The German Rubber Industry Association is urging EU policymakers to simplify Packaging and Packaging Waste Regulation requirements for industrial shipments, saying current obligations could create excessive administrative burdens for B2B trade.
The German rubber industry is calling for changes to the European Union’s Packaging and Packaging Waste Regulation (PPWR), arguing that some of its requirements are not suited to packaging used in business-to-business industrial shipments.
The regulation’s key provisions began applying in Germany on 12 August 2026, introducing new requirements covering packaging sustainability, recyclability, labelling and related compliance obligations. The European Commission says the rules are intended to reduce packaging waste, increase recycling and create a more harmonised framework across the EU.
However, the German Rubber Industry Association (WDK) says the framework places an additional administrative burden on companies involved in industrial B2B shipments. WDK CEO Boris Engelhardt said the regulation is largely designed around consumer goods and does not adequately reflect the specific characteristics of industrial transport packaging.
According to WDK, medium-sized rubber companies are particularly concerned about requirements associated with individual shipments. These include labelling, documentation, conformity assessments, monitoring and registration obligations, including requirements connected with shipments to other EU countries. The association also highlighted situations in which packaging is transferred between different parts of the same company.
WDK is therefore seeking a more targeted approach for transport packaging used in B2B operations. One of its proposals is to exempt companies that use less than 10 tonnes of shipping packaging annually in B2B activities from certain requirements. The association believes such an exemption could reduce compliance costs for smaller and medium-sized industrial businesses without undermining the regulation’s broader environmental objectives.
The association is also asking policymakers to remove the requirement for companies to appoint authorised representatives in EU countries where they already have the necessary internal reporting capabilities. In addition, it wants documentation obligations for transport packaging moving between affiliated companies and branches in different EU countries to be reduced or eliminated where the packaging is already covered by the company’s own compliant waste-management system.
Another proposal from WDK is a “Green Gate” approach. Under this model, information and labelling for transport packaging would be collected once by the first company placing the packaging on the market, with the relevant data then made accessible to other parties involved in the supply chain. The association believes this could prevent companies from repeatedly submitting the same information.
WDK is also seeking greater regulatory clarity from both EU and German authorities. The association argues that the development of additional delegated acts to supplement the PPWR could increase complexity for businesses if requirements are not clearly defined.
The debate highlights the challenge of applying a common packaging framework across very different sectors. While the PPWR is intended to create a more circular packaging system and reduce waste across the European market, industrial organisations are calling for implementation methods that recognise the operational realities of B2B transport packaging.
For the rubber industry, the priority is to maintain the environmental objectives of the PPWR while avoiding duplicate reporting, unnecessary paperwork and compliance procedures that may have limited additional environmental benefit. The outcome of discussions between industry representatives and policymakers could influence how B2B transport packaging requirements are implemented across the European industrial sector.