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Countdown to the New EU Packaging and Packaging Waste Regulation: Compliance Considerations

By Thomas Dünchheim, Joahnn-Frederik Schuldt, Arne Paulus & Leo Mittag on June 16, 2026
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Row of EU Flags in front of the European Union Commission building in Brussels

Beginning Aug. 12, 2026, the new European Union Packaging and Packaging Waste Regulation (PPWR) (Regulation (EU) 2025/40 – PPWR) will replace the Packaging Waste Directive 94/62/EC (PPWD). The PPWR marks a fundamental shift from the PPWD by creating a uniform, directly applicable EU framework for packaging. Under the regulation, Member States are barred from introducing additional national packaging requirements unless explicitly permitted by the PPWR. 

For an overview of the PPWR’s background and its specific implications for e-commerce businesses, see our prior client alert from 2025.

The PPWR aims to reduce packaging and packaging waste and support a circular packaging economy across the EU by setting requirements covering the entire packaging life cycle, including strict rules on recyclability, recycled content, labeling, and waste reduction. While the PPWR applies from Aug. 12, many substantive obligations will become applicable gradually between 2027 and 2040.

Link to Click here to read the full GT Alert. Click here to read the full GT Alert.

Photo of Thomas Dünchheim Thomas Dünchheim

Thomas Dünchheim is a Shareholder in the Public Law Group in Germany and focuses on infrastructure (particularly transport and energy), defense, health, state modernization, and foreign trade. He has more than twenty years of experience in public law, particularly in procurement law, subsidy

…

Thomas Dünchheim is a Shareholder in the Public Law Group in Germany and focuses on infrastructure (particularly transport and energy), defense, health, state modernization, and foreign trade. He has more than twenty years of experience in public law, particularly in procurement law, subsidy law, municipal, environmental, and construction law, as well as gambling law. He advises federal, state, and local government agencies and companies, as well as private companies and investment banks. His clients include private and public infrastructure operators, state-owned companies, and banks, which he regularly advises on complex regulatory and administrative law issues and on digitization projects.

Thomas also regularly advises U.S. and international companies on EU and UK product safety, labelling, and chemicals compliance requirements across a range of industries, including footwear, textiles/biocides, personal care, medtech, veterinary products, and chemicals. His work includes comprehensive reviews of product compliance under EU chemicals and product safety laws, including substance limits, safety regulations, labelling requirements for products and packaging, EPR and waste management obligations, EU Declarations of Conformity, instruction manuals, and related regulatory requirements. Thomas has been recommended for many years in leading legal directories for state aid law, public commercial law, environmental and planning law, and subsidy law. Legal 500 recommends him among leading partners for public commercial law.

Before joining Greenberg Traurig, Thomas was a partner at Hogan Lovells in Dusseldorf. In addition, he served as full-time mayor of the city of Monheim am Rhein for over ten years. In this role, he was responsible for numerous strategic projects in the areas of administrative modernization, digitalization, and infrastructure development. Since 2016, he also holds an honorary professorship in constitutional and public law as well as public commercial law at EBS University for Business and Law in Wiesbaden.

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Photo of Joahnn-Frederik Schuldt Joahnn-Frederik Schuldt

Johann-Frederik Schuldt is a Shareholder in the Public Law Group in Germany and co-heads the ESG practice in Germany. Johann develops workable solutions in complex cases that require deep knowledge of regulatory law, commercial understanding and experience in governmental and political issues. He…

Johann-Frederik Schuldt is a Shareholder in the Public Law Group in Germany and co-heads the ESG practice in Germany. Johann develops workable solutions in complex cases that require deep knowledge of regulatory law, commercial understanding and experience in governmental and political issues. He represents private and public companies, industry associations as well as national and international governments.

Johann advises his clients on all questions of administrative, constitutional and EU law as well as on environmental, public planning and building law matters. As a particular focus, Johann advises clients on regulatory and environmental compliance in cross-border cases and global supply chains. He has wide-ranging experience in the fields of rent price law and the regulation of the housing market. Johann’s work comprises high profile litigation cases, contract negotiations and transactions.

Johann regularly publishes articles on public and regulatory law topics. His publications have been recognized with several academic awards and have been cited by the German Federal Constitutional Court and the German Federal Supreme Court in landmark decisions. Johann has been recognized in the “Best Lawyers” ranking by Handelsblatt as one of the best lawyers in Germany for public administrative law.

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Photo of Arne Paulus Arne Paulus

Arne Paulus is an Associate in the Public Law Group in Germany. He advises national and international clients on issues of public building and planning law matters, environmental law, public procurement law, rent price law and housing market regulation as well as other…

Arne Paulus is an Associate in the Public Law Group in Germany. He advises national and international clients on issues of public building and planning law matters, environmental law, public procurement law, rent price law and housing market regulation as well as other regulatory issues.

He represents clients vis à-vis authorities and in court proceedings.

Amongst Arne’s clients are project developers, investors and housing associations.

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Photo of Leo Mittag Leo Mittag

Leo Mittag is an Associate in the Government Law & Policy practice group. He advises national and international clients on all matters related to administrative and constitutional law, as well as at the interface between regulation and politics. His practice focuses on public-private…

Leo Mittag is an Associate in the Government Law & Policy practice group. He advises national and international clients on all matters related to administrative and constitutional law, as well as at the interface between regulation and politics. His practice focuses on public-private partnerships, chemicals law, privatizations, immigration, and defense.

He assists American, European, and international clients with regulatory issues, international compliance, and complex approval and administrative procedures, and represents their interests vis-à-vis European and German administrative authorities and political decision-makers.

Before joining Greenberg Traurig, Leo Mittag worked for a leading international strategy consultancy for political communication and public affairs. He completed his legal education and training in Hamburg, Cologne, Berlin, Hong Kong, and Tokyo.

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  • Posted in:
    Administrative and Regulatory, Environmental and Climate
  • Blog:
    E2 Law Blog
  • Organization:
    Greenberg Traurig, LLP
  • Article: View Original Source

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