What is the difference between the PPWR and EmpCo?

The PPWR governs the packaging, EmpCo governs what you may say about it. Both apply side by side, cover the same products and have different key dates.

What the PPWR governs

Regulation (EU) 2025/40 on packaging and packaging waste concerns the item itself: the substances it contains, material use, recyclability, recycled content, reuse, packaging minimisation and labelling. Being a regulation, it applies directly in every member state without national transposition. Whoever places packaging on the market has to assess its conformity and document the evidence in a technical file. More on this on the PPWR page.

What EmpCo governs

Directive (EU) 2024/825 concerns not the product but the claim made about it. It sets the conditions under which companies may advertise environmental and sustainability claims or sustainability labels to consumers. Being a directive, it works through national law; in Germany through six new entries on the blacklist in the Annex to section 3 (3) of the Unfair Competition Act. It is enforced not by an authority but by competitors and consumer associations. More on this under Green Claims.

Where the two meet

At the packaging on the shelf. The PPWR determines which property a packaging must have and be able to prove, EmpCo determines whether that property may be printed on the pack and how it has to be worded. Recycled content that meets the PPWR requirement is not yet a permissible advertising claim; conversely, a carefully worded claim does not make a packaging compliant.

An independent certification serves both sides: it documents the product characteristic for the technical file and at the same time provides the evidence base that EmpCo requires for communication.

The key dates

• 11.02.2025: The PPWR enters into force, with an 18 month transition period
• 19.02.2026: The German EmpCo transposition is promulgated in the Federal Law Gazette
• 27.03.2026: Deadline for transposing EmpCo into national law
• 12.08.2026: The PPWR becomes applicable, further requirements phase in until 2040
• 27.09.2026: The new EmpCo rules apply