The Economic Association of the German Rubber Industry (WdK) is calling for eased requirements under the European Packaging and Packaging Waste Regulation (PPWR) for transport packaging in the B2B sector. The association is particularly critical of labelling, documentation and registration obligations, and is proposing a „green gate approach“ whereby transport packaging would only need to be recorded and labelled once.
According to the WdK, numerous requirements of the PPWR are geared towards the consumer goods sector and are unsuitable for shipping between industrial companies. In particular, medium-sized companies in the rubber industry are complaining about additional bureaucracy for packaged consignments, the association announced at the start of the mandatory application of the PPWR on 12 August 2026.
The burdens mentioned by the WdK include labelling and documentation requirements, mandatory conformity assessment procedures, monitoring requirements and registration obligations for dispatch abroad. According to the association, these requirements also apply to deliveries between different operating sites of the same company and to the reuse of packaging that has already been used.
WdK calls for exemptions for B2B transport packaging
„The PPWR targets the consumer goods sector and is not suited for shipping between industrial companies (B2B). It is like having to force your foot into a shoe that is two sizes too small: it pinches everywhere, and causes more trouble than it's worth,“ says Boris Engelhardt, General Manager of the WdK.
The association is therefore calling for the PPWR to be adapted to the specific characteristics of transport packaging in B2B shipping. According to the WdK, companies with an annual consumption of less than ten tonnes of shipping packaging in the B2B sector should be exempt from the regulations.
„What we all find most astonishing, however, is that the EU and now also the German Federal Government are bringing the packaging regulation into force as a binding requirement for businesses, even though they have not yet clarified many details themselves. After all, the EU has already announced up to 80 further delegated acts to shape the PPWR. Legal certainty? Cutting red tape? Forget it!“
Boris Engelhardt, Chief Executive of the German Rubber Industry Association
Furthermore, the WdK calls for the abolition of the obligation to involve authorised representatives in European countries if companies can make the required declarations there themselves. Documentation requirements for transport packaging between affiliated companies and branches in other EU countries should also be removed. The association justifies this by stating that such packaging is already integrated into the company's own waste management.
„Green Gate approach for transport packaging
As a further simplification, the WdK proposes a so-called „Green Gate approach“. According to this, a single registration and labelling process should be sufficient for each transport packaging. The relevant information is to be stored with the first distributor and then be accessible to all parties involved. Ideally, in the association's view, this should take place at the packaging manufacturer as the first actor in the lifecycle of the packaging.
„For every transport packaging, a single registration and labelling must be sufficient. This is stored with the initial placer on the market and can be accessed there by all parties involved. Ideally with the packaging manufacturer as the first actor in the packaging life cycle, says Engelhardt.
According to its own figures, the WdK represents more than 200 companies with over 60,000 employees and a total annual turnover of more than ten billion euros.
Source: WdK
