Manufacturers in the EU must design packaging to be resource-efficient to produce, and ensure that it is reusable or recyclable. They must issue a declaration of conformity regarding these and other properties. Despite the clear regulations, many questions remain unanswered, as a recent survey of members of the corporate network BAUM e. V. and other companies shows.
The survey, conducted on behalf of the Forum Ökologisch Verpacken, shows that companies generally welcome the objectives of the PPWR. They view the regulation as an important step towards a circular economy, intended to promote more and better recycling as well as a reduction in superfluous packaging. However, many departments are struggling with the details of implementation. The bureaucracy is perceived as overly burdensome, and many companies require external consultancy to provide the required data for the declarations of conformity. These declarations will be mandatory for all packaging in the EU from August 2026 and require comprehensive information on the recyclability, compostability and labelling of the packaging.
Uncertainties during implementation
In addition to the requirements of the PPWR, companies must also implement the new EU regulations on green claims (EmpCo) from September. This significantly increases the burden and ambiguity. A typical piece of feedback from the survey is: „The thing with the declarations of conformity is still too unclear, we don't know exactly how to make it legally compliant.“ Although industry associations, trade media and authorities are dealing with the topic intensively, only seven percent of companies feel confident regarding the specific requirements of the regulation.
Progress and challenges
Despite the challenges, work on implementing the PPWR is well underway. Around two-thirds of the surveyed companies are in the planning or implementation phase. Some have already implemented measures, including the reduction of packaging material, the switch to recyclable packaging, and the substitution of plastic. Fibre-based packaging such as paper, cardboard, or corrugated board is of particular focus, scoring well due to its circular properties. These materials require only five out of a total of eleven relevant declarations of conformity, which reduces the bureaucratic burden.
Mixed reactions from industry
Martin Oldeland, Deputy Chairman of BAUM, describes the economic sentiment as divided. While the PPWR is recognised as a legitimate instrument for promoting the circular economy, its implementation is assessed as organisationally demanding and legally ambiguous. The survey results confirm earlier assessments of the PPWR and illustrate the specific challenges facing businesses. The full results of the survey are available on the BAUM website. The corporate network was founded in 1984 as the „Bundesdeutscher Arbeitskreis für umweltbewusstestes Management“ by Hamburg entrepreneurs.
Source: BAUM e.V.







