Automotive industry operators should immediately :

1. Assess their role(s) according to PPWR (manufacturer, importer, distributor, producer). For this, three questions are helpful: Where is your packaging coming from, what is your company doing with it and where does it go to?

2. Based on the role, review whether packaging labels need to be implemented and/or adapted.

3. Draft the documentation and ensure access to the necessary documentation.

Additional recommended actions :

4. Ask suppliers for packaging information: Obtain weights and material groups of packaging for accurate volume forecasting.

5. Adapt system participation in good time: Enter into new agreements or expand existing contracts with system operators.

6. Update registration data in the LUCID Packaging Register: Add and review all relevant brand names.

7. Report adjusted planned and forecasted volumes in the LUCID Packaging Register.

8. Keep a logical paper trail: Record all relevant packaging and volume data for year-end reporting.

With the August 12 deadline fast approaching, automotive companies that fail to comply risk distribution bans and significant fines. The industry is already shifting from analysing PPWR requirements to implementing practical solutions, with workshops and industry bodies working to develop common approaches across the automotive supply chain . Companies should act now to avoid disruption and position themselves for compliance in the new regulatory landscape.