Is there a transition period after 12 August 2026?

There is no general transition period for new packaging. From 12 August 2026, packaging newly placed on the market must comply with the PPWR requirements. Only existing stock that was lawfully produced and labelled before that date may still be sold through.

What is the Sunrise Date for GS1 Digital Link?

The Sunrise Date for the mandatory use of the GS1 Digital Link standard is expected to fall on 1 January 2027. Until then, a ramp-up phase is envisaged during which conventional labelling will still be accepted under certain conditions.

From when do the minimum quotas for recycled content apply?

The first binding minimum quotas for recycled materials in packaging enter into force from 2030. However, from 12 August 2026, a documentation obligation regarding recycled content already applies. The quotas will increase again from 2040.

Do I need to re-register in LUCID?

No, re-registration is not generally required. However, existing LUCID registrations must be checked for compliance with the PPWR material classification and updated where necessary. The fundamental obligation to register before first placing packaging on the market remains unchanged.

Who bears the burden of proof in the supply chain?

The primary obligation to provide evidence rests with the economic operator placing the packaging on the market – i.e. the manufacturer or importer who first introduces the packaging onto the EU market. Suppliers are obliged to make declarations of conformity and technical documentation available upon request.

PPWR-Wissen

Deadlines & Transition Rules under the PPWR: What Applies When?

The EU Packaging and Packaging Waste Regulation (EU) 2025/40 – known as the PPWR – enters into force on 12 August 2026, without any general transition period for its core obligations. Manufacturers, importers, and economic operators placing products on the EU market must comply with the new requirements on labelling, recyclability, and minimum recycled content from that date. This article provides a structured overview of the key deadlines and obligations.

The Hard Deadline: 12 August 2026

Regulation (EU) 2025/40 applies from 12 August 2026 directly in all EU Member States – without any further national transposition act. From that date, new packaging placed on the market for the first time must comply with the PPWR requirements. There is no general transition period of the kind that was customary under earlier directives.

What Applies to Existing Stock?

For packaging lawfully placed on the market before 12 August 2026, a limited sell-off arrangement applies. Existing stock may still be sold through, provided it complies with the national rules in force up to that point. In practical terms, this means that packaging produced and labelled before the cut-off date does not have to be immediately destroyed or reprinted. The decisive point, however, is that from 12 August 2026 onwards, no new batches may be produced or imported under the old requirements.

Labelling Obligation and GS1 Digital Link: Sunrise Date 2027

The PPWR prescribes machine-readable labelling in accordance with the GS1 Digital Link standard for certain types of packaging. Full operation of this system is scheduled for the so-called Sunrise Date, expected to be 1 January 2027. Until then, a technical ramp-up phase applies: manufacturers who have not yet fully implemented GS1 Digital Link may provisionally use conventional barcodes with supplementary information, provided the substantive labelling requirements of the PPWR are already met. After the Sunrise Date, GS1 Digital Link will be mandatory for the affected categories.

Supply Chain Deadlines and Recycled Content

The requirements for minimum proportions of recycled materials are staggered by packaging type and material class:

From 12 August 2026: basic obligations to document recycled content for all affected packaging
From 2030: first binding minimum quotas for recycled content, e.g. 30% for plastic packaging (contact-sensitive applications excluded)
From 2040: increased quotas (up to 65% depending on category)

Within the supply chain, the primary obligation to provide evidence falls on the economic operator placing the packaging on the market – typically the manufacturer or importer. Suppliers must hold corresponding declarations of conformity and technical documentation, as these must be produced during market surveillance inspections.

LUCID Registration Obligation: What Is Changing?

The obligation to register in the German packaging register LUCID (Bundeszentralregister Verpackungen, operated by the Stiftung Zentrale Stelle Verpackungsregister – ZSVR) remains in force and is not superseded by the PPWR. However, from 12 August 2026 the following applies: the material categories and quantity data stored in the LUCID system must reflect the PPWR-compliant material classification. Existing registrations must be reviewed and updated where necessary. New market participants must register before first placing packaging on the market – this obligation already existed under the Packaging Act and remains unchanged under the PPWR.

Recommended Action

Review your packaging portfolios for PPWR compliance without delay: labelling content, material composition, and recyclability are the three central points of examination. For binding legal advice, contact your competent Chamber of Industry and Commerce (IHK) or a legal adviser specialising in product law.

Häufige Fragen

Is there a transition period after 12 August 2026?: There is no general transition period for new packaging. From 12 August 2026, packaging newly placed on the market must comply with the PPWR requirements. Only existing stock that was lawfully produced and labelled before that date may still be sold through.
What is the Sunrise Date for GS1 Digital Link?: The Sunrise Date for the mandatory use of the GS1 Digital Link standard is expected to fall on 1 January 2027. Until then, a ramp-up phase is envisaged during which conventional labelling will still be accepted under certain conditions.
From when do the minimum quotas for recycled content apply?: The first binding minimum quotas for recycled materials in packaging enter into force from 2030. However, from 12 August 2026, a documentation obligation regarding recycled content already applies. The quotas will increase again from 2040.
Do I need to re-register in LUCID?: No, re-registration is not generally required. However, existing LUCID registrations must be checked for compliance with the PPWR material classification and updated where necessary. The fundamental obligation to register before first placing packaging on the market remains unchanged.
Who bears the burden of proof in the supply chain?: The primary obligation to provide evidence rests with the economic operator placing the packaging on the market – i.e. the manufacturer or importer who first introduces the packaging onto the EU market. Suppliers are obliged to make declarations of conformity and technical documentation available upon request.

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