What does PPWR stand for?

PPWR stands for ‘Packaging and Packaging Waste Regulation’. It came into force on 11 February 2025 and will largely apply across all EU member states from 12 August 2026. The regulation aims to reduce packaging waste and ensure that packaging can be more easily recycled or reused. Unlike previously, largely uniform rules now apply across the whole of the EU.

What’s new?

Of particular importance to wine merchants and wineries is the obligation to fully document the packaging used. In future, a winery must record for each item the components of the packaging and the suppliers from whom they originate. This includes the bottle, cork or screw cap, capsule, label, and cardboard box.

Anyone classified as a ‘packaging producer’ must also be able to confirm that the packaging meets the currently applicable requirements. This certification does not need to be published. However, it must be submitted to a supervisory authority within ten working days if requested to do so.

Furthermore, the packaging producer must be named, including their full address. According to the German Winegrowers’ Association, the usual practice for wine of stating only the postcode and town is not always sufficient. However, the association states that this additional information can also be provided via the e-label.

Single-use packaging such as glass bottles must be documented for at least five years, whilst reusable packaging must be documented for ten years. Further requirements will follow later, including standardised material labelling, stricter rules on recyclability and less empty space in shipping boxes. From 2030, shipping and transport packaging may, in principle, consist of no more than half empty space. At the same time, packaging must be at least 70 per cent recyclable. Further stages will follow in 2035 and 2038.

Who is affected by the regulation?

Almost all businesses that manufacture, fill, import, resell, or deliver packaging to end customers are affected. These include wine-growing estates, wineries, importers, wine merchants, and online shops.

In the case of retail or own-brand products, the retailer may be deemed the responsible party if the wine is sold under their name or brand. Classifying small wineries is more difficult. ‘Micro-enterprises’ are defined as businesses with fewer than ten employees and an annual turnover or balance sheet total of no more than two million euros. According to the German Winegrowers’ Association, it has not yet been conclusively clarified whether the proposed relief will apply to wineries in all cases. There is therefore no general exemption for small businesses.

Anyone who places a maximum of ten tons of packaging on the market for the first time in an EU Member State each year may be eligible for relief from certain reporting requirements. However, this does not exempt them from their other obligations.

What are the biggest problems for wineries and retailers?

The first challenge arises during the inventory process. For every wine and every packaging variant, businesses must clearly identify the bottle, closure, capsule, label, shipping box, and supplier. Technical data and supporting documentation must be requested from suppliers and subsequently kept up to date.

There are also unresolved issues. Many details regarding labelling, recyclability, and calculation methods will only be specified by further EU regulations. Businesses must therefore review their documentation regularly and update it where necessary. Selling to several EU countries can also be particularly time-consuming: as things stand, companies must, in principle, register separately in every country in which they first offer packaged goods for sale. Without a branch of their own, a local contact person in the relevant country may also be required. This costs time – and money.

What costs might be involved?

It is not currently possible to quote a reliable flat rate. The amount depends primarily on the number of wines, packaging variants, and export markets. Potential costs arise from:

• Working hours or external consultancy for the collection and maintenance of packaging data
• Technical documentation, tests, or analyses
• Changes to labels and e-labels
• New bottles, closures, or shipping boxes
• Registration and packaging licensing in several EU countries
• Potential contacts or service providers abroad
• Rising disposal charges for packaging that is difficult to recycle

Costs can be particularly high if a wide variety of bottle and box formats are used, or if a business delivers directly to several EU countries. By grouping packaging variants, liaising with suppliers in good time and organising documentation by item number, you can minimise the workload.