Effective August 12, 2026, Brussels is tightening packaging regulations within the EU. At that time, the Packaging and Packaging Waste Regulation (PPWR) will become directly applicable in all Member States. In Germany, it will supersede key provisions of the existing Packaging Act. The EU justifies this move by citing the need to foster a circular economy, boost recycling, and reduce packaging waste. However, this entails new administrative burdens for manufacturers, distributors, and importers. Consequently—and particularly for small and medium-sized enterprises (SMEs) engaged in international business—this means anticipating new registration requirements, documentation obligations, the need for authorized representatives, and increased costs. (deloitte: 22.05.26)
Packaging Regulation Directly Impacts Business Processes
The PPWR differs from previous EU directives. It applies directly and does not require traditional national transposition. Consequently, the Member States’ scope for maneuver regarding key packaging issues is reduced.
Germany will continue to apply the Packaging Act until the designated deadline. Thereafter, EU regulations will play a more dominant role in the day-to-day operations of many businesses. Furthermore, packaging is to be recorded, assessed, and recycled in a more standardized manner. However, large corporations are better positioned to manage this transition with ease.
International Business Becomes More Costly for Small Providers
These new regulations hit retailers engaged in cross-border sales particularly hard. While large providers utilize their own internal infrastructure, small businesses often require external assistance. Consequently, operating without a physical branch in the target country incurs additional costs—even before the first sale is made.
Authorized representatives or external service providers handle the necessary registrations and liaise with regulatory authorities. Additionally, fees are incurred for ongoing reporting and compliance documentation. As a result, a small EU market can quickly become unprofitable for niche providers. Consumers, in turn, feel the impact through a reduced range of product choices.
Bureaucracy Ties Up Personnel Instead of Creating Value
The Packaging Ordinance hits the economy at a time of already heavy administrative burdens. The ifo Institute estimates bureaucratic costs in Germany at around 146 billion euros per year. Moreover, new administrative requirements tie up personnel that businesses urgently need elsewhere.
The Institute for Employment Research (IAB) cites a need for approximately 325,000 additional workers over a three-year period. However, these employees are effectively missing from the fields of production, development, and sales. As a result, companies lose momentum, profitability, and competitiveness.
SMEs Bear the Costs of New EU Directives
The Packaging Ordinance is part of the Green Deal initiative. By 2030, packaging is intended to be more recyclable and circular in nature. From a political standpoint, this objective remains understandable. Nevertheless, its implementation places a heavy strain on many businesses operating with tight margins.
Germany is already grappling with high energy prices, a weak industrial sector, and rising labor costs. Furthermore, new reporting obligations drive up fixed costs. Consequently, the competitive gap widens between domestic firms and competitors operating under less stringent regulatory regimes. Yet, in the absence of simplified procedures, it is small and medium-sized enterprises (SMEs), employees, and consumers who ultimately pay the price.