Do you ship or sell packaged goods in Germany or other EU countries? If so, new obligations may apply to your packaging. We guide you step by step through the key questions.
The Packaging and Packaging Waste Regulation (PPWR) governs the entire life cycle of packaging - from design and manufacture through use and labelling to reuse, recycling and disposal. It generally applies to all packaging and packaging waste placed on the EU market.
Avoid unnecessary packaging and packaging waste, promote reuse, refill and high-quality recycling, reduce the use of primary raw materials and substances of concern, and further harmonise differing national requirements to simplify the EU internal market.
11.02.2025
The PPWR enters into force.
from 2028
Introduction of harmonised European labelling for packaging (objective: harmonisation of labelling)
from 2030
Key requirements take effect, including recyclability, recycled content, packaging minimisation, empty space and reuse - depending on the packaging type and use case. Extensive documentation obligations apply, for example regarding the material composition of packaging.
from 2035
Packaging must additionally be demonstrably collected, sorted and recycled at scale.
by 2040
Further target levels for recycled content, waste prevention and reuse will be tightened gradually.
The PPWR sets requirements for packaging (e.g. recyclability and recycled content) and its documentation. EPR (Extended Producer Responsibility) covers, among other things, registration, volume reporting and payment of fees in the respective country.
Registration in the German LUCID packaging register does not automatically fulfil your obligations in other EU countries. All Member States establish their own rules, which must be followed. Any sanctions must also be defined by the Member States.
The EU institutions are currently discussing potential simplifications regarding the requirement to appoint an EPR authorised representative in the respective destination country for cross-border sales within the EU. It has not yet been finally determined which businesses may benefit from these changes and under what conditions. Until any such amendments take effect, the existing obligations remain applicable. For further information, please refer to the section Links to European Commission Documents below.
For standard DHL packaging, we provide the information required for your EPR reporting. Assessing your own role, countries and EPR obligations generally remains your responsibility. Further below, we list service providers, useful information sources and links to European Commission documents.
Create an overview of all packaging used.
Product packaging
The PPWR distinguishes between several legal roles, in particular producer, manufacturer, importer, distributor, authorised representative and - for extended producer responsibility - producer. Under Article 3 of the Regulation, your role depends, among other things, on who places the packaging or packaged product on the market under their own name or trademark, who imports it from a third country, who makes the packaging available on the market, where the company is established and in which Member State the packaging is first made available. Depending on the packaging, supply chain and sales channel, a company may have several roles at the same time. Therefore, assess your role separately for each packaging type and sales channel, including questions such as:
Who determines the design and material of the packaging - you or a packaging manufacturer?
Too complicated? Further below, we provide links to service providers and other useful sources.
Record all EU countries to which you sell or ship. Then assess EPR requirements for each country.
Material composition
Packaging weights
Recyclability
Recycled content
Test reports and specifications
All DHL packaging is suitable for compliant shipping. You can find all required data and conformity information here (only available in German).
Registration
Participation in a compliance scheme
Volume reporting
Fees
Where applicable, an authorised representative in the destination country
Regularly review new products, packaging, suppliers, destination countries and regulatory changes.
European packaging rules continue to evolve. Here you will find selected links that may be particularly relevant to companies shipping across EU borders.
The European Commission would like to temporarily suspend the obligation for certain EU companies to appoint an EPR authorised representative in every EU destination country. The proposal is still being considered by the European Parliament and the Council.
The European Commission is working on more harmonised formats for registration and reporting packaging volumes. However, a central European EPR register or mandatory one-stop shop has not yet been adopted.
The European Commission has clarified its PPWR information. Direct online sales to end customers in another Member State give rise to EPR obligations in the respective destination country. Further details on sanctions are provided in section XVI.1.
The mandatory EU pictograms and technical formats for harmonised packaging labelling have not yet been finalised.
DHL shipping materials (only available in German)
Technical documentations for DHL packaging (only available in German)
Guidance on secure packaging
Packaging assessment regarding protection against damage (only available in German)
Determine your own role
Assess your own packaging
Obtain supplier evidence
Assess EPR obligations for each destination country
Complete registrations and reports
Where applicable, appoint authorised representatives in the destination country
Keep evidence available
Specialised compliance service providers can support you, for example, with country assessments, registrations, volume reporting and documentation. Our customers use providers such as:
Support with packaging EPR, registration, volume reporting and international packaging licensing.
View provider: lizenzero.com/en/
Self-service and full-service EPR solutions, as well as support with PPWR readiness and documentation.
View provider: www.ecosistant.eu/en
In addition to the comprehensive service, under which ecosistant handles all administrative processes for you, a low-cost information and self-service option is also available. It provides information for each country and step-by-step guidance for implementing the requirements yourself.
Support with international EPR registrations, volume reporting and authorised representative solutions.
View provider: take-e-way.de/leistungen/ppwr-registrierung-bevollmaechtigter/
Note: The companies listed are examples of external providers, including providers mentioned by our customers. Their inclusion does not constitute a recommendation or certification by DHL.
PPWR - Regulation (EU) 2025/40
Binding EU Regulation: https://eur-lex.europa.eu/legal-content/DE/TXT/?uri=CELEX:32025R0040
European Commission
Information on the PPWR: https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste_en?prefLang=de
Central Agency Packaging Register
Information on packaging obligations: https://verpackungsregister.org
LUCID
German packaging register: https://lucid.verpackungsregister.org
Chamber of Commerce
The respective chambers of commerce provide information and advice on PPWR and EPR obligations, for example:
https://weltweit-erfolgreich.de/bayern/fokusthemen/erweiterte-herstellerverantwortung-epr-in-europa/
This page provides general guidance and does not constitute legal advice. Your specific obligations depend in particular on your role, the type of packaging, the flow of goods and sales channel, the destination country and the date on which the packaging is placed on the market. Consult official information and seek expert advice if you are unsure.