Shortly before the new EU Packaging Regulation comes into effect, criticism from the business sector is growing. Both the German E-Commerce and Distance Selling Association (bevh) and the German Association of the Footwear and Leather Goods Industry (HDS/L) are calling for greater planning certainty and a practical implementation of the so-called PPWR, which is scheduled to apply from August 12, 2026.
The trigger for this is updated interpretive guidance published by the EU Commission on August 3rd. According to this guidance, online retailers are generally not considered producers of neutral, standard shipping cartons if they simply unfold, fill, and affix a standard shipping label. Responsibility may instead lie with the packaging manufacturer. However, the situation may be different for custom-made or branded cartons, as well as in cross-border supply chains.
This changes the current German practice, according to which online retailers are regularly required to register and participate in a system for the shipping packaging they fill. The German E-Commerce and Distance Selling Trade Association (bevh) welcomes the fundamental change of course but criticizes the late timing of the clarification.
“After more than a year of preparation for the Packaging Ordinance, online retailers now have to completely reorganize,” explains Eva Behling, Head of Legal and Compliance at the German E-Commerce and Distance Selling Trade Association (bevh). The association is therefore calling for a moratorium until open questions of interpretation are clarified and a legally sound basis exists for retailers and packaging manufacturers.
The HDS/L also sees a significant need for action in light of the short notice given the guidance. The association demands that the responsible authorities refrain from imposing sanctions in the first few months after the start of application and give companies an opportunity to rectify the situation. Immediate bans or recalls should be avoided.
“It is crucial that new legal requirements can be implemented in a practical way and that companies are given sufficient time for implementation,” explains HDS/L Managing Director Torben Schütz. Additional bureaucracy and more complex reporting obligations would tie up resources that could be better invested in innovation and sustainable product development.
The PPWR (Product Packaging and Packaging Regulation) imposes new requirements on product cartons, shipping packaging, and filling and protective materials for the footwear and leather goods industry. While the HDS/L (German Association for Leather Goods and Leather Products) generally supports the goal of conserving resources and strengthening the circular economy, it warns of rising costs and additional effort, particularly for medium-sized companies.
