PPWR: Between New Guidelines and Practical Questions

With the Packaging and Packaging Waste Regulation (PPWR), the European Union has established a new legal framework for packaging. Regulation (EU) 2025/40 entered into force on February 11, 2025. The first requirements have been mandatory in all EU member states since August 12, 2026. The goal of the PPWR is to reduce packaging waste, strengthen the circular economy, and establish uniform rules for packaging across Europe.

At first glance, these goals seem reasonable: packaging should be designed to use fewer resources, be more easily recycled, and be designed with reuse in mind to a greater extent in the future. The regulation covers the entire life cycle of packaging—from development and use to disposal and recycling. Key topics include recyclability, labeling, packaging minimization, the use of recycled materials, and restrictions on certain substances.

For companies, however, it quickly becomes apparent that the real challenge often lies not in the goals themselves, but in their implementation.

At Finke Colors, too, we are closely examining the impact of the PPWR on our processes and packaging solutions. This is no longer just about sustainability issues. The focus is increasingly on specific questions that many companies are currently dealing with:

Who is considered the manufacturer of packaging in a given case?

Who assumes the role of the producer or the distributor?

What requirements apply to transport packaging?

What labeling must be added in the future, and when will this requirement take effect?

In many cases, distinguishing between responsibilities within the supply chain proves particularly complex. The deeper one dives into the regulation, the clearer it becomes how closely regulatory requirements, packaging design, documentation, and operational processes are interconnected.

In addition, while parts of the PPWR have been applicable since August 2026, many other requirements will be phased in gradually through 2030, 2035, and beyond. For example, binding requirements regarding the recyclability of packaging and recycled content targets for certain plastic packaging will be further specified in the coming years.

A recent example is the restriction on PFAS in food contact packaging, which takes effect on August 12, 2026, and represents an important step toward reducing so-called “forever chemicals.”
For us at Finke Colors, this means systematically reviewing existing packaging concepts, shipping packaging, labeling, and internal processes. At the same time, we are in close communication with customers, suppliers, and industry partners. After all, many questions can only be answered collaboratively along the value chain.

From our perspective, the PPWR is therefore not a one-off compliance project with a fixed end date. Rather, it marks the beginning of a long-term process of change for the entire packaging industry.

And that is precisely why the most important insight from the past few months is this:
The more deeply one engages with the PPWR, the less it is about individual provisions and the more it is about a shared understanding of its practical implementation.