--- title: "re_source Hamburg-based startup explains EU Packaging Regulation PPWR; Penalties up to €200,000" sdDatePublished: "2026-08-25T04:06:00Z" source: "https://startupcity.hamburg/news-events/news/what-startups-need-to-know-about-the-new-eu-packaging-regulation" topics: - name: "regulation of industry" identifier: "medtop:20000636" - name: "consumer goods" identifier: "medtop:20000243" - name: "business service" identifier: "medtop:20001371" - name: "international trade" identifier: "medtop:20000373" - name: "environmental policy" identifier: "medtop:20000423" locations: - "Hamburg" - "Germany" --- re_source Hamburg-based startup explains EU Packaging Regulation PPWR; Penalties up to €200,000 What Startups need to know about the new EU Packaging Regulation | Startup City Hamburg What Startups need to know about the new EU Packaging Regulation A new packaging regulation, also known as the Packaging and Packaging Waste Regulation (PPWR), has been in force in the EU since 12 August 2026. The Hamburg-based startup re_source provides a platform dedicated to the topic of compliant and sustainable packaging. One of the co-founders, Victor Büchner, answered a few questions for us about the regulations. Which Startups are affected by the PPWR regulations that have now come into force? The PPWR applies directly in all EU Member States, with no general exceptions based on company size. This means that any startup that places packaging or packaged goods on the market in the EU for the first time is affected. The legal term for this is ‘producer’. The following categories are affected: E-commerce involving shipping boxes, packing materials and subscription boxes. This is particularly tricky when shipping to several EU countries, as it requires registration for each target market. Food, drink, supplements, cosmetics: these sectors are the hardest hit because additional limits on per- and polyfluoroalkyl substances (PFAS, also known as ‘forever chemicals’) already apply to food contact materials. private label: They are generally regarded as the producer for legal purposes and bear the full burden of documentation, even if production is carried out by a contract manufacturer. Importers, for example from Asia or even from the UK. They must verify their suppliers’ compliance and obtain the necessary data for this purpose. Packaging and materials startups: customers are now asking for evidence. This is more of an opportunity than a risk, provided they act with startup speed. Fulfillment service providers and marketplaces: From now on, they are no longer permitted to allow retailers to sell without proof of registration. Consumer Products: Transport and outer packaging are also included here. There are concessions for the smallest enterprises with fewer than ten employees and an annual turnover of less than 2 million euros. If the supplier is based in the same country, they assume the role of the producer. What steps do Startups need to take straight away? Clarify your role: producer, manufacturer, importer or distributor? This varies depending on the packaging and the target market. Everything else depends on this. Build up a packaging inventory: list each variant, including materials, weight, components and supplier. Most startups haven’t documented this properly. Declaration of conformity and technical documentation for each packaging variant: these have been mandatory since 12 August. If they are missing, the packaging is deemed not to have been lawfully placed on the market: this may result in a sales ban, a recall or fines of up to 200,000 euros. There is a requirement to retain these documents for 5–10 years, and they must be submitted to the authorities within 10 days. Contact suppliers – preferably today – to request material data, PFAS and heavy metal certifications, test reports and recycled content figures. This is the most time-consuming part of the process and, in our experience, often takes weeks or even months. PFAS testing for food-contact packaging: there are strict limit values in place. Typical high-risk items include coated paper, grease barriers, and packaging for baked goods and takeaways. Ensure compliance with the EPR system for resource planning: register and participate in the system in every EU country to which you supply goods; appoint an authorised representative where you do not have a branch. Marketplaces are now actively checking this. Failure to comply results in a listing ban. This is why many startups are now posting on LinkedIn that they are currently only selling in Germany. Check the claims on the packaging: ‘reusable’ is only permitted if there is a genuine take-back scheme in place; misleading environmental claims are not permitted. Appoint a person to take responsibility and amend supplier contracts to include compliance undertakings and a duty to report any changes to materials. How can your startup, re_source, help other startups with the Packaging Ordinance? We already work with both small and very large companies, helping them get started with a PPWR readiness check. Using our tool, we can request missing data from their suppliers and manufacturers, follow up where necessary, and thus ensure that the data is complete. It is also possible to analyse existing gaps and draw up declarations of conformity. We therefore facilitate the entire process, from data collection and defining roles right through to the final declaration of conformity. Our tool also covers EPR. And one key point that sets us apart: we can also help to identify and source compliant alternative materials.