Green claims are coming under regulatory scrutiny earlier than many companies expect. While the EU Packaging and Packaging Waste Regulation (PPWR) is often associated with the target year 2030, key requirements will apply much sooner. By 12 August 2026 at the latest – 18 months after the PPWR enters into force – initial obligations must already be implemented. Environmental claims, labelling, marking, and the handling of hazardous substances in packaging will be particularly affected.
These topics were also at the heart of a presentation by Peter Désilets, Managing Director and Co-Founder of Pacoon Sustainability Concepts, at the Solpack Forum during FACHPACK 2025. His key message: companies must review and adapt their packaging and related communication now.
The aim of the new requirements is to consistently prevent greenwashing. Environmental claims are considered greenwashing if they are misleading, vague, inaccurate, or not verifiable. This applies not only to text, but also to logos, symbols, images, or audiovisual advertising.
“For example, if you display a green leaf on your packaging but provide no sustainability context, you already have a problem. Anything that suggests sustainability without a factual connection should be reviewed or, ideally, removed,” advises Désilets.
Even statements that currently seem self-evident will be assessed more critically in the future. “Standard requirements such as the legally mandated recycled content under the PPWR will fall under this definition and may no longer be promoted. The same applies to self-evident product characteristics,” warns the Pacoon Managing Director.
Sustainability therefore remains a central communication topic in the packaging industry, as was recently evident at FACHPACK 2025. However, the scope for promotional claims is narrowing: “If companies cannot prove what makes them particularly sustainable, many of these claims will disappear,” predicts Désilets.
Green claims are currently governed by three regulatory frameworks: the Empowering Consumers Directive (applicable from September 2026), the PPWR (binding from August 2026), and the Green Claims Directive, which is unlikely to be implemented.
Even though requirements for recycled content and recyclability will only apply from 2030, the PPWR introduces concrete obligations as early as August 2026. Companies must assess whether packaging contains relevant substances, complies with limit values, and remains marketable.
“By August next year, companies must at least be able to explain in their conformity report whether hazardous substances are under control and limit values are being met,” says Peter Désilets.
Vague or blanket promises such as “climate neutral through compensation” will no longer be permitted. Only precise, substantiated, and certified claims will be allowed. Clear differentiation is also required: a product may be organic without its packaging or production being sustainable. Digital outsourcing of information will no longer suffice either.“A simple reference to a website along the lines of ‘you can read more there’ will no longer be acceptable. The information must be explained directly and clearly,” Désilets explains.
Future PPWR labelling requirements are particularly relevant for packaging companies. These include harmonised disposal instructions, material information, and clear differentiation between single-use, reusable, and deposit systems. From August 2026 onwards, packaging must also be clearly identifiable, for example through batch or serial numbers and information on the manufacturer or distributor.
Missing or incorrect labelling may prevent market access or lead to customs delays. The effort required for compliance is substantial. Many companies are currently revising thousands of artworks. Transport packaging must not be overlooked either, as missing registrations can delay supply chains and cause significant costs.
There is little time left until August 2026. What is required now is a systematic analysis of all packaging and environmental claims, a review of existing artworks, the consolidation of evidence and certifications, and a robust data basis for packaging and product information. A clear timeline and action plan are crucial. Those who start now will reduce regulatory risks and remain capable of acting under the new requirements.
Author: Alexander Stark, Editor FACHPACK360°
