German rubber industry calls for simpler B2B packaging regulation
17 Aug 2026
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WDK says PPWR requirements are unsuitable for transport packaging, calls for exemptions
Frankfurt, Germany – The German rubber industry has called for changes to the EU Packaging and Packaging Waste Regulation (PPWR), which took effect in Germany 12 Aug, stating that its requirements are not suited to shipments between industrial companies.
"The PPWR is aimed at the consumer goods sector and is not suitable for shipping between industrial companies (B2B),“ said Boris Engelhardt, CEO of German rubber industry assocation (WDK) 12 Aug.
“It is as if you have to squeeze your foot into a shoe that is two sizes too small: it pinches everywhere. And it creates more burdens than benefits,” he added.
According to WDK, medium-sized companies in the rubber industry in particular are complaining about the renewed increase in bureaucratic requirements for every individual shipment they package.
These include labelling requirements, documentation requirements, mandatory conformity assessment procedures, monitoring requirements and registration obligations for every shipment abroad.
The requirements apply even when shipping to another part of the same company, Engelhardt added.
On behalf of the European processing industry, WDK said it was specifically calling on the legislator to adapt the PPWR to the special nature of transport packaging in B2B shipping.
The association called on policy makers to exempt companies with annual shipping packaging consumption in B2B shipping of less than 10 tonnes.
It also called on them to abolish the obligation to involve authorised representatives in European countries where companies have their own competence to report.
Furthermore, it asked for the elimination of documentation requirements for transport packaging between affiliated companies and branches in other EU countries (B2B).
These, he said, are already integrated into the company's own waste management in compliance with PPWR.
"And we call for a 'Green Gate approach': For each transport packaging, a single collection and labelling must be sufficient,” said Engelhardt.
The approach will see the first party placing the packaging on the market filing the data, which can then be accessed by all parties involved.
Engelhardt also called for further clarity on the regulation by the EU and Germany, stating that the EU’s announcement of 80 further delegated acts to flesh out the PPWR did not bring legal certainty and instead added to bureaucracy.
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