What happens if I do not comply with the PPWR? What penalties am I facing?

From 12 August 2026, Regulation (EU) 2025/40 becomes mandatorily applicable. Infringements of PPWR labelling obligations are pursued by national market surveillance authorities – in Germany these are the Länder authorities, coordinated through the Federal Office of Consumer Protection and Food Safety (BVL).

What specific sanctions are threatened?

The Regulation obliges Member States to establish effective, proportionate and dissuasive sanctions. The German legislator is oriented towards a fine framework of up to EUR 100,000 per infringement. Repeated or serious infringements may attract higher penalties, provided national implementing legislation so provides.

In addition to fines, the following measures are possible: - Distribution bans: Products without compliant PPWR labelling (QR code with recycling information, recycled content declaration, material code) may no longer be placed on the market. - Recall and market withdrawal: Authorities may order the recall of products already in circulation. - Reputational damage: Infringements are published in the EU-wide RAPEX/Safety Gate system.

Who carries out inspections?

Market surveillance authorities carry out spot checks – both at manufacturers and in trade. Packaging without machine-readable GS1 Digital Link QR codes or missing recyclability declarations constitutes an infringement.

Note: For a binding legal assessment of your specific products and packaging, please contact your local Chamber of Industry and Commerce (IHK) or a lawyer specialising in packaging law.