Six weeks. That's all the time separating the entry into force of the EU Packaging Regulation PPWR on August 12, 2026 and the application date of the Green Claims Directive ECGT on September 27, 2026. For many packaging teams, that means two compliance projects, two deadlines, two rounds of documentation — all within a window shorter than a typical artwork approval process.
Yet both regulations draw on exactly the same underlying data: the material composition, recyclability, and sustainability attributes of every individual packaging unit. Once you see that, two parallel projects become one.
What the PPWR Requires of Your Packaging Labels
The PPWR (Regulation (EU) 2025/40) was published in the EU Official Journal on January 22, 2025, and entered into force on February 11, 2025. [1] As an EU regulation, it applies directly in all 27 member states — with no room for national variation. [1]
From August 12, 2026, companies must be able to demonstrate that their packaging meets the regulation's core requirements — backed by complete packaging data and traceable documentation. [2] The PPWR introduces harmonized labeling obligations in a phased approach. [3]
Key Labeling Requirements at a Glance
Material composition (from 2028): Packaging must carry clearly legible pictograms indicating material composition — the specific symbols will be defined by EU implementing acts before August 12, 2026. [1] Germany's draft implementing legislation (VerpackDG) also provides for material abbreviations such as "PVC," "PET," or "ALU." [1]
QR code and digital labeling (from 2029): Packaging may include a QR code or another standardized open data carrier. [1] Through this QR code, consumers can access sorting instructions — information about which bin each component of the packaging belongs in. [1]
Recyclability grades: The PPWR introduces three recyclability performance grades, ranging from A (≥ 95%) to C (≥ 70%). [4] From 2035, only packaging in performance grades A or B may be placed on the market. [4]
Declaration of Conformity (from August 12, 2026): From the very first deadline, companies must prepare a Declaration of Conformity for each packaging unit and maintain technical documentation with verified material and recyclate data, as well as recyclability information. [5]
Heads up — data problem: Labeling requirements are not just a design challenge — they require the necessary data to be structured and readily accessible. A QR code on the packaging is only as good as the data behind it. Anyone looking to meet the PPWR's requirements needs a solid digital foundation. (LawCode)
What the ECGT Requires of Your Environmental Claims
The ECGT (Directive (EU) 2024/825) is the second major regulation hitting packaging teams in fall 2026. The directive entered into force on March 26, 2024, and applies from September 27, 2026. [6] Germany transposed the directive into national law in February 2026 through two pieces of legislation — including the third amendment to the Act Against Unfair Competition (UWG). [7]
The regulation's starting point: According to a 2020 European Commission study, 53.3% of environmental claims examined across the EU were vague, misleading, or unsubstantiated — and 40% could not be verified at all. [8]
What Will Be Prohibited from September 27, 2026
The ECGT specifically bans:
- Generic environmental claims without substantiation: Terms like "eco-friendly," "carbon neutral," "green," "sustainable," or "biodegradable" are prohibited unless the product's environmental performance can be demonstrated. [9]
- Self-created sustainability labels: Proprietary labels or logos that imply sustainability are no longer permitted — only labels based on a transparent, independent certification scheme. [9]
- Carbon-neutrality claims based solely on offsets: Claims such as "carbon neutral" or "CO₂ neutral" are banned for products where that neutrality is achieved purely through the purchase of carbon credits. [9]
- Misleading partial claims: It is prohibited to advertise a characteristic that applies to only a small part of the product in a way that implies the entire product is sustainable — for example, "made from recycled material" without specifying that this refers only to the packaging. [9]
What remains permitted: Specific, concrete claims backed by clear data. Instead of "sustainable packaging," a claim like "packaging made from 70% recycled plastic" is permissible — provided the figure is substantiated. [10]
The Penalties Are Significant
Violations of the ECGT can be costly: member states may impose fines of at least four percent of annual turnover. [11] In addition, violations can result in companies being excluded from public procurement for up to twelve months. [12] And competitors can take legal action — companies that advertise with vague environmental promises while rivals invest in genuine sustainability risk injunctions. [11]
Find out in a free consultation how well your packaging data is positioned for PPWR and ECGT compliance.
Check Your PPWR & ECGT Readiness NowWhere PPWR and ECGT Overlap — and Why That's an Opportunity
Here's the critical point that many compliance teams miss: at their core, both regulations demand the same underlying data.
The PPWR defines the minimum legal standards for packaging — recyclability, recyclate content, substance restrictions. The ECGT defines which communications about those very packaging attributes are permissible when addressing consumers. [13]
This has an important practical implication: under the PPWR (Article 14), environmental claims on packaging are only permissible if the packaging exceeds the PPWR's minimum requirements. [13] Printing "100% recyclable" on packaging that is merely required to be recyclable under the PPWR anyway means advertising the obvious — and that qualifies as misleading. [13]
The Synergy: PPWR Data as the Foundation for Substantiated Green Claims
A well-structured PPWR Declaration of Conformity already contains the bulk of the evidence the ECGT requires for substantiated environmental claims:
| PPWR Data Point | Use for ECGT Compliance |
|---|---|
| Material composition (layer structure, weights) | Substantiates claims such as "packaging made from X% recycled material" |
| Recyclability assessment (grade A/B/C) | Substantiates or refutes "recyclable" claims |
| Recyclate content (PCR rate) | Substantiates specific recycled-content claims |
| Supplier certificates | Third-party evidence for material properties |
| Declaration of Conformity | Audit-ready documentation for regulators and trade partners |
The substantiation infrastructure required for credible environmental claims under the ECGT largely overlaps with the infrastructure needed for PPWR compliance. [14] Build one, and you've effectively built the other.
Common Risk Scenarios from Real-World Projects
These recurring problem cases come up time and again in packaging projects:
- "100% recyclable" — with no recognized recyclability assessment and no consideration of actual sorting and recovery infrastructure in the target market. [15]
- "Sustainable packaging" — with no clear definition of which metrics (recyclate content, carbon footprint, material reduction) the claim actually refers to. [15]
- "Plastic-free" — even though plastics are still present in labels, barrier layers, or adhesives. [15]
- "Carbon-neutral packaging" — when only carbon credits were purchased, with no transparent documentation of the accounting methodology or offset projects. [15]
All four cases will be actionable under the ECGT from September 27, 2026. And all four can either be substantiated or corrected in time — with structured packaging data.
The Integrated Compliance Approach: One Project Instead of Two
Rather than treating PPWR and ECGT as separate projects, we recommend building a shared data foundation in four steps:
How Packa Addresses Both Requirements at Once
Packa is built as a central data platform for packaging management — designed precisely for this integrated approach. The platform connects PPWR compliance and green claims substantiation within a single shared data foundation:
Structured specification data: AI-powered digitization of supplier TDS documents, PDFs, and ERP exports into a structured, auditable data foundation — including material composition, layer structure, recyclate content, and certificates for each packaging article.
PPWR Compliance Engine: Automated checking of every packaging unit against PPWR requirements, recyclability assessment using EU methodology, and generation of the Declaration of Conformity — directly from specification data.
Green claims substantiation: The same material data captured for the PPWR Declaration of Conformity is immediately available as evidence for environmental claims — version-controlled, audit-ready, and accessible at any time.
Supplier management: Structured collection of missing data points from suppliers — no more chasing individual contacts by phone.
The result: no duplicated data effort, no parallel projects, no compliance gaps between PPWR and ECGT.
Conclusion: The Data Foundation Is What Decides
PPWR and ECGT are not isolated compliance tasks — they are two sides of the same coin. The PPWR requires that packaging be demonstrably designed to be sustainable. The ECGT requires that communications about that sustainability be verifiable. Build the data foundation for one, and you've largely solved the other.
The six weeks between the two deadlines are not a buffer — they're a signal that both regulations must be approached as a single, integrated challenge. Packaging teams that start building a structured, digital data foundation now will not only achieve compliance. They will also be positioned to communicate genuine sustainability performance credibly — and gain a competitive edge over companies that continue to rely on vague promises.
Discuss your specific situation with our experts — free of charge and no obligation.
Talk to a Packaging ExpertDoes the ECGT also apply to B2B communications on packaging?
The ECGT is primarily aimed at claims directed at consumers (B2C). However, packaging prints visible to end consumers are clearly covered. For purely B2B packaging with no consumer contact, applicability must be assessed on a case-by-case basis. Regardless, an increasing number of trading partners and retailers are demanding ECGT-compliant documentation — even in a B2B context.
What happens to stock that was produced before September 27, 2026?
Brands that wait until the end of August may find themselves sitting on non-compliant stock the moment enforcement begins. The ECGT provides no transitional arrangement for already-produced packaging. Plan your artwork changes with sufficient lead time — typical print template cycles take 3–6 months.
Is the Green Claims Directive (GCD) still relevant?
The separate Green Claims Directive (COM(2023) 166) was withdrawn by the European Commission in the summer of 2025. The ECGT is therefore the only currently legally binding EU regulation against greenwashing. For packaging teams, this means: the ECGT is the definitive framework — and it applies from September 27, 2026, without exception.
Which packaging items are subject to the PPWR declaration of conformity?
The PPWR applies to virtually all packaging placed on the market in the EU — sales packaging, grouped packaging, and transport packaging. A declaration of conformity must be prepared for each individual packaging item and must confirm compliance with Articles 5 through 12 of the PPWR — in particular substance restrictions, minimization requirements, and recyclability.
How high are the fines for ECGT violations?
Member states may impose fines of at least four percent of annual turnover in the affected countries. For large companies, this can amount to millions. Additional penalties include disgorgement of profits, exclusion from public tenders for up to twelve months, and cease-and-desist actions by competitors.
