Does the PPWR also apply to accessory packaging such as charging cable boxes or battery protective cases?

Yes. All packaging that arises at the end consumer or in the B2B sector and protects or transports a product falls under the PPWR. This also covers small accessory packaging such as boxes for charging cables or protective cases for batteries. The decisive criterion is whether the material primarily fulfils a packaging function.

Do we need to apply both the WEEE symbol and the new PPWR labelling to the same packaging?

Yes, both labelling requirements are mandatory independently of one another. The WEEE symbol on the device addresses the disposal of the electrical equipment itself, while the PPWR-compliant labelling (e.g. QR code with material information) concerns the packaging. A package may therefore simultaneously bear the WEEE symbol (if the device is visible within it) and the PPWR labelling.

From when exactly does the reuse obligation for heavy household appliances apply?

The PPWR (EU) 2025/40 provides for the reuse obligation for transport packaging of heavy household appliances from the year 2030. The precise quantity thresholds and technical specifications will be set out in delegated acts of the European Commission. Manufacturers and retailers should begin planning now, as reuse systems in the supply chain require considerable lead times.

Who bears legal responsibility: the manufacturer of the device or the importer of the packaging?

The PPWR is addressed primarily to the party that first places a product on the EU market – as a rule, the manufacturer or, for imports from third countries, the importer. For own-brand devices that are produced for you and distributed by you in the EU, you as the party placing the product on the market bear full responsibility for packaging compliance. For a legally sound assessment of your specific supply chain configuration, we recommend consulting your competent Chamber of Industry and Commerce (IHK).

Branchenguide · PPWR

PPWR for Electronics & Home Appliances: What Applies in Addition to the WEEE Symbol from 12 August 2026

Manufacturers and importers of electronics and home appliances have been familiar with the WEEE symbol and take-back obligations for waste electrical equipment for many years. With the Packaging and Packaging Waste Regulation (EU) 2025/40 – known as PPWR – an additional compliance layer comes into effect on 12 August 2026, specifically targeting the packaging of your products. This affects not only outer cartons, but also EPS inner cushioning, protective films, cable ties and fixing materials – materials that are particularly widespread in the electronics industry.

PPWR and WEEE: Two Systems, One Obligation

The WEEE symbol on your device governs the disposal of the product itself. The PPWR, by contrast, applies to packaging – and both requirements apply in parallel from 12 August 2026. This means: even if your product is already fully WEEE-compliant in its labelling, all primary, secondary and transport packaging must additionally meet the new PPWR criteria.

EPS Packaging: A Particular Challenge for the Industry

Expanded polystyrene (EPS) is widely used in the electronics industry due to its excellent shock-absorbing properties. The PPWR sets clear parameters here: EPS packaging must be designed to be recyclable, and the proportion of recycled content will be progressively increased. Assess now whether your existing EPS inlays meet the minimum recyclability requirements, or whether a switch to alternatives such as moulded cellulose or honeycomb paper is advisable.

Protective Films and Cable Ties Under PPWR Scrutiny

Small components such as protective films on displays, cable ties for cable management and fixing strips fall under the category of functional packaging and are likewise subject to the PPWR. The following applies to these materials:

Minimisation obligation: Use only as much packaging material as is strictly necessary to protect the product. Oversized protective film cuts or multiply-wound cable ties may be deemed unnecessary.
Labelling obligation: From 12 August 2026, packaging units must be fitted with a QR code or machine-readable data carrier containing information on material composition and recycling pathway.
Plastics minimisation: Single-use plastic components that primarily serve a packaging function must be reduced to the technically necessary minimum.

Heavy Appliances: Plan Now for the Reuse Obligation from 2030

For heavy household appliances such as refrigerators, washing machines and dishwashers, the PPWR provides for mandatory reusable transport packaging systems from 2030. This may seem a long way off – but it is not, when one considers the lead times required for logistics adjustments and supplier contracts. Recommendation: Begin the feasibility analysis for reusable transport packaging (e.g. plastic pallet systems, returnable cartons with collection logistics) now, to avoid time pressure by 2030.

Concrete Action Steps for Your Business

1. Conduct a packaging audit: Record all packaging types – from individual packaging to transport units – and assess recyclability and material labelling. 2. Evaluate EPS alternatives: Commission your packaging suppliers with a comparative analysis between EPS and more sustainable alternatives, taking into account your protection requirements. 3. Build a QR code system: Implement a digital solution for packaging labelling at an early stage, as this requirement calls for systemic infrastructure. 4. Involve the supply chain: Communicate the new requirements to your packaging suppliers and request compliance documentation. 5. Obtain legally sound advice: Your competent Chamber of Industry and Commerce (IHK) provides free and legally reliable consultation on the PPWR requirements for your specific product category. Make use of this service before restructuring internal processes.

Häufige Fragen

Does the PPWR also apply to accessory packaging such as charging cable boxes or battery protective cases?: Yes. All packaging that arises at the end consumer or in the B2B sector and protects or transports a product falls under the PPWR. This also covers small accessory packaging such as boxes for charging cables or protective cases for batteries. The decisive criterion is whether the material primarily fulfils a packaging function.
Do we need to apply both the WEEE symbol and the new PPWR labelling to the same packaging?: Yes, both labelling requirements are mandatory independently of one another. The WEEE symbol on the device addresses the disposal of the electrical equipment itself, while the PPWR-compliant labelling (e.g. QR code with material information) concerns the packaging. A package may therefore simultaneously bear the WEEE symbol (if the device is visible within it) and the PPWR labelling.
From when exactly does the reuse obligation for heavy household appliances apply?: The PPWR (EU) 2025/40 provides for the reuse obligation for transport packaging of heavy household appliances from the year 2030. The precise quantity thresholds and technical specifications will be set out in delegated acts of the European Commission. Manufacturers and retailers should begin planning now, as reuse systems in the supply chain require considerable lead times.
Who bears legal responsibility: the manufacturer of the device or the importer of the packaging?: The PPWR is addressed primarily to the party that first places a product on the EU market – as a rule, the manufacturer or, for imports from third countries, the importer. For own-brand devices that are produced for you and distributed by you in the EU, you as the party placing the product on the market bear full responsibility for packaging compliance. For a legally sound assessment of your specific supply chain configuration, we recommend consulting your competent Chamber of Industry and Commerce (IHK).

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