May 4, 2026 – The European Packaging and Packaging Waste Regulation (PPWR) brings a fundamental shift in responsibilities: According to a recent press release by the Central Agency Packaging Register (ZSVR), retailers will in future become the obligated party themselves – particularly for private label products.
Retailers become responsible producers
As of 12 August 2026, new requirements for system participation will apply. According to these, the obligation to participate in recycling will lie with retailers if:
- products are distributed under a private label
- imported goods are placed on the German market without a domestic intermediary
Companies that develop or commission products under their own name or brand are therefore considered the responsible producers of the packaging. A transfer of this obligation to suppliers or contract fillers is explicitly excluded.
No transition period – system participation required before distribution
Particularly critical:
No transition period is предусмотрed. System participation must be fully completed before the products are placed on the market.
Companies that fail to comply with this obligation in time risk a sales ban on their products.
Risks to the stability of the recycling system
The ZSVR warns of significant impacts on the dual system if companies do not fulfill their obligations in time.
If previously obligated companies deregister volumes and retailers in particular do not fully assume these quantities within their reporting, financing gaps will arise. These may jeopardize the stability of the entire system and hinder the timely securing of sorting and recycling capacities.
Concrete need for action for retailers
To implement the new requirements on time, the ZSVR recommends the following measures:
- Request packaging data from suppliers (weights and material fractions)
- Adjust existing system participation contracts or conclude new ones in good time
- Update registration data in the LUCID Packaging Register (including brand names)
- Report planned and forecast quantities correctly and consistently
- Fully document packaging and volume data
Only if these steps are implemented in time can compliant system participation be ensured.
Conclusion
The PPWR marks a clear turning point:
Retailers will assume full responsibility for system participation for private labels and certain imports.
Companies are now required to adapt their processes and take action in good time to avoid risks to sales and the financing of recycling.
How EKO-PUNKT can support you
EKO-PUNKT supports companies in the practical implementation of PPWR requirements. In addition to system participation in Germany (packaging licensing), our services include testing the recyclability of packaging, advising on design for recycling, clarifying EPR roles and obligations, including international execution, and providing support with documentation and preparation for the upcoming delegated acts.
If you would like to review your current packaging portfolio or prepare for the future PPWR requirements at an early stage, our experts are at your disposal.
Get advice now and get in touch with us
Author
EKO-PUNKT GmbH & Co. KG
Vanessa Herzog
Waltherstr. 49-51
51069 Köln
T +49 221 964897-62
M +49 160 6184350
vanessa.herzog@eko-punkt.de
Source: Press release of the Central Agency Packaging Register (ZSVR), “PPWR shifts responsibility to retailers: Without timely system participation, a sales ban is imminent”, Osnabrück, April 16th 2026.
Image credits: EKO-PUNKT, ZSVR Central Agency Packaging Register logo