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Recyclability Becomes Subject to Documentation Requirements – Is Your Company Prepared?

26 May 2026 – Starting on 12 August 2026, companies will be required to maintain significantly more extensive documentation for their packaging under the new PPWR. The PPWR already introduces new requirements for technical documentation and conformity assessments of packaging from August 2026 onwards. At the same time, companies must begin preparing their packaging for future recyclability requirements, which will become legally binding from 2030.

PPWR Introduces New Documentation Obligations

The PPWR aims to consistently establish a circular economy for packaging throughout Europe. A key element is the mandatory assessment and documentation of packaging recyclability.

In the future, companies must be able to clearly demonstrate:

  • which materials a packaging consists of,
  • how well it can be sorted and recycled,
  • whether it complies with Design for Recycling criteria,
  • and which recyclability class it achieves.

This makes recyclability a measurable and documentable factor across the entire packaging value chain.

New Documentation Requirements Apply from 12 August 2026

The PPWR entered into force on 11 February 2025. However, most mandatory requirements will apply from 12 August 2026.

From that date onwards, companies must in particular be able to provide:

  • technical documentation,
  • as well as, in the future, declarations of conformity

for their packaging.

Even though specific recyclability requirements will only become mandatory step by step from 2030 onwards, companies already need to establish the necessary data foundations and documentation processes today.

Many companies are currently still insufficiently prepared for these new requirements.

Many Packaging Solutions Still Do Not Meet Future Requirements

Particularly critical are:

  • complex multi-material packaging,
  • components that are difficult to separate,
  • problematic colour and labelling solutions,
  • as well as packaging designs without a focus on recycling processes.

Many packaging solutions currently in use were originally developed primarily with marketing, protection, or cost considerations in mind. However, upcoming regulatory requirements are now placing actual circularity at the centre of attention.

Companies that fail to assess and optimise their packaging in time risk increasing pressure to adapt, as well as regulatory and economic disadvantages.

Design for Recycling Becomes the Standard

The PPWR clearly states that packaging must already be designed for recyclability during the development phase.

The following factors are becoming increasingly important:

  • mono-material solutions,
  • reduced material diversity,
  • recycling-friendly colours and additives,
  • clear separability of individual components,
  • as well as technical sortability.

As a result, “Design for Recycling” is becoming a key responsibility for product development, procurement, sustainability, and packaging management.

Early Analysis Creates Security

To identify risks at an early stage, companies are increasingly relying on data-based packaging analyses and recyclability assessments.

With PackLab Pro, EKO-PUNKT supports companies in analysing and assessing packaging with regard to recyclability, material combinations, and future PPWR requirements. This enables optimisation potential to be identified early and packaging solutions to be further developed in a targeted manner.

 

About EKO-PUNKT

EKO-PUNKT is the dual system of REMONDIS and supports companies in licensing packaging in compliance with legal requirements as well as fulfilling regulatory obligations under Extended Producer Responsibility (EPR) both nationally and internationally.

With PackLab Pro, EKO-PUNKT also offers a holistic solution for assessing the recyclability of packaging. PackLab Pro helps companies identify regulatory risks at an early stage and creates the foundation for the efficient implementation of future verification and documentation obligations – including the prospective creation of declarations of conformity under the new EU Packaging and Packaging Waste Regulation.

Test PackLab Pro Free of Charge Now


Companies that create transparency and analyse their packaging at an early stage can reduce regulatory risks and prepare specifically for upcoming PPWR requirements. PackLab Pro helps companies make recyclability measurable, documentable, and future-proof.

Register Now for a Free PackLab Pro Live Demo (German language)

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

Image credits: AI-generated with OpenAI.