[Industry information / 19-26] 01.06.2026

With the new European Packaging and Packaging Waste Regulation (PPWR) (Regulation (EU) 2025/40), companies in the musical instrument and music equipment sector are facing extensive new requirements, both now and in the coming years.

The PPWR marks a fundamental shift in the way packaging is managed across Europe. The aim of the regulation is to significantly reduce packaging waste, strengthen the circular economy and mandatorily promote sustainable packaging solutions. At the same time, the Regulation not only replaces the previous EU Packaging Directive 94/62/EC, but will also have a significant impact on national packaging legislation and its future implementation in Germany.

​

The Regulation has been in force since 11 February 2025. The first binding obligations come into force on 12 August 2026, with further requirements to follow gradually from 2027.

​

It is particularly important to note that the PPWR affects not only manufacturers or packaging producers, but is also expected to impact large parts of the supply and distribution chain in the music industry — including specialist music retailers, e-commerce companies and distribution networks.

​

Retailers and online retailers in particular may face increased requirements in future regarding shipping packaging, documentation obligations, labelling, packaging reduction and compliance processes. This applies especially when companies place packaging on the market, import it or distribute it under their own brand for the first time.

In principle, the regulations apply to packaging regardless of the material used, as well as to numerous economic operators along the supply chain. These include, in particular:

 

• Manufacturers and producers

• Suppliers

• Importers

• Distributors and retailers

• Fulfilment service providers

• E-commerce companies

• Authorised representatives

 

The following types of packaging, amongst others, may be affected:

 

• Retail packaging

• Shipping and transport packaging

• Outer packaging

• Product display packaging

 

This may result in a significant need for adaptation, particularly for companies in the MI sector with international sales, e-commerce structures or complex supply chains.

​

The new regulations focus in particular on:

 

• Recyclability of packaging (‘Design for Recycling’)

• Mandatory recycled content targets

• Reduction of unnecessary packaging and void space requirements

• Reusable and returnable packaging requirements

• Extended labelling and information requirements

• Comprehensive verification and documentation requirements

• Registration and compliance requirements

 

Companies should bear in mind that the PPWR does not only concern technical packaging issues, but is also expected to have an increasing impact on contract drafting, procurement, product development, logistics, supply chain management and internal compliance structures.

​

Particular attention must also be paid to the potential consequences of non-compliance. Depending on the wording of national implementing regulations, these can range from market access restrictions, through the take-back and recall of packaging, to national sanctions. According to the current draft of the Packaging Law Implementation Act, infringements may in future be punishable by fines per infringement. In addition, there are potential civil law risks within existing business relationships.

​

Against this background, SOMM recommends that its member companies address the new requirements at an early stage and review existing processes. These include, in particular:

​

• Analysis of existing packaging structures

• Review of existing supply and contractual relationships

• Discussions with packaging manufacturers and suppliers

• Establishment of internal documentation and evidence-keeping processes

• Training of relevant staff

• Early assessment of potential adaptation requirements in e-commerce

​​

SOMM will actively monitor further regulatory developments and keep its members continuously informed about relevant requirements, deadlines and practical implications. Compliance is increasingly becoming a key prerequisite for market access and competitiveness.

​

Note: This industry information is provided for general guidance only and does not constitute individual legal advice. The content has been prepared with the utmost care; however, it does not claim to be exhaustive or legally binding. Companies should assess the specific implications of the PPWR in consultation with specialist legal and compliance advisers. SOMM is happy to assist its members, where required, in identifying suitable contacts and experts for practical implementation.