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PPWR Action Required – What Comes Next?

Written by Alisa Maier | Sep 24, 2026, 8:13:21 AM

Which PPWR requirements apply to our company?

Being able to answer this question provides an important foundation. The company’s exposure has been assessed, relevant requirements and responsibilities are understood, and the first areas where action may be needed are becoming visible. But clarity about the current situation alone does not create compliance.

The key next question is: What do we need to do in concrete terms to close existing gaps and implement the PPWR requirements within the company?

This requires turning the initial assessment into a structured implementation process: identifying compliance gaps in greater detail, prioritising measures, developing a roadmap, and then translating the identified requirements into practice.

The first step is to systematically compare existing business practices with the relevant regulatory requirements. This is where a compliance gap analysis becomes necessary. It assesses existing structures, processes and responsibilities against the requirements of the PPWR, while also taking the previous legal framework into account, particularly the German Packaging Act.

At the same time, the focus must also be on what lies ahead: Which requirements will become relevant in the coming years, and which changes should companies already start preparing for today?

This turns a potential need for action into a concrete assessment: Where do actual compliance gaps exist, and what is required to close them?

These gaps can take on very different forms. Required information or documentation may be missing. Responsibilities may not yet be clearly defined. Supplier contracts may need to be adapted, or the necessary declarations of conformity may need to be prepared or obtained.

Existing processes or data structures may also not yet adequately reflect the regulatory requirements. Once the gaps have been identified, the next step is to prioritise the necessary measures in a meaningful way. Not every requirement is equally urgent. Some measures need to be implemented in the short term, while others require longer lead times or will only become relevant lateron. At the same time, certain measures may depend on one another or involve several business functions.

A PPWR roadmap provides the necessary structure. It organises the required measures according to urgency and impact, defines the next steps, and helps companies plan responsibilities and resources effectively.

The roadmap therefore answers three key questions:

    • What do we need to do?
    • When do we need to do it?
    • What should be prioritised?

This turns regulatory requirements into a concrete and manageable implementation plan.


The key is to actually close the identified gaps

A gap analysis and roadmap provide direction. However, PPWR compliance is only achieved once the measures derived from them are actually implemented.

Depending on the identified need for action, this may include registering in different EU Member States, contractually requiring suppliers to meet certain obligations, preparing or obtaining declarations of conformity, or adapting existing internal processes.

In addition to legal considerations, procurement, data management, reporting, and existing IT system landscapes may also become relevant.

The key is to translate regulatory requirements into existing corporate structures in a way that works in day-to-day operations.


From analysis to implementation

This is where our consulting approach comes in: We support companies not only in identifying compliance gaps but also in closing them.

From an in-depth gap analysis and the prioritisation of measures to the development of a PPWR roadmap and operational implementation, we support companies throughout the necessary steps. This may include registrations, contractual arrangements, declarations of conformity, as well as the review and adaptation of internal processes.

The PPWR Quick Check first answers the question: Where do we stand?

Building on this, the focus then shifts consistently to the next steps: What do we need to do now, what should be prioritised and how do we implement it?

Step by step, regulatory uncertainty is transformed into a structured path towards PPWR compliance.


Do you understand your PPWR exposure and want to determine your specific need for action?

We support you in systematically analysing compliance gaps, prioritising the necessary measures and implementing them pragmatically in practice.