The new EU Packaging and Packaging Waste Regulation (PPWR) is considered one of the most significant regulatory shifts in recent years for the packaging, retail, and waste management sectors. After being published in the Official Journal of the European Union in January 2025 under number 2025/40 and entering into force on February 11, 2025, the actual date of application is now approaching: August 12, 2026. From that date onward, new obligations will apply for the first time — ranging from recycled content requirements to extended producer responsibility (EPR).
However, it is precisely this start date that has triggered strong opposition within the industry. In the summer of 2025, a broad alliance of leading trade associations formed, calling for a postponement of the regulation’s application by several months.
In July 2025, 17 organizations — including the Federal Association of the German Waste Management Industry (BDE), the bvse, the German Retail Association (HDE), the Federation of German Food and Drink Industries (BVE), the GKV, the German Plastics Packaging Industry Association (IK), the Brand Association, and the German Dairy Industry Association — sent a joint letter to Federal Environment Minister Carsten Schneider.
The letter warns of “serious practical problems” should the new EU regulation take effect as planned in the middle of the financial year. The signatories advocate postponing the start to January 1, 2027, to “allow time for legally sound national implementation and transitional measures.”
The letter states: “From August 12, 2026, new EU definitions (including ‘producer’ and ‘manufacturer’) will apply, with major implications for the allocation of responsibilities within the extended producer responsibility (EPR) system. The obligation for companies to license packaging will shift, which could lead some currently obligated companies to suspend or reduce payments due to uncertainty over who will be responsible in the future.”
The associations also criticize the lack of legal clarity and uncertain national implementation timelines: “Until the end of 2026, the German Packaging Act will remain partially applicable. At the same time, the German transposition law is not expected to be available until mid-2026.”
Without clear definitions and responsibilities, the associations warn, there is a risk of duplicate contracts, uncertain financial flows, and increased bureaucracy. Municipal services such as waste consulting and container cleaning are particularly at risk.
The associations’ demand is clear: “Postponing the start of the new rules to January 1, 2027, would give all parties the necessary time to implement the new regulations in a legally sound and orderly manner.” Germany, they add, could take an active, coordinating role — especially since many other member states face similar challenges.
Brussels’ response arrived in October and left no room for doubt: the European Commission intends to stick to the planned start date in August 2026. According to Euwid, Environment Commissioner Jessika Roswall stated in a letter to an affected industry association and members of the German Bundestag that the new obligations under the EU Packaging Regulation would take effect as scheduled on August 12, 2026.
She described the much-criticized mid-year transition as “challenging” but at the same time opened the door to supporting measures. Member states will be granted some flexibility in 2026 to introduce corrective mechanisms addressing transitional problems during the shift in producer responsibilities and to ensure coordinated implementation.
Thus, the official timetable remains unchanged. “Implementation of the PPWR has already begun, and the Commission is coordinating with stakeholders to ensure timely execution,” the correspondence summary states. Brussels rejects any extension of the deadline. For companies, this means one thing: they must be ready by August 2026.
Author: Alexander Stark, Editor, FACHPACK360°
