Packaging (PPWR)

Obligations under the Packaging Act (VerpackG, VerpackDG) and the EU Packaging Regulation (PPWR)

Customer information, Wickede, August 2026

Regarding the implementation of the Packaging Act (VerpackG), the future EU Packaging Regulation (Regulation (EU) 2025/40) (PPWR) and the national implementing regulation (VerpackDG), we would like to inform you as follows:

The overarching objectives of the PPWR – a greater focus on sustainability, circularity and the reduction of environmental impact – are in line with Prolytik’s guiding principles and core values. The responsible and sustainable use of natural resources is a fundamental aspect for Prolytik Schmierstoffe GmbH and is therefore part of our corporate guidelines. Prolytik is committed to fulfilling its obligation to comply with the applicable and relevant environmental regulations (the principle of legal compliance) and to the continuous improvement of environmental protection. For many years, we have also been consistently reducing our environmental impact, such as energy consumption, waste and pollutants, both in production and in our products.

Three sets of regulations on packaging and packaging waste

Three sets of regulations are currently applicable and relevant to the subject of packaging and packaging waste in Europe and Germany:

1 |	VerpackG (still valid until August 2026) the German Packaging Act (Act on the Placing on the Market, Take-Back and High-Quality Recycling of Packaging – Packaging Act, VerpackG)
2 |	PPWR (in force in the EU since February 2025) Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste. The provisions are to be applied in parts in all EU Member States from 12 August 2026.
3 |	VerpackDG the Packaging Law Implementation Act (VerpackDG) aligns the national legal framework for packaging waste with the PPWR.

We would like to provide you with the following information regarding packaging

• Our company is subject to the regulations; we are an economic operator in a defined area within the meaning of the new definitions set out in the PPWR.
• We naturally comply with the obligations under the PPWR, which include, for example:

  The minimisation requirement	Art. 10 PPWR
  Compliance with sustainability requirements, including substance bans	Art. 5 et seq. PPWR
  Reusability and recyclability	Art. 6 PPWR
  Registration in the producers’ register	Art. 44 PPWR
  Labelling and information requirements	Art. 12 PPWR
  Due diligence obligations, in particular checks in the upstream supply chain	Art. 19 PPWR

• We are closely monitoring the planned national implementation of the PPWR and are currently identifying any future requirements that may have changed.
• We are currently assessing the extent to which we are affected by the significantly more far-reaching and extensive obligations as a producer under Article 15 PPWR (conformity assessment procedures, EU declarations of conformity, preparation of technical documentation):
  • in accordance with Recital 76 of the PPWR, we are not experts in packaging – we are not familiar with the design and manufacturing processes of our packaging,
  • in accordance with Article 21 of the PPWR, we do not alter the existing characteristics of the packaging, meaning that we do not compromise the packaging’s conformity.
• During supplier approval and goods receipt, we exercise due diligence to ensure compliance with the requirements.
• Where non-conformities are identified, we have established standard QM processes for corrective and preventive actions in accordance with the PPWR.
• In the context of market surveillance measures (e.g. regulatory inspections), we cooperate with the relevant authorities and provide the documents required under the PPWR.
• In accordance with Article 19(3) of the PPWR, there are confidentiality obligations and severely restricted obligations to provide information regarding internal documents and evidence. These are, in principle, reserved for the supervisory authorities.
• Furthermore, in the context of the current environmental policy focus on the circular economy, we adhere to the long-established waste management principle (prevention, reduction, recycling, disposal) in relation to our packaging as well.
• As part of our internal organisational processes, we have implemented internal procedures and controls to ensure that these processes are carried out pragmatically and in compliance with the law in areas such as procurement, production and sales.