Companies now need to determine how they are affected by the PPWR. This includes obligations to ensure the recyclability for all packaging and to use recycled content in plastic packaging. While some details may still need clarification – forewarned is forearmed!

Extended producer responsibility – a backgrounder 
The Green Deal has charted the course, and Europe intends to become climate-neutral by 2050. To achieve this goal, the EU is calling for a sustainable closed-loop economy that handles resources efficiently. A key legislative instrument – extended producer responsibility (EPR) – is playing an important role in this context: its aim is to minimise the environmental impact of products and packaging, from design to take- back and recycling.

Who needs to take action? 
The provisions of the EPR affect all actors who market products in the EU – whether as a manufacturer, producer, (online) retailer or importer. Strict regulations are already in place for the material streams of packaging, electrical appliances and batteries. As of 2025, textiles are now also subject to an EU-wide separate collection rule.

What are the obligations for companies – in Germany, for example? 
In short: more transparency, less environmental impact. The rules applicable to distributors under the EPR policy include the following:

• EPR registration: Businesses must register with the relevant national authorities so that the origin and distribution channels of their products and packaging can be properly traced. In Germany, for example, the EPR number for packaging corresponds to the LUCID registration number recorded with the Central Agency Packaging Register (ZSVR).
• Cooperation with take-back systems and waste management companies: Distributors are responsible for the entire lifecycle of their products and packaging. Specifically, this means that they also bear the costs of take-back, sorting and recycling. In the case of sales packaging, this is regulated in Germany through participation in a dual system.
• Reporting duties: Companies must regularly report the quantities placed on the market to the relevant authorities and systems. Depending on the country, these reports must be submitted on an annual, quarterly or even monthly basis.

Packaging in the spotlight: what’s new in the PPWR? 
The Packaging and Packaging Waste Regulation (PPWR), which entered into force in early 2025, is an EU regulation that sets new and uniform standards for EPR while formulating clear targets on waste, including packaging recyclability. In 2024, Interzero organised a roadshow in four major German cities to inform businesses about the new requirements. Key aspects include:

• Recyclability: From 2030 onwards, all packaging must be reusable or recyclable. Packaging with a recyclability rate below 70% may no longer be placed on the market.
• Targets for recycled content: From 2030 onwards, the EU will impose minimum targets for the use of post-consumer recycled (PCR) materials in plastic packaging.
• Mandatory labelling: To simplify waste separation, disposal and recycling, standardised labelling requirements will be introduced for packaging.
• Eco-fee modulation: The fees payable within EPR systems will be more closely aligned with ecological criteria. Accordingly, fees charged for licensing or disposal will be inversely proportional to packaging recyclability. 

International aspects: 
Considerable effort has been made to harmonise packaging legislation within the EU. Nevertheless, regulations – and therefore compliance requirements – may still differ from one EU country to another, such as in terms of packaging licensing, existing eco-modulation models or specific requirements for packaging labelling. As a leading EPR service provider, Interzero helps its customers to stay on top of these developments and remain compliant with national regulations.