PPWR: The underestimated challenge facing the automotive industry
The EU’s Packaging and Packaging Waste Regulation (PPWR) is more than just a recycling requirement. It is changing roles, responsibilities and decision-making processes throughout the automotive supply chain.
There are only a few months left before things get serious. The new European Packaging and Packaging Waste Regulation (PPWR) came into force on 11 February 2025. Since then, it has been legally binding EU law. However, general application will not begin until 12 August 2026. From then on, fines will officially be imposed if the regulations are ignored. From this date onwards, companies must actually comply with the new requirements, whether in terms of recyclability, labelling, packaging minimisation or conformity assessment.
Currently, car manufacturers and OEM suppliers are cautious when asked about the PPWR. But manufacturers of transport and protective packaging for the automotive industry and their suppliers are not yet ready to go either. Numerous details still need to be clarified. Apart from that, the effort required by the companies affected is considerable. Ernst Hahn, managing director at a packaging solutions firm said: "For many companies, the implementation of the PPWR currently means a high level of organisational effort combined with a great deal of uncertainty.”
“Numerous questions regarding practical implementation – such as role allocation in complex supply chains – have not yet been conclusively clarified, which we can clearly sense in the uncertainty of our customers,” Hahn said. “We also see considerable challenges in achieving the defined recycling rates across the board by the deadline. Against the backdrop of the current economic situation, we view the PPWR critically, but are of course preparing for its general application from August 2026."
What the PPWR means for automotive logistics
In many automotive organisations, the initial impetus for PPWR comes from sustainability, ESG or regulatory affairs departments. There, the regulation is classified, evaluated in terms of timing and translated into internal roadmaps. However, as soon as concrete implementation issues arise, the focus shifts. Packaging development, plant logistics and industrial engineering take on a central role because they decide how reusable concepts, material alternatives or new container standards can actually be integrated into processes. Purchasing ultimately becomes the decisive lever when it comes to translating new packaging requirements into supplier specifications, contracts and cost models.
Companies will need to measure and prove compliance with various KPIs, including sufficient recycled material content, maximised packaging density, and minimum rates of recycled and reused packaging. Reporting will influence fees under the EPR concept, and declaration of packaging material types and counting of reused and recycled items will be mandatory.
Lubomir Kroupa, COO of an environmentally-friendly packaging firm, says that the obligation to issue declarations of conformity is particularly relevant in the short term. “From 12 August 2026, we will have to confirm to our customers that the packaging complies with the requirements. However, it has not yet been conclusively clarified how this conformity is to be proven in detail,” he explains. “Other issues, such as volume reduction or binding recycling quotas, will only take effect later, in some cases from 2030 onwards. Nevertheless, the framework is clear: it will gradually become more restrictive. It is still manageable, but only if you address it at an early stage. At present, it is particularly unclear how the requirements can be clearly mapped in ERP systems and what the checks will look like in concrete terms.”
The positives and negatives of the PPWR
While the system is designed to be punitive, with potential fines for non-compliance, there are upsides to compliance, as optimising packaging density can reduce transport costs and the overall need for packaging. The overall cost impact is a complex combination of increases and potential savings.
But if the way packaging is considered within production cycles changes, savings could be realised further. Kroupa says that packaging has long been considered a pure C-part, a low-value, high-volume component. In future, he says it will move more towards becoming a B-part, and will be included earlier in development and decision-making processes. “It is often only recognised at a late stage that packaging has an impact on transport efficiency, production processes and costs,” he says. “This view will have to change.”
Kroupa also sees benefits in some of the uniform regulations that will be applied across EU countries. “Labelling is a good example,” he says. “Until now, there have been national symbols and requirements, which has led to a multitude of different logos on packaging. Uniform EU-wide labelling is sensible and necessary. These are measures that are relatively easy to implement and actually have an impact.”
Kroupa adds that the requirements also open up opportunities for innovation in the automotive supply chain. “We have been seeing a clear trend in the market for about one and a half to two years, away from polystyrene and towards alternative materials,” Kroupa says. “Many companies were already working intensively on this before the PPWR came into force. At the same time, it is becoming apparent that certain materials previously used, such as cross-linked foams for sensitive visible parts, are no longer viable because they are not recyclable. New solutions based on non-cross-linked plastics or paper-based concepts are emerging here.”
He says that reusable systems have long been established in the automotive industry, while classic plastic containers are investment-intensive and only pay off if they are used a large number of times. “We therefore see potential in hybrid solutions: paper-based packaging that can be reused four to six times,” he says. “If these requirements are recognised as reusable in the future, this would be a practical approach. It is important that regulation remains realistic in this area.”
Underestimated requirements beyond the material
A key issue is reuse. The regulation not only sets quotas, but also requires the establishment of functioning reuse systems. A reusable container alone does not meet this requirement. Return logistics, circulation figures, responsibilities, cleaning processes and inventory control are crucial.
In addition, there are documentation and information requirements. In future, packaging must be clearly identifiable, provide information on material composition and use and, depending on the design of the legal acts, be digitally readable. For automotive companies, this means viewing packaging more as a data-containing object that must be integrated into IT and tracking systems.
The frequently used buzzword ‘recyclability’ also falls short in its implementation. Challenges arise less with the base material than with components such as labels, adhesives, inlays or functional protective materials. These details determine whether packaging is actually recyclable in real-world sorting and recycling processes.
International supply chains as a stress test
The challenges of the PPWR are particularly evident in international supply chains. Overseas transport and so-called long-distance flows can conflict with regulatory reuse targets and logistical reality. Unilateral flows of goods make classic reusable cycles difficult, while long transit times increase circulating stocks and capital commitment.
One consequence is hybrid models: reusable where returns are realistic, combined with optimised single-use solutions for special cases. These approaches are supplemented by regional pools, consolidated return points or foldable and nestable container concepts. The PPWR forces companies to systematically justify and document these decisions.
Another factor is the infrastructure in the country of origin and destination. Packaging solutions must take into account means of transport, handling options and recycling structures along the entire chain. This makes packaging design a task that extends beyond the individual location.
Preparing for a new importance on packaging
Ultimately, the PPWR is not just another environmental compliance exercise to be delegated to sustainability teams. It is a structural shift in how packaging is designed, specified, sourced, circulated, tracked and financed across automotive supply chains. With August 2026 approaching, logistics leaders cannot afford to treat packaging as an afterthought, as regulation will reach deep into purchasing, IT, plant operations and cross-border flows, with real financial implications for non-compliance. But by starting to clean master data, review designs and stress-test reuse systems, OEMs, logistics providers and suppliers can uncover efficiency gains and avoid fees. The PPWR represents an opportunity to automotive logistics and supply chains to rethink packaging as a strategic asset rather than a cost to be contained.
