Must our IBC containers be designed as reusable from 2026 onwards?

The binding reuse quotas for IBC containers take effect in stages from 2030, not on the cut-off date of 12 August 2026. However, the recyclability obligations and the minimum requirements for packaging optimisation already apply on that date. It is nevertheless advisable to evaluate reuse systems now in order to meet the 2030 quotas without short-term investment pressure.

How does the PPWR interact with our hazardous goods packaging under ADR?

The PPWR contains no blanket exemption for hazardous goods packaging. The recyclability obligations apply there in principle as well, provided this is technically and legally feasible from a safety perspective. PPWR obligations supplement ADR/IMDG requirements – they do not replace them. Coordinate your dangerous goods officer and packaging manager and seek legal advice from your Chamber of Industry and Commerce if in doubt.

From when must our industrial packaging carry the new PPWR labelling system?

The harmonised mandatory labelling under the PPWR (material type, recycling information, reuse symbol) will become compulsory in stages from 2028. No new labelling obligations under the PPWR apply on the cut-off date of 12 August 2026. Use the transition period to adapt your labelling concepts and printing processes – especially where production start-up times in series manufacturing are long.

Branchenguide · PPWR

PPWR for Industry & Mechanical Engineering: Packaging Obligations from 12 August 2026

For companies in industry and mechanical engineering, the EU Packaging Regulation (EU) 2025/40 brings far-reaching changes to transport packaging, bulk containers and reuse systems. From 12 August 2026, binding requirements on recyclability, labelling and packaging minimisation will apply – including for purely industrial B2B supply chains. Those who act now will avoid costly retrofitting and safeguard their ability to deliver to customers and authorities alike.

What the PPWR Means for Industrial B2B Supply Chains

Regulation (EU) 2025/40 – the so-called Packaging and Packaging Waste Regulation (PPWR) – replaces the previous Directive 94/62/EC and, as an EU regulation, applies directly in all Member States. For companies in industry and mechanical engineering, the provisions on transport packaging, bulk containers and reuse systems are of particular relevance.

Transport Packaging: Understanding and Leveraging the EPR Exemption

A common misconception: Extended Producer Responsibility (EPR) does not apply to purely B2B transport packaging that is not passed on to end consumers. Pallets, stretch film, wooden crates and load carriers that remain exclusively within commercial goods flows and are demonstrably taken back within the company are exempt from the EPR reporting obligation. The key is a seamless record of return – document your internal processes carefully.

IBC Containers and Bulk Packaging: Reuse as a Mandatory Programme

The PPWR establishes binding reuse quotas for certain packaging categories from 2030. For Intermediate Bulk Containers (IBC) and bulk packaging in industrial use, it is advisable to establish reuse systems now in order to meet the transition deadlines without a backlog of investment. Check whether your existing IBC contracts already cover reconditioning cycles and return obligations – if not, contractual adjustments with suppliers and customers will be necessary.

Recyclability Requirements and Minimum Recycled Content

From 12 August 2026, all packaging placed on the market must meet the PPWR's recyclability criteria. For industrial packaging, this means in concrete terms: composite materials (e.g. coated metal containers, plastic-laminated composite pallets) must be assessed for their separability. From 2030, minimum requirements for the use of recycled content will also increase – graduated quotas apply to industrial plastic packaging. Commission your packaging suppliers now to provide declarations of conformity in accordance with the PPWR criteria.

Hazardous Goods Packaging: Note the Dual Regulation

Companies that package or transport hazardous goods are subject to ADR/IMDG/IATA regulations in addition to the PPWR. The PPWR contains no explicit hazardous goods exemption for primary packaging – the recyclability obligation therefore also applies here, to the extent technically and safety-technically feasible. Coordinate your compliance review between your dangerous goods officer and the person responsible for packaging.

Labelling Obligations from 2028

The PPWR introduces harmonised mandatory labelling: material type, recycling information and – for reusable packaging – a uniform reuse symbol. Plan your labelling and printing processes well in advance, as the changeover on packaging lines in series production may require considerable lead time.

Practical Tips for Industry & Mechanical Engineering

Start your inventory now: Categorise all packaging types (primary, secondary, tertiary/transport) and clarify EPR status.
Request supplier documentation: Ask your packaging suppliers to provide PPWR-compliant declarations of conformity now.
Create a reuse quota roadmap: Define internally which packaging streams will be converted to reuse by 2030.
Train purchasing and logistics departments: The classification of new packaging must in future take PPWR criteria into account.
Legally sound advice: Contact your local Chamber of Industry and Commerce – chambers offer free initial consultations on the PPWR and can provide sector-specific assessments that go beyond general information.

Häufige Fragen

Does Extended Producer Responsibility (EPR) also apply to pallets and stretch film that we use only internally?: No – purely B2B transport packaging that is not passed on to end consumers and demonstrably remains within or is taken back by the company is exempt from the EPR reporting obligation. The key is a seamless record of the return. Recommendation: document your return processes in writing and have the classification confirmed by your Chamber of Industry and Commerce.
Must our IBC containers be designed as reusable from 2026 onwards?: The binding reuse quotas for IBC containers take effect in stages from 2030, not on the cut-off date of 12 August 2026. However, the recyclability obligations and the minimum requirements for packaging optimisation already apply on that date. It is nevertheless advisable to evaluate reuse systems now in order to meet the 2030 quotas without short-term investment pressure.
How does the PPWR interact with our hazardous goods packaging under ADR?: The PPWR contains no blanket exemption for hazardous goods packaging. The recyclability obligations apply there in principle as well, provided this is technically and legally feasible from a safety perspective. PPWR obligations supplement ADR/IMDG requirements – they do not replace them. Coordinate your dangerous goods officer and packaging manager and seek legal advice from your Chamber of Industry and Commerce if in doubt.
From when must our industrial packaging carry the new PPWR labelling system?: The harmonised mandatory labelling under the PPWR (material type, recycling information, reuse symbol) will become compulsory in stages from 2028. No new labelling obligations under the PPWR apply on the cut-off date of 12 August 2026. Use the transition period to adapt your labelling concepts and printing processes – especially where production start-up times in series manufacturing are long.

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