Compliance Briefing for US Companies

PPWR compliance for US companies selling into Germany.

Regulation (EU) 2025/40 — the PPWR — applies from 12 August 2026. For a US company entering Germany, the practical question is not what the regulation says, but what must be done before the first shipment: PFAS, EPR, LUCID, labelling and the 2030 design roadmap.

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Packaging is one compliance item inside a bigger decision. If you are weighing up the German market as a whole, start with the Germany market entry strategy or the costs and timeline for US companies.

Deadlines

The PPWR timeline at a glance

11 Feb 2025PPWR enters into force
12 Aug 2026Regulation applies; Directive 94/62/EC repealed; PFAS restriction for food-contact packaging
12 Aug 2028Harmonised material and sorting labelling becomes mandatory
1 Jan 2029Deposit return systems for plastic bottles and metal cans; 90 percent separate collection
1 Jan 2030Design-for-recycling, recycled content, minimisation and empty space limits, format bans, reuse targets
2035 / 2040Recyclability at scale; higher recycled-content thresholds

Free download

The PPWR Readiness Checklist — one page, 20 checks

A printable one-pager to walk through with your packaging, supply chain and legal contacts: scope and responsibility, the Day-1 PFAS and EPR obligations, design for recyclability, labelling and documentation, and the commercial consequences.

Covers the 12 Aug 2026, 12 Aug 2028 and 1 Jan 2030 milestones
Written for companies selling into Germany and the wider EU
PDF, one page, no newsletter subscription

For US companies

From first shipment to full compliance: the 90-day PPWR roadmap

Packaging compliance is a launch precondition, not a post-launch task. This is the practical sequence for US companies entering Germany, mapped to the dates that matter.

Request the roadmap US expansion timeline and costs

Confirm entry mode

Cross-border, German fulfilment, or local entity. This determines who holds the EPR obligation and who can register in LUCID.

Appoint an authorised representative

Non-EU producers must have an authorised representative in Germany for packaging EPR. Marketplaces and customs authorities will ask for it.

LUCID registration + dual-system contract

Register in the LUCID packaging register and license packaging with a dual-system operator before the first shipment lands.

Close the PFAS gap for food contact

Intentionally added PFAS in food-contact packaging is banned from 12 August 2026. Get supplier declarations now.

Map the 2028 and 2030 design deadlines

Labelling changes in 2028 and design-for-recycling rules in 2030 should enter your product roadmap this year.

Get the roadmap

Request the 90-day PPWR roadmap

Tell me what you are shipping and where you stand. I'll send you a tailored 90-day action plan for PPWR compliance and German market entry — plus the one-page checklist.

Tailored to your product category and entry mode
Includes LUCID, EPR, PFAS and 2030 design steps
No obligation — reply to unsubscribe at any time

Contents

Ten questions, answered

01What is the EU Packaging Regulation and what changes on 12 August 2026?
02Who is affected — and does it apply to US companies selling into the EU?
03What is the PFAS restriction that starts on 12 August 2026?
04What do the recyclability and recycled-content rules require?
05How do the packaging minimisation and empty space rules affect e-commerce?
06What labelling will be required on packaging?
07Which packaging formats are banned, and what about reuse and deposits?
08How does this interact with the German VerpackG and LUCID?
09What should a US brand do in the next 90 days?
10How does PPWR compliance fit into a US company's first 90 days in Germany?

What is the EU Packaging Regulation and what changes on 12 August 2026?

One European rulebook replaces 27 national interpretations — and it applies directly, without transposition.

EU packaging regulation 2026

Short answer

The EU Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, applies from 12 August 2026 and replaces Directive 94/62/EC. From that date one directly applicable European rulebook governs packaging design, recycled content, labelling, reuse and producer responsibility across all 27 member states.

The PPWR was published in the Official Journal in January 2025 and entered into force on 11 February 2025, with a general application date of 12 August 2026. Unlike the directive it replaces, it does not need to be transposed into national law: it binds companies directly, in the same wording, in every member state.

That is the structural change worth planning around. Until now, a brand selling into Germany, France and Spain dealt with three national packaging laws that agreed on principles and disagreed on detail. From August 2026 the substantive requirements are harmonised, while registration, fees and enforcement stay national — in Germany through the VerpackG, the LUCID register and the Zentrale Stelle Verpackungsregister.

Most of the hard numerical targets do not bite in 2026. They arrive on staged deadlines up to 2030, 2035 and 2040. What 2026 does is fix the framework, start the clock, and switch on the first substantive restriction: PFAS in food-contact packaging.

The essentials

Regulation (EU) 2025/40, in force since 11 February 2025
Applies from 12 August 2026; Directive 94/62/EC is repealed
Directly applicable — no national transposition needed
National registers and EPR fees continue to apply on top

Who is affected — and does it apply to US companies selling into the EU?

The obligation follows the packaging into the market, not the company that shipped it.

PPWR requirements for US companies

Short answer

The PPWR applies to anyone placing packaged goods on the EU market: manufacturers, importers, distributors, brand owners, marketplaces and fulfilment providers. Location is irrelevant. A US company shipping direct-to-consumer into the EU is a producer under the rules and needs an authorised representative for producer responsibility in each member state it sells into.

If your product arrives in an EU customer's hands in a box, a bag, a bottle or a blister, you are in scope. So is the shipping carton, the pallet wrap, the void fill and the label. The regulation covers primary, grouped, transport and e-commerce packaging alike, and it covers service packaging handed over at the point of sale.

For companies without an EU establishment, the practical entry point is extended producer responsibility. You cannot register yourself from abroad in most member states; you appoint an authorised representative established in that country, who registers on your behalf, files volume reports and pays the licensing fees to a compliance scheme. In Germany that means LUCID registration plus a contract with a dual system before the first parcel ships.

Marketplaces such as Amazon and Otto are legally obliged to verify that their sellers are registered. In day-to-day reality this is where non-compliance surfaces first: the listing is blocked, not the shipment.

Who carries the duty

Brand owners and manufacturers placing packaged goods on the EU market
Importers and distributors, including cross-border D2C sellers
Online marketplaces and fulfilment service providers with verification duties
Non-EU producers via an authorised representative per member state

US expansion to Germany: costs, timeline and steps →

What is the PFAS restriction that starts on 12 August 2026?

The one substantive restriction that takes effect on day one — and it hits food service and food retail packaging hardest.

PFAS food contact packaging ban EU

Short answer

From 12 August 2026 food-contact packaging may not be placed on the EU market if it contains intentionally added PFAS above the thresholds set in the regulation. This affects grease-resistant paper, moulded fibre bowls, coated cartons, baking papers and similar barrier applications.

Per- and polyfluoroalkyl substances are used to give paper and fibre packaging grease and water resistance. The PPWR prohibits placing food-contact packaging containing intentionally added PFAS on the market above the concentration limits defined in the regulation, with effect from 12 August 2026.

Practically, this means burger wraps, fries bags, moulded fibre bowls, pizza box liners, microwave popcorn bags, coated paper cups and comparable barrier packaging need documented PFAS-free alternatives — and documentation from suppliers, not verbal assurance.

Ask suppliers for declarations of compliance that name the substance groups and the test methods used. If your packaging is bought through a converter or a co-packer, the declaration has to trace back to the coating, not stop at the converter.

Action items before August 2026

Inventory every food-contact SKU with a grease or moisture barrier
Request supplier declarations covering intentionally added PFAS
Qualify replacement materials early — validation takes longer than sourcing
Keep test evidence on file; enforcement is document-driven

What do the recyclability and recycled-content rules require?

2030 is the design deadline — which for most packaging development cycles means the decision happens in 2027 or 2028.

PPWR recyclability requirements

Short answer

From 1 January 2030 all packaging placed on the EU market must be designed for recycling under harmonised criteria and graded by performance class; packaging below the threshold may no longer be sold. Plastic packaging must also contain minimum recycled content, with higher targets from 2040.

The regulation introduces design-for-recycling criteria with performance grades. From 2030, packaging that does not meet the minimum grade cannot be placed on the market; from 2035 the bar rises to packaging that is recyclable at scale. Multi-material laminates, dark carbon-black plastics, full-body shrink sleeves and non-separable barrier layers are the usual casualties.

For plastic packaging, minimum recycled-content shares apply per packaging type from 2030, with a further increase in 2040. Contact-sensitive applications such as food packaging have their own, lower thresholds, reflecting the availability of food-grade recyclate.

The commercial consequence is that recyclability moves from a marketing attribute to a market-access condition — and EPR fees are increasingly eco-modulated, so poor design gets priced as well as regulated.

Design decisions to start now

Mono-material structures instead of multi-layer laminates
Detachable labels, sleeves and closures that survive sorting
Avoid carbon black and full-body sleeves that defeat NIR sorting
Secure recyclate supply contracts before 2030 demand tightens

How do the packaging minimisation and empty space rules affect e-commerce?

For cross-border D2C brands this is the rule with the most direct operational impact.

e-commerce packaging empty space rule EU

Short answer

From 1 January 2030 grouped, transport and e-commerce packaging must keep the empty space ratio at or below 40 percent, and all packaging must be minimised to the weight and volume needed for function, safety and consumer acceptance. Double-walled boxes, oversized cartons and decorative void fill come under pressure.

The regulation requires packaging to be reduced to the minimum necessary for functionality, product protection, safety and hygiene, and it explicitly targets packaging designed to appear larger than the product requires — including false bottoms and misleading double walls.

For e-commerce, the empty space ratio applies to the shipping unit. Meeting it usually means more carton sizes, right-sizing at the pack station, and reviewing whether protective fill is genuinely load-bearing or simply habit.

This also has a cost upside. Right-sizing reduces volumetric shipping weight, which for transatlantic and intra-EU parcel flows is often the largest single line in the landed cost of a D2C order.

What to review in fulfilment

Carton range and right-sizing logic at the pack station
Empty space ratio measured per shipping unit, not per SKU
Void fill: load-bearing function versus presentation
Any packaging whose size implies a larger product than delivered

What labelling will be required on packaging?

Artwork changes come with a two-year runway — plan them into the next scheduled print cycle, not a separate project.

PPWR packaging labelling requirements

Short answer

Harmonised material composition and sorting labels become mandatory from 12 August 2028, using pictograms defined in Commission implementing acts. Reusable packaging and packaging in deposit return systems carry their own marks, and labels may be applied digitally via QR or data carrier where the acts allow.

Packaging placed on the market from 12 August 2028 must carry harmonised labelling indicating material composition to support correct sorting by consumers. The exact pictograms and formats are set in implementing acts that follow the regulation.

Separate marks apply to reusable packaging and to packaging covered by a deposit return system. National labels that duplicate or contradict the harmonised scheme are to be phased out, which removes some of today's country-by-country artwork variation.

The cost driver is not the label itself but the artwork cycle. Brands with dozens of SKUs and multi-country artwork should fold PPWR labelling into an already-planned redesign rather than running a stand-alone revision.

Labelling checklist

Harmonised material and sorting labels from 12 August 2028
Distinct marking for reusable and deposit packaging
Watch the implementing acts for final pictogram specifications
Bundle changes into the next scheduled artwork cycle

Which packaging formats are banned, and what about reuse and deposits?

The bans are format-specific and mostly land in 2030 — but they invalidate packaging concepts being designed today.

single use plastic packaging ban 2030 EU

Short answer

From 1 January 2030 several single-use plastic formats are prohibited, including grouped shrink wrap for multipacks, single-use plastic for fresh fruit and vegetables under 1.5 kg, hotel miniature toiletries and single-use packaging for food and drink consumed on premises. Reuse targets apply to transport and some beverage packaging, and member states must run deposit return systems for plastic bottles and metal cans by 2029.

Annex V of the regulation lists prohibited single-use packaging formats with effect from 1 January 2030. The list is concrete rather than principle-based: shrink-wrapped multipacks, plastic packaging for small quantities of unprocessed fresh produce, miniature cosmetic packaging in hospitality, and single-use packaging used to serve food and drink consumed inside a restaurant or café.

Reuse and refill targets apply from 2030 to transport and sales packaging in defined categories, with beverage sectors carrying specific quotas and some exemptions negotiated during the legislative process. Systems for pooling, return and washing are the practical bottleneck, not the packaging itself.

Member states must operate deposit return systems for single-use plastic bottles and metal beverage containers by 1 January 2029, reaching a 90 percent separate collection rate. Germany's Pfand system is already there; several other markets will build theirs from scratch, which changes barcode, labelling and pricing setups for anyone selling beverages across borders.

Formats to design out

Shrink wrap holding multipacks together
Single-use plastic for fresh produce below 1.5 kg
Hotel and hospitality miniature toiletries
Single-use serviceware for on-premises consumption

How does this interact with the German VerpackG and LUCID?

European harmonisation does not remove the national paperwork — in Germany it is still the first thing that blocks a launch.

VerpackG LUCID registration

Short answer

The PPWR harmonises requirements, but German registration duties remain: producers must register packaging in the LUCID register of the Zentrale Stelle Verpackungsregister and license it with a dual system before the first shipment. Selling unregistered packaging in Germany carries a de facto sales ban and marketplace delisting.

Anyone who first places packaged goods on the German market — including a US company shipping direct to German consumers — must be registered in LUCID before the first parcel ships, and must license the packaging volumes with a dual system such as Der Grüne Punkt, Interseroh or Landbell.

Registration is free and fast; the licensing fees scale with material type and tonnage and are increasingly eco-modulated, so recyclable mono-material packaging is cheaper to license than composite structures.

The German-specific traps are the same ones that appear in most market-entry projects: registering the brand name exactly as it appears on the packaging, reporting volumes on time, and remembering that shipping cartons and void fill are licensable packaging too, not just the retail box.

German compliance sequence

LUCID registration under the brand name shown on the packaging
Dual system contract covering all licensable volumes
Volume reporting to the register and the system on schedule
Include transport packaging and service packaging, not just primary

LUCID registration steps for US sellers →

What should a US brand do in the next 90 days?

Two deadlines are near-term. The rest is a design and artwork roadmap you set now and execute on your own print cycle.

PPWR compliance checklist

Short answer

Build a packaging inventory, close the PFAS gap for food-contact items before 12 August 2026, confirm EPR registration and an authorised representative in every EU market you sell into, then plan design and artwork changes against the 2028 labelling and 2030 design deadlines.

Days 1-30: list every packaging component per SKU, per market, with material, weight and supplier. Most compliance problems are visibility problems first — nobody owns the full packaging bill of materials.

Days 31-60: close the two near-term items. Confirm PFAS status for every food-contact item and confirm EPR registration and authorised representation in each EU market you ship to, Germany included.

Days 61-90: map the staged deadlines onto your own artwork and tooling cycles — labelling in 2028, design-for-recycling, recycled content, empty space and format bans in 2030 — and decide which changes ride along with already-planned redesigns.

The 90-day sequence

Packaging inventory per SKU and per market
PFAS gap closed for food-contact packaging
EPR registration and authorised representative confirmed
Deadline map merged into existing design and print cycles

Build the wider market entry strategy →

How does PPWR compliance fit into a US company's first 90 days in Germany?

Packaging is one of the operational items that blocks a German launch if it is treated as a legal afterthought.

PPWR compliance US companies Germany

Short answer

For a US company entering Germany, packaging compliance is a launch precondition, not a post-launch task. The sequence is: decide the entry mode, confirm VAT and EPR obligations, appoint an authorised representative, build the packaging inventory, and close the PFAS and LUCID gaps before the first shipment.

US companies often discover packaging compliance after the warehouse is stocked and the marketplace listing is live. That is the expensive version. The cheaper version is to treat PPWR and the German VerpackG as part of the same readiness checklist as VAT, product labelling and imprint.

The practical sequence starts with the entry mode. If you ship direct-to-consumer from a US warehouse, you still need an authorised representative in Germany and LUCID registration before the first parcel. If you use a German fulfilment centre or a local GmbH, the same duties apply, but the local entity can sometimes simplify registration and reporting.

The next step is a packaging inventory. List every packaging component that touches a German customer — primary packaging, shipping carton, void fill, tape, labels, pallet wrap — with material type, weight and supplier. This is the document that feeds LUCID reporting, dual-system licensing and the PPWR design roadmap.

Close the 2026 gaps first: PFAS documentation for food-contact packaging and EPR registration. Then schedule the 2028 labelling and 2030 design work into the product roadmap. Most of the 2030 changes are material decisions that have to be made in 2027 or 2028, so the only mistake is starting too late.

US market-entry checklist

Confirm entry mode: cross-border, German fulfilment, or local entity
Appoint authorised representative for EPR in Germany
LUCID registration before first shipment
Packaging inventory with material, weight, supplier per SKU
PFAS documentation for food-contact packaging
Dual-system contract for packaging waste licensing

US expansion to Germany: costs and timeline →

FAQ

Questions companies ask about the PPWR.

When does the EU Packaging Regulation apply?

Regulation (EU) 2025/40 (PPWR) entered into force on 11 February 2025 and applies from 12 August 2026. From that date it replaces the old Packaging and Packaging Waste Directive 94/62/EC as directly applicable law in every EU member state. Further obligations phase in up to 2030, 2035 and 2040.

Is the PPWR a regulation or a directive — does that matter?

It matters a lot. The predecessor was a directive, transposed into 27 different national laws. The PPWR is a regulation: it applies directly and identically in every member state. National rules such as the German VerpackG remain relevant for registration and enforcement, but the substantive packaging requirements are now European.

Does the PPWR apply to US companies selling into the EU?

Yes. The rules follow the product, not the seller's location. If you place packaged goods on the EU market — including direct-to-consumer shipments and marketplace sales — you must meet PPWR requirements and, as a producer without an EU establishment, appoint an authorised representative for extended producer responsibility in each member state you sell into.

What changes for packaging on 12 August 2026 specifically?

The regulation becomes the applicable legal framework, the old directive is repealed, and the restriction on intentionally added PFAS in food-contact packaging above the defined thresholds takes effect. Most design, recycled-content, minimisation and reuse targets apply later, mainly from 2030.

What is the empty space rule for e-commerce packaging?

From 1 January 2030 grouped, transport and e-commerce packaging must not exceed an empty space ratio of 40 percent, and packaging must be minimised in weight and volume to what is needed for function and safety. Oversized boxes with void fill are the classic failure case.

Do US companies need to register packaging in Germany before selling?

Yes. Before placing any packaged goods on the German market, a producer must register in the LUCID packaging register and contract with a dual system. Non-EU companies without a German establishment must appoint an authorised representative to handle this. Selling without registration is effectively a sales ban and marketplaces will delist unregistered sellers.

What is the cost of PPWR compliance for a small US brand entering Germany?

The administrative cost is modest: LUCID registration is free, and dual-system licensing fees scale with packaging weight and material, typically a few hundred to a few thousand euros per year for small brands. The larger costs are operational: redesigning packaging for recyclability, switching PFAS-containing food-contact materials, updating artwork for harmonised labels, and setting up an authorised representative. Plan for those as part of the market-entry budget, not as a compliance line item.

Can a US company use the same packaging it sells in the United States?

Not without review. US packaging rules do not align with EU requirements on PFAS restrictions, recyclability design, recycled-content quotas, and labelling. A packaging concept that is legal in the US may still fail EU market access, especially if it uses intentionally added PFAS in food contact or contains materials that are not recyclable under EU criteria.

Sources

Where this comes from

This briefing is general information, not legal advice. Deadlines and thresholds are set out in the regulation and refined through Commission implementing acts — check the current text for your specific packaging category.

Keep reading

Packaging is one line item. Here is the rest of the entry.

Germany market entry strategy →Entry mode, beachhead, pricing, channels and a 90-day roadmap for US companies.US expansion: costs and timeline →Entity costs, VAT, hiring costs and the sequence from decision to first revenue.Full DACH market-entry guide →The complete guide to selling into Germany, Austria and Switzerland.Hiring in Germany →What it takes to put a first commercial hire on the ground in Germany.

Next step

Not sure where your packaging stands?

Packaging compliance is one part of a German market entry — alongside VAT, registers, localization and the first local hires. A short call is usually enough to see whether you have a gap.

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