German Businesses Face Increased Burdens Under New EU Packaging Regulation

The new European Packaging Regulation, effective since August 12, 2026, has introduced significant obligations and administrative challenges for German companies, especially small and medium-sized enterprises (SMEs). Aimed at harmonizing packaging rules across the EU, reducing waste, and promoting the circular economy, the regulation requires producers to create conformity declarations and manufacturers to register with the Central Packaging Register in Germany. However, these new duties have raised concerns about practicality and bureaucratic costs among businesses.

According to Matthias Carl, Managing Director of the IHK Lippe, small businesses in particular struggle with determining their exact role under the regulation—for example, whether they are classified as "suppliers," "producers," or "manufacturers"—as the classification determines specific obligations including labeling and participation in dual waste systems. Suppliers must also provide technical data on hazardous substances, a task complicated by difficulties in obtaining such information from non-EU suppliers.

Dr. Ralf Mittelstädt, CEO of IHK NRW, highlighted that while businesses support the circular economy goals, clarity and practicability in the application of rules are crucial. He noted increased proof and documentation requirements, such as conformity declarations, and the added complexity for companies engaged in cross-border shipments, which may face extra registration and local representation mandates. Mittelstädt warned that such hurdles disproportionately impact smaller companies, potentially leading to higher costs, increased bureaucracy, and reduced acceptance of environmental policies.

Despite the absence of an official transition period, companies may continue to use existing packaging stock without re-labeling if they can reasonably ensure conformity. Both experts emphasize the importance of clearer guidelines, proportionality in implementation, and the avoidance of double reporting to facilitate compliance. The new regulation marks only the beginning, with further obligations expected in coming years.