The new EU Packaging and Packaging Waste Regulation (PPWR) introduces mandatory requirements effective August 12, 2026, that will directly impact procurement. Specifically, procurement departments will be required to issue declarations of conformity, adhere to material requirements, and document every piece of packaging. The regulation shifts the focus to the product itself, extending significantly further than previous waste legislation. For many companies, the challenge lies less in the regulation itself and more in how to implement these requirements in practice.

In this webinar, Christoph Schnoor, Senior Associate in Environmental and Packaging Law at the law firm Luther, and Johanna Teichmann from Customer Development at Tacto, explain what the PPWR specifically requires and what is essential for successful implementation in procurement.

PPWR Overview: Objectives and Effective Date

‍

As an EU regulation, the PPWR is directly applicable in all member states. It pursues five core objectives: reducing packaging waste, promoting a circular economy with recyclable packaging by 2030, stricter limits for hazardous substances, harmonizing the internal market, and improving consumer information through clear labeling. The fundamental obligations take effect on August 12, 2026, with further requirements phased in until 2040.

‍

Product Compliance Responsibilities

‍

Central to this is a new assignment of roles along the supply chain: producers, manufacturers, importers, distributors, and suppliers each have different obligations. Moving forward, the producer must conduct a conformity assessment procedure, create technical documentation, and issue an EU declaration of conformity. Initially, this primarily covers material restrictions under Article 5 (lead, cadmium, mercury, hexavalent chromium, and the new PFAS restriction for food contact materials) and recyclability under Article 6. Declarations of conformity and documentation must be retained for five years for single-use packaging and ten years for reusable packaging. Determining who holds the actual role of producer or manufacturer depends on the individual case and is not always the supplier.

‍

Circular Economy Obligations and Compliance Support with Tacto

‍

Beyond the product law level, waste management obligations also apply. At the national level, the Packaging Act (VerpackDG) specifies these requirements, mandating registration, system participation, data reporting, and completeness declarations, among other things. Violations can result in fines of up to 200,000 euros, and failure to register can lead to a ban on placing products on the market. The timeline is staggered: following the fundamental obligations in 2026, increased requirements for labeling, minimum recycled content, and recyclability will follow in the years leading up to 2030, 2035, and 2040.

‍

Compliance Support with Tacto

‍

The greatest operational leverage lies in the documentation that must be obtained from suppliers for each packaging unit. This is exactly where Tacto’s AI agents come in: the Material Compliance Agent automatically sends requests to all packaging suppliers, independently reads the uploaded declarations of conformity and certificates, and captures relevant data points—such as packaging type, PFAS, heavy metals, and recycling class—structured by item and supplier. The current compliance status is available at the touch of a button, and expiring documents are detected automatically. This allows companies to manage the growing documentation burden without having to track it manually in spreadsheets.

‍

Conclusion

‍

The PPWR shifts significantly more responsibility in packaging law onto manufacturing companies and procurement departments. It is crucial to clarify your role early on, identify the affected packaging, and organize the required documentation in a structured manner. Those who address this now will be prepared by the deadline, rather than having to scramble under time pressure later.

Christoph Schnoor (Luther) and Johanna Teichmann (Tacto) explain what the new EU Packaging Regulation means for procurement starting August 12, 2026: from new roles and declarations of conformity to material and recycling obligations, as well as the national Packaging Act (VerpackDG) and the risk of fines. The recording demonstrates how companies can categorize these requirements and practically implement the necessary supplier documentation using AI agents.