The EU Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, applies from 12 August 2026. Alongside it, Germany's new packaging law implementation act (VerpackDG) brings a change that affects many sellers from Asia directly.
Germany: an authorised representative for sellers abroad
From 12 August 2026, companies based outside Germany, without a German branch, that sell empty packaging or packaged products directly to end users in Germany must appoint an authorised representative and register that representative in the LUCID Packaging Register before making products available on the German market. The German register describes registration itself as remaining the company's own responsibility.
Across the EU: what applies now
- PFAS limits for food-contact packaging.
- Producer responsibility rules, including representatives for producers established outside a member state.
- Later phases, mostly from 2028 to 2030, for harmonised labels, recyclability grades, recycled content and empty space.
France: a postponement to note
On 28 July 2026, the French government announced that operational implementation of the EPR scheme for professional (commercial and industrial) packaging moves to 1 January 2027, because the conditions for efficient deployment were not yet in place. Existing obligations for household packaging are unchanged.
What we did
- Confirmed authorised-representative arrangements for Germany and updated the register.
- Checked supplier PFAS declarations for paper and coated products sold into the EU.
- Updated our country map of packaging obligations so each market's registrations, representatives and deadlines sit in one place.