2026-06-11
Companies in Germany are preparing for a major change in packaging rules as the European Union’s new Packaging and Packaging Waste Regulation, known as the PPWR, begins to apply on Aug. 12, 2026, bringing direct legal obligations for producers and importers without the need for a separate national law.
The regulation, identified as EU 2025/40, is already in force at the European level, but a transition period has delayed its practical application. From mid-August next year, businesses placing packaging on the market in Germany and across the European Union will have to meet a first set of mandatory requirements tied to conformity, documentation and labeling.
According to guidance published this week by the German law firm Reuschlaw, every type of packaging placed on the market from that date will need a valid EU declaration of conformity and technical documentation. The same first phase will also introduce stricter limits for hazardous substances, including PFAS in food packaging, and initial producer labeling duties.
The change matters across consumer goods industries, but it is especially relevant for wine, beer, spirits and other beverage companies because packaging is central to how those products move through supply chains and reach retailers. Bottles, cans, multipacks, shipping cartons and closures may all fall within the new compliance framework. For beverage operators in Germany, the rules could mean added work on traceability systems, label redesigns and supplier verification, with possible effects on costs and timelines.
The regulation is part of a broader European effort to reduce packaging waste and build a more circular economy based on reuse, recycling and lower resource consumption. Businesses are being given time to adapt through a phased rollout, but the first deadline is expected to trigger immediate operational changes because it applies directly to packaging introduced to the market from that day forward.
Reuschlaw said companies should begin by identifying their exact role in the supply chain. Under the PPWR, obligations differ depending on whether a business acts as a producer, importer or another type of economic operator. In international supply chains, one company may hold more than one role at the same time, which can expand its compliance burden.
The firm also said businesses should review their product portfolios carefully and distinguish between packaging types and packaging materials. As under earlier EU rules, the framework broadly separates sales packaging, grouped packaging and transport packaging, while also distinguishing components from materials. That distinction matters because suppliers of packaging materials will need to provide complete conformity evidence from August 2026.
A third area of preparation concerns what information must appear on packaging. For all packaging placed on the market from Aug. 12, 2026, producers will have to provide administrative details directly on the packaging. These include a unique type, batch or serial number for traceability; the producer’s name, registered trade name or registered trademark; and a postal address. A digital contact point must also be provided through an email address and/or a URL. The information may also be made digitally accessible through a QR code.
Importers will face their own marking duties from the same date. They will have to place their name, registered trade name or registered trademark and postal address on the packaging as well.
For beverage companies, those requirements may be particularly sensitive because many products already carry dense mandatory information tied to alcohol content, ingredients, deposits, recycling systems and market-specific labeling. Adding traceability identifiers and digital access points could require redesigns across bottle labels, can sleeves and secondary packaging. Importers of wines or spirits entering Germany from outside the bloc may also need to coordinate more closely with foreign suppliers to ensure that required information appears correctly before products are released onto the market.
Later stages of the PPWR are expected to arrive from 2028 onward through additional implementing acts that still need to be adopted at the EU level. Those later measures are expected to cover minimum recycled content in packaging as well as harmonized rules on recycling labels and recyclability standards.
That later timeline gives companies some room to plan for structural changes in sourcing and package design. But lawyers and compliance advisers say the August 2026 phase should not be treated as minor because it creates baseline legal conditions for market access. Technical files must be assembled in advance, supplier documentation must be checked and packaging layouts may need to be updated months before products are shipped.
In Germany, where beverage producers range from large brewing groups to family-owned wineries and mineral water bottlers, preparation may vary widely depending on company size and export exposure. Larger operators often already manage complex labeling systems across several markets. Smaller businesses may face a steeper adjustment if they rely on external suppliers for bottles, labels or transport materials and have limited internal compliance staff.
The legal shift also comes as food and beverage companies across Europe face broader pressure on packaging strategy from sustainability targets, deposit-return systems and consumer scrutiny over waste. The PPWR adds another layer by tying environmental policy more closely to product documentation and identification requirements at unit level.
Reuschlaw said companies should not wait until summer 2026 to act because preparing technical documentation, negotiating with international suppliers and changing packaging layouts can take months. For drinks businesses that work with seasonal production cycles or long lead times for printed labels and imported glass, that warning may prove especially important as the deadline approaches.