Packaging regulations are still widely perceived in many companies as a classic B2C issue.
However, this rule-of-thumb is becoming increasingly inapplicable.

Current legislative developments at both the national and European level – particularly with regard to the upcoming EU Packaging and Packaging Waste Regulation (PPWR) – make one thing clear: B2B companies are increasingly coming into regulatory focus.

Transport, industrial, and reusable packaging will be significantly more integrated into the scope of Extended Producer Responsibility (EPR) in the future – with concrete obligations, documentation requirements, and risks along the entire supply chain.

Packaging Regulation in Transition: From National Rules to an EU-Wide Framework

Regulatory requirements for packaging are evolving dynamically. In addition to existing national packaging laws, the PPWR will, for the first time, establish a harmonized European legal framework.

Key objectives of current and upcoming regulations include:

• Strengthening the circular economy
• Reducing packaging waste
• Increasing recyclability and reuse rates
• Significantly expanding Extended Producer Responsibility (EPR)

The scope of application is being gradually expanded, further including packaging types that were previously considered less critical in the B2B context.

A widespread misconception is that packaging regulation applies exclusively to sales packaging in end-consumer business. In fact, many regulations already apply and will increasingly apply to B2B packaging, including:

• Transport packaging
• Industrial and production packaging
• Reusable packaging
• Packaging used in cross-border trade

B2B companies are particularly affected if they:

• Place packaging on the market for the first time
• Act as importers or manufacturers
• Are part of international supply chains within the EU

This creates concrete regulatory obligations that, in practice, are often underestimated or not fully addressed.

Extended Producer Responsibility: More Than Just Registration

Extended Producer Responsibility entails far-reaching obligations that will further increase under the PPWR. These go well beyond a one-time registration and include, among others:

• Registration with national packaging registers
• Ongoing volume and material reporting
• Proof of recovery and recycling
• Ensuring data quality and traceability
• Preparation for regulatory audits

Especially in the B2B environment, it is common to find that packaging is incorrectly classified or that responsibilities along the supply chain have not been clearly defined.

Typical Challenges in the B2B Context

Project experience shows that recurring problem areas are:

• Lack of transparency regarding packaging types used
• Unclear producer roles in complex supply chains
• Manual, error-prone data collection
• Lack of integration of packaging data into existing IT systems
• Uncertainty regarding national and EU-wide obligations

These factors not only increase the risk of back payments or fines but may also impact market access and the ability to deliver.

What B2B Companies Should Do Now

In light of the upcoming PPWR requirements, a proactive and structured approach is recommended:

1. Analyze the packaging portfolio
Which types of packaging are used, in which countries, and in which role?

2. Clearly define producer responsibilities
Who is legally responsible – at the national and EU level?

3. Establish robust processes and a reliable data foundation
Volumes, materials, and reporting must be consistent and auditable.

4. Prepare specifically for the PPWR
Companies that act today can avoid future operational and regulatory disruptions.

Packaging regulation is no longer a purely B2C issue. B2B companies are increasingly directly affected – both from a regulatory and an operational perspective. Those who act now create transparency, reduce risk, and position themselves for upcoming EU requirements.

We support you in implementing EPR and PPWR requirements in a structured, legally compliant, and practical way.