German rubber industry warns of “bureaucratic tsunami” with new EU packaging reg
4 Aug 2025
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Calls for an “urgent” exemption for small quantity threshold of 10 tonnes per year
Frankfurt – The German rubber industry has warned that the incoming EU Packaging and Packaging Waste Regulation (PPWR) will hit smaller manufacturers with a “bureaucratic tsunami” unless exemptions are introduced for low?volume users.
From 1?Aug?2026, the PPWR will require all businesses using packaging to document the origin and use of every item over the past five years.
By 2030, companies must register with a national authority and file detailed annual reports on packaging volumes by category.
“This time next year, many smaller European companies will have a rude awakening if the EU does not counteract with exemptions for small packaging quantities,” said Boris Engelhardt, managing director of the German Rubber Industry Association (WDK).
The rules will also demand a formal conformity assessment and technical documentation for all transport packaging, kept for at least five years.
“If they don’t use standard transport packaging, then this applies for every single shipment,” Engelhardt warned 31 July.
And that, he added, “applies regardless of the size of the item or the amount of packaging material used.”
The WDK argued that the measures will make it harder to reuse single?use packaging and do not reflect the realities of shipping customised products.
The PPWR currently offers lighter reporting rules for companies using less than 10?tonnes of packaging a year.
However, Engelhardt said this threshold should apply to all documentation, reporting and registration requirements.
“We urgently need a 10?tonne?per?year rule below which companies are fully exempt from these bureaucracy obligations,” he said.
Engelhardt went on to say that the EU Commission has announced 83 ‘delegated acts’ to flesh out the PPWR.
One of those acts, he said, must at least introduce small?quantity thresholds.
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