Does the PPWR also apply to small agricultural businesses that only purchase for their own use?

Pure end users who obtain packaging exclusively for internal business consumption are generally not subject to the obligations of a person placing goods on the market under the PPWR. However, as soon as you resell goods in packaging or act as a contract packager, you become an economic operator and are subject to the relevant obligations. If in doubt, a review by the IHK is recommended.

Do pesticide canisters that already hold UN approval need to be additionally labelled under the PPWR?

Yes. The UN dangerous goods classification and the PPWR labelling are two independent requirements, both of which must be fulfilled. The PPWR labelling (recyclability, material type) is added supplementarily to the dangerous goods labelling. Manufacturers of plant protection product containers are obliged to adapt their labels accordingly. Please verify this at your next labelling update.

Is silage film exempt from the PPWR?

A complete exemption does not exist; however, the PPWR provides for simplified conditions for agricultural films where a proven take-back system exists. In Germany, this operates through recognised sector-based take-back schemes. Operations that demonstrably return their silage films through such a system and document this may benefit from simplified obligations. The precise thresholds and conditions should be clarified through the IHK or the competent sector association.

What happens if my packaging supplier has not yet implemented PPWR labelling?

As a person placing goods on the market, you bear responsibility for ensuring that the packaging meets the statutory requirements – regardless of whether your supplier takes action. Request written declarations of conformity from your suppliers and include contractual deadlines for PPWR-compliant conversion in new contracts. If suppliers fail to meet this obligation, you may need to change suppliers or retrofit the labelling yourself.

Branchenguide · PPWR

PPWR for Agriculture & Farming Operations: Packaging Obligations from 12 August 2026

With Regulation (EU) 2025/40 – the so-called Packaging and Packaging Waste Regulation (PPWR) – new, binding requirements for packaging and its labelling will enter into force on 12 August 2026, directly affecting agricultural and farming operations as well. Whether fertiliser packaging, pesticide canisters or seed bags: as a person placing goods on the market or a user of certain types of packaging, you must act now. This technical article explains what matters in practice.

What the PPWR Means Concretely for Agricultural Operations

The PPWR obliges all economic operators along the supply chain – including agricultural businesses, provided they place packaging on the market or act as the first entity to do so. In the agricultural sector, four packaging categories are particularly relevant:

1. Fertiliser Packaging

Sacks and big bags for mineral fertilisers, substrate mixes or organic fertilisers are subject to the new labelling obligations under Art. 11 PPWR from 12 August 2026. The packaging must bear a QR code or comparable digital element providing information on recyclability and material separation. Manufacturers and importers distributing fertilisers under their own labelling are directly affected. Practical tip: Coordinate early with your packaging supplier regarding which materials are classified as recyclable and whether the current print design has sufficient space for the QR code addition.

2. Pesticide Canisters and Hazardous Goods Packaging

Particular attention is required where the PPWR intersects with the Dangerous Goods Regulation (ADR/GGVSEB). Pesticide containers are frequently designed as UN-certified hazardous goods packaging. The PPWR applies additionally: it requires that these packaging types also meet the minimum recyclability requirements and are labelled accordingly. Since reuse obligations for hazardous goods containers are generally excluded for safety reasons, the need for action focuses on labelling and registration in the EU-wide packaging register (where you act as a person placing goods on the market). Practical tip: Check whether your suppliers are already implementing the new labelling requirements, and request written declarations of conformity.

3. Seed Bags

Seed bags – depending on size and material – fall under the single-use packaging rules of the PPWR. Plastic film bags made from non-recycled plastic will be subject to recyclate quotas in the medium term. For seed dealers and propagation businesses carrying out their own packaging operations, the following applies: the labelling rules must be complied with from 12 August 2026. Practical tip: Switch to paper or certified compostable plastic bags where the seed permits this – you will not only comply with the PPWR but also benefit from more favourable recycling classifications.

4. Silage Film

Silage films are a special case: as agricultural stretch films they are frequently classified as industrial packaging. The PPWR provides transitional arrangements and possible exemptions for certain agricultural films, provided that national take-back and recovery systems (e.g. the AgriRec association in Germany) can be demonstrated to function effectively. Practical tip: Register your operation with a recognised take-back system and document the quantities returned – this is a prerequisite for making use of any available exemptions.

General Obligations at a Glance

Labelling of all packaging with recycling information (QR code or pictogram) from 12 August 2026
Minimum recyclate content in plastic packaging according to a defined timetable
Registration obligation in the national packaging register (LUCID), if not yet completed
Documentation obligation for packaging quantities and disposal pathways

For legally sound advice on your specific individual case, please contact your responsible Chamber of Industry and Commerce (IHK). The IHK offers free initial consultations on PPWR obligations and can assess whether your operation is to be classified as a manufacturer, importer or user.

Häufige Fragen

Does the PPWR also apply to small agricultural businesses that only purchase for their own use?: Pure end users who obtain packaging exclusively for internal business consumption are generally not subject to the obligations of a person placing goods on the market under the PPWR. However, as soon as you resell goods in packaging or act as a contract packager, you become an economic operator and are subject to the relevant obligations. If in doubt, a review by the IHK is recommended.
Do pesticide canisters that already hold UN approval need to be additionally labelled under the PPWR?: Yes. The UN dangerous goods classification and the PPWR labelling are two independent requirements, both of which must be fulfilled. The PPWR labelling (recyclability, material type) is added supplementarily to the dangerous goods labelling. Manufacturers of plant protection product containers are obliged to adapt their labels accordingly. Please verify this at your next labelling update.
Is silage film exempt from the PPWR?: A complete exemption does not exist; however, the PPWR provides for simplified conditions for agricultural films where a proven take-back system exists. In Germany, this operates through recognised sector-based take-back schemes. Operations that demonstrably return their silage films through such a system and document this may benefit from simplified obligations. The precise thresholds and conditions should be clarified through the IHK or the competent sector association.
What happens if my packaging supplier has not yet implemented PPWR labelling?: As a person placing goods on the market, you bear responsibility for ensuring that the packaging meets the statutory requirements – regardless of whether your supplier takes action. Request written declarations of conformity from your suppliers and include contractual deadlines for PPWR-compliant conversion in new contracts. If suppliers fail to meet this obligation, you may need to change suppliers or retrofit the labelling yourself.

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