In his presentation at Future Resources 2025 in Cologne, Dr Markus W. Pauly, lawyer and partner at the law firm PAULY Rechtsanwälte, showed just how far-reaching the new EU Packaging Regulation (PPWR) will be for existing structures.

With legal precision and a twinkle in his eye, Pauly explains why the regulation - although it is formally an EU regulation - contains numerous elements of a directive and therefore plays a hybrid role between EU and national law. This means that although the PPWR comes into force directly in all member states, many details first have to be specified in national implementation laws - which have not yet been passed.

Pauly provides an overview of key definitions such as the concept of packaging, which will be defined much more broadly in future - including permeable tea bags or coffee capsules, which will be considered packaging for the first time. He also explains the legal distinction between „producer“ and „manufacturer“ and why this issue will be decisive for liability and obligations in practice.

In addition to formal aspects, Pauly deals with the substantive obligations of the PPWR: substance bans such as PFAS, minimum recyclate content for plastic packaging, the requirements for recyclability, minimisation of packaging and reusable quotas. He emphasises the uncertainty of many companies that are still waiting for national implementation regulations - and are also under time pressure: This is because the first regulations will become binding from 12 August 2026.

The presentation thus provides a clear legal compass in an increasingly complex regulatory environment - and shows why packaging manufacturers, brands and retailers should urgently address the upcoming obligations now.

The recording was made as part of Future Resources 2025, organised by Interzero and packaging journal in cooperation with interpack.