The new EU Packaging Regulation (PPWR) is fundamentally changing the rules of the game for packaging – and this affects not only the retail sector, but the PPWR also presents new challenges for car manufacturers.
In Germany alone, the B2B sector accounted for around 9.5 million tonnes of packaging waste in 2023 – the automotive industry accounts for a large share of this, as individual parts and materials must be transported safely over long distances. The first requirements will become binding from August 2026, with further requirements following in stages until 2040.
For car manufacturers in particular, the PPWR means they need to be vigilant, as the new regulation makes no distinction between consumer goods packaging and industrial packaging such as load carriers, protective packaging for components and much more. We have taken a detailed look at the future challenges posed by the PPWR for the automotive industry.
The future for the automotive and industrial sectors under the PPWR – a quick read
- The PPWR will come into force in August 2026 and will fully apply to industrial and transport packaging in the automotive industry.
- Automotive manufacturers and suppliers must fulfil EPR obligations, demonstrate recyclability and establish reusable systems.
- Global supply chains, high volumes of packaging and as yet unresolved detailed regulations are proving particularly complex. These factors make preparation considerably more difficult.
- Those who act now will secure competitive advantages – those who wait risk compliance gaps and market losses.
What is the PPWR and why does it hit car manufacturers so hard?
The PPWR – short for the Packaging and Packaging Waste Regulation – is an EU regulation that came into force on 11 February 2025 and will become binding from 12 August 2026. It replaces the previous Packaging Directive (PPWD) of 1994 and thus represents a fundamental and forward-looking change to the system:
The old directive left the practical implementation to individual countries. This resulted in significant differences between countries, which at times hampered trade. With the new regulation, which applies directly and uniformly across all 27 EU Member States, there is no unnecessarily wide scope for interpretation and processes are therefore clear.
Challenging targets
The core objectives of the Regulation are clearly defined:
- To halt packaging waste in the EU by 2030 and reduce it in the long term
- To ensure that all packaging is recyclable by 2030
- To make the use of recycled materials (recyclates) mandatory
- To establish reusable systems as the standard
- To harmonise producer responsibility (EPR) across the EU
What makes the PPWR so special for the automotive sector? It explicitly makes no distinction between consumer and industrial packaging. Whether it is a consumer product on a supermarket shelf or protective packaging for a gearbox housing on its way from a Tier 2 supplier to the OEM – both are subject to the same rules.
And whilst food manufacturers have already come to terms with the new regulations on packaging across the board, the automotive industry is showing a certain degree of inertia and caution, which could quickly prove detrimental.
When does the PPWR come into force for automotive manufacturers, and what deadlines are looming?
For automotive manufacturers, too, the PPWR is not a one-off event, but a phased regulatory programme. An overview of the key milestones:
- 11 February 2025: The PPWR officially comes into force
- 12 August 2026: The first requirements become binding. EPR registration with an EPR registration number, labelling of materials, compliance with design specifications for all types of packaging and much more are now mandatory.
- 2030: All packaging must be recyclable. The recycled content requirements for packaging must be met and verified.
- 2035: Packaging must not only be recyclable, but must also be demonstrably recycled on a large scale
- 2040: Stricter recycled content targets for plastic packaging
Particularly challenging: Delegated acts are still pending for many detailed regulations. In practice, this means uncertainty, stagnation and stress. For car manufacturers, it is therefore important to stay informed about the PPWR, and this is where we – as your professional partner – are always by your side!
What requirements does the PPWR impose on the automotive sector and its manufacturing processes?
The new obligations can be grouped into four key areas – all of which are directly relevant to automotive logistics. We’ve summarised them briefly for you:
- Recyclability and Design for Recyclability: From 2030, the PPWR stipulates that all packaging must be technically recyclable. This is particularly relevant for the automotive industry because it relies heavily on composite materials and bespoke packaging, which often cannot be easily integrated into existing recycling processes. This means that many packaging designs will need to be fundamentally revised – and each solution must be accompanied by clear documentation that can be presented in the event of a dispute.
- Minimum proportions of post-consumer recycled content (PCR): The PPWR stipulates that plastic packaging must contain a minimum proportion of post-consumer recycled content. This poses challenges for the automotive industry, as protective and transport packaging often has to meet high mechanical requirements that recycled materials cannot always reliably fulfil. Furthermore, PCR materials are more expensive and their availability fluctuates, meaning that procurement strategies and supplier relationships must be fundamentally overhauled.
- Reusable obligations and scalable reuse systems: The PPWR stipulates binding reusable quotas for packaging and requires verifiable, scalable take-back systems. Existing reusable systems – which, whilst widespread in the automotive industry, are often organised in a pragmatic and undocumented manner – must be formalised, equipped with clear return processes and cleaning standards, and checked for compliance. The transition from individual reusable containers to scalable pooling models thus becomes a strategic imperative – throughout the entire supply chain.
- Extended Producer Responsibility (EPR): EPR obliges companies to bear the costs of collecting, sorting and recycling their packaging themselves and to register for this purpose in national registers such as the LUCID Packaging Register. This is particularly relevant for the automotive industry because, in complex supply chains, several parties may often qualify simultaneously as ‘producers’ within the meaning of the regulation – from OEMs and Tier 1 suppliers right through to importers. Who bears responsibility must be clearly defined in the contract.
For more in-depth information on the topic of PPWR, we recommend visiting our blog. You’ll find a wealth of further information there!
Why is the PPWR particularly complex for the automotive manufacturing sector?
The automotive industry faces a major challenge as a result of the PPWR. Various factors will need to be taken into account in future in order to tackle the implementation of the directive effectively through comprehensive waste management. Only in this way will environmental compliance become an achievable goal.
The following points represent pain points for automotive manufacturers and suppliers under the PPWR:
Unclear allocation of roles in multi-tier supply chains
In the automotive industry, the question “Who is actually the manufacturer within the meaning of the PPWR?” is often difficult to answer when it comes to OEMs, Tier 1, Tier 2 and Tier 3 suppliers, as well as logistics service providers. Common issues include:
- Who fills the packaging first?
- Who places it on the market, and in which market?
- How should cross-border imports from non-EU countries be handled?
Enormous variety of packaging
A typical automotive company uses hundreds to thousands of different types of packaging. These include:
- Small load carriers (SLCs) and large load carriers (LLCs)
- Single-use protective packaging for sensitive components
- Shipping cartons for spare parts
- Containers for dangerous goods and special packaging
- Export packaging for non-EU markets
Each category may be subject to different requirements, and everything must be documented.
Data structures are not PPWR-compatible
Although many companies have ERP data on packaging quantities, this is not in the formats required by the PPWR for reporting and documentation. In practice, this often means:
- Redesign of a reporting data model
- Master data maintenance for all packaging types
- Retention obligations ranging from 5 years (single-use) to 10 years (reusable)
The lack of secondary legislation creates planning uncertainty
Delegated acts addressing many detailed issues are still pending. Those who wait for complete clarity will lose valuable preparation time. Those who rely on incorrect standards too early risk having to redo work. The only solution: comprehensive advice from a professional partner who keeps track of changes to the PPWR and their implications for the automotive industry on your behalf. We can provide you with the best possible support here!
How can automotive companies best prepare for the PPWR?
The PPWR is not an insurmountable problem – but it does require structured, early action. We therefore recommend the following approach:
- Step 1 – Comprehensive packaging inventory: Record all packaging that your company places on the market – categorised by material, type, volume, target market and intended use.
- Step 2 – Defining roles within the supply chain: Clarify contractually at an early stage who bears EPR responsibility within your supply chain.
- Step 3 – Recyclability assessment: Have existing packaging designs assessed for recyclability – in accordance with the PPWR’s assessment framework.
- Step 4 – Strategically establish or adapt reusable systems: Develop scalable reusable concepts with clear return processes, cleaning standards and pooling models.
- Step 5 – Establish a data model and reporting infrastructure: Invest in a robust data system that reports packaging volumes by material fraction, category and destination country.
- Step 6 – Review and expand EPR registrations: Existing registrations (e.g. in LUCID) remain valid but must be adapted to meet new requirements.
Should you need help with these steps, we would of course be happy to support you with our expertise in the PPWR for the automotive sector!
PPWR as a strategic competitive factor for the automotive sector
It would be short-sighted to view the PPWR merely as a regulatory burden. Companies that act consistently – and, above all, in good time – stand to gain real advantages. These include, for example:
- Tendering advantages: Sustainable packaging solutions are increasingly becoming an evaluation criterion – among OEMs, in the public sector and in international procurement processes.
- Cost advantages: Scalable reusable systems significantly reduce packaging costs in the long term compared to single-use solutions.
- Relevance to investors: ESG criteria, which include packaging sustainability, are carrying increasing weight in financing decisions and ratings.
- Competitive differentiation: Companies that can demonstrate they operate PPWR-compliant supply chains gain an edge over competitors who only react under pressure.
The PPWR is therefore far more than just a compliance issue for the automotive sector. It is a driver for the redesign of supply chains, packaging design and sustainability strategies across the entire automotive industry.
And to ensure that you, too, successfully navigate this transformation, you have a reliable partner in us! So get in touch with us today!
FAQ: PPWR for the automotive sector
What does the PPWR mean for automotive manufacturers in practical terms?
The PPWR imposes new requirements on packaging and packaging waste for automotive manufacturers. This affects not only retail packaging, but also transport, protective and industrial packaging throughout the entire supply chain. In future, companies will have to demonstrate recyclability, reusable rates and compliance with documentation requirements. As a result, packaging management is becoming a strategic area of focus.
When does the PPWR come into force for car manufacturers?
The regulation came into force on 11 February 2025. However, the first binding requirements will apply from 12 August 2026. Further requirements, for example regarding recyclability and the proportion of recycled content, will be introduced gradually up to 2040. Companies should therefore begin implementation at an early stage.
Why is the PPWR particularly relevant to the automotive industry?
The PPWR affects the automotive sector, an industry characterised by complex supply chains and a large number of different packaging solutions. Many components are transported internationally and require specialised protective packaging. At the same time, the new regulations also apply to industrial packaging. This creates a significant need for manufacturers and suppliers to adapt.
What types of packaging are covered by the PPWR for the automotive sector?
The PPWR for the automotive sector covers almost all types of packaging used in the industry. These include small load carriers, large load carriers, export packaging, spare parts cartons and protective packaging for sensitive components. Reusable systems and single-use packaging are also affected. Companies must therefore systematically record and assess all packaging.
What requirements does the PPWR impose on the automotive industry regarding recyclability?
From 2030, packaging must be recyclable in accordance with the PPWR’s specifications. For the automotive industry, this means that many existing packaging concepts will need to be reviewed and, where necessary, adapted. The focus is particularly on composite materials. In addition, companies must be able to document and demonstrate recyclability.
