What does the PPWR mean for Commercial Packaging?

The new EU Packaging and Packaging Waste Regulation (PPWR) brings commercial, trade, and industrial packaging into the scope of extended producer responsibility (EPR), which previously largely excluded non‑household packaging.

Contrary to prior exemptions for packaging not directly related to households, the PPWR now subjects such commercial packaging to broader regulatory obligations under the responsibility of the producers.

The German Federal Association for the Waste, Water and Circular Economy (BDE) warns that this expansion may result in unnecessary over‑regulation. The BDE emphasizes that Germany already has an effective and functioning waste management infrastructure, and that there is no essential need for additional requirements specific to commercial packaging.

According to the BDE’s position, existing take‑back systems are organized on a market basis, are widely available nationwide, and operate efficiently with minimal bureaucracy. Introducing additional reporting or documentation obligations, or even new producer organisations with financial guarantees—as could be derived from the PPWR—would only increase costs and administrative burden without corresponding benefits.