Your guide to the EU Packaging and Packaging Waste Regulation.

Regulation (EU) 2025/40 applies directly in all 27 member states from August 12, 2026, and it reaches every company that places packaging or packaged products on the EU market, wherever the company is based. The recyclability, recycled-content and empty-space rules follow from January 1, 2030 at the earliest, each waiting on a Commission act that is still pending. This page shows where the deadlines, fees and open acts stand, so you can work out what applies to you and what to change first.

Updated October 21, 2026. Every figure carries an evidence label showing how settled it is.

What applies on August 12, 2026, and what waits

PPWR is directly applicable from August 12, 2026. No national transposition required. The Declaration of Conformity obligation, PFAS limits, and EPR registration and fee obligations apply on that date across all 27 EU member states. Grade-based eco-modulation of EPR fees is mandatory under Art. 6(4)(d)/6(8) but binds later, around mid-2031 (18 months after both the Art. 6(4) delegated acts, due Jan 1, 2028, and the Art. 6(5) implementing acts, due Jan 1, 2030). 9 cost-driving items remain pending out of roughly 30 expected in total. Only Art. 6(4), Art. 7(9), and Art. 11(2) are delegated acts; Art. 64 carries the exhaustive list of delegated empowerments, and everything else here is an implementing act, a standardization request, or a requirement set in the Regulation itself (ACT-07); key technical thresholds are still being finalized.

One-page PPWR primer

Page preview of the PPWR primer

A one-page PDF, written to be forwarded ahead of a conversation so that nobody has to explain the regulation from scratch. It covers what already applies, which dates are fixed and which wait on an act, and who carries the duties.

The download starts when you submit, and the link then stays on this page. Your details are used to reply to you and, if you tick a box, to contact you about advisory support or send updates. See the terms of use.

Latest developments

All updates
Oct 21, 2026

The EU Sorting Label Act Slips to Mid-2027. The Commission now plans to adopt the implementing decision that sets the EU's harmonized sorting label in the second quarter of 2027, not in the fourth quarter of 2026 as its register showed earlier this month.

Oct 20, 2026

Parliament Votes to Limit the Representative Suspension to Small Firms. On October 20, 2026 Parliament adopted its amendments to the proposal that would pause the duty to appoint an authorized representative for EPR in each EU country where you sell directly to end users (Art. 45(3)).

Oct 7, 2026

Tell the Commission Where Recycling Targets Will Be Missed. The Commission has opened a call for evidence for its 2027 early warning report, the exercise that names which member states are at risk of missing the 2030 recycling targets, including the packaging material targets.

Sep 22, 2026

The EU Sorting Label Act Is Now Scheduled for Late 2026. The Commission has opened a register entry for the implementing decision that will set the EU's harmonized sorting label and the related labels for reusable packaging, deposit packaging, and recycled or bio-based content.

Sep 22, 2026

Three Recycled-Content Consultations Have Closed. The Commission's three early consultations on recycled plastic in packaging closed on September 16, 2026.

Read this week's update or browse the full dated archive, one page per development with its source.

What is the PPWR?

A plain-language primer on Regulation (EU) 2025/40
Regulation (EU) 2025/40 on Packaging and Packaging Waste (PPWR) entered into force on February 11, 2025. It is directly applicable EU law, no national transposition law is needed. The Commission's official interpretive guidance was published in the Official Journal on June 10, 2026 as Commission Notice C/2026/3084. DG Environment separately maintains a Frequently Asked Questions document, whose second edition was published on July 31, 2026 (ISBN 978-92-68-42316-5). It complements the Commission Notice and is interpretive: it shows what the Commission says, not what the Regulation requires. Every business that places packaged goods on the EU market, including importers and online marketplaces, must comply from August 12, 2026. The regulation covers all packaging: primary (consumer-facing), secondary (transit), and tertiary (industrial/transport).

Core Goals

  • Reduce packaging weight and complexity (minimization rules)
  • Make all packaging recyclable or reusable by 2030
  • Mandate post-consumer recycled (PCR) content targets by 2030
  • Modulate EPR fees by recyclability grade in every member state (rates stay national; the modulation framework is what gets harmonized)
  • Mandate DRS for beverage containers by 2029
  • Eliminate PFAS from food-contact packaging (from Aug 12, 2026)

Who Must Comply

Art. 3(1)(15) defines producer as five independent tests, not a ranking. Any manufacturer, importer or distributor meeting one of them is the producer, so the same product can have a different producer in each member state.

  • Limbs (a) and (b)Established in a member state and supplying it for the first time from within that same state
  • Limbs (c) and (d)Established in a member state or a third country and supplying another member state directly to end users. A business customer that consumes what it buys is an end user (Art. 3(1)(23)), so direct cross-border B2B is caught
  • Limb (e)Unpacking packaged products without being an end user, unless another person is the producer under (a) to (d)
What moves the obligation, and the other roles
  • Selling through a distributor established in the destination market can make that distributor the producer there, under limb (a) or (b)
  • Limb (c) and (d) producers must appoint an authorized representative by written mandate in every member state they supply other than their state of establishment (Art. 45(3)). This is the duty non-EU sellers most often miss
  • Packaging suppliers and converters owe the manufacturer the information and Annex VII technical documentation needed to demonstrate conformity (Art. 16), independently of the producer analysis
  • Distributors must verify, before making packaging available, that the producer is registered under Art. 44, that the packaging is labeled under Art. 12, and that manufacturer and importer duties are met (Art. 19)
  • Online marketplaces are not producers under PPWR. A platform letting consumers conclude distance contracts must obtain the producer's Art. 44 registration number and self-certification and assess them before allowing use of its service (Art. 45(4) and (6)), and may meet the producer's Art. 45(2) cost obligations only on a written mandate

Art. 45(1) attaches EPR to packaging a producer makes available for the first time on the territory of a member state, or unpacks without being an end user.

Which limb applies to your company is a question about your route to market in each member state. Source: Regulation (EU) 2025/40, Arts. 3(1)(15), 3(1)(23), 16, 19, 44 and 45, read in the OJ PDF on August 8, 2026 [LOCKED].

Where to Start

The changes are coming in waves

Milestone that reshapes the market Phased obligation or Commission deadline
Aug 12, 2026Now
General applicationEnforcement
PFAS banned in food-contact packaging; EU Declaration of Conformity required; producer identification and marking; EPR registration in every market; suppliers must provide accurate material data (Art. 16). No grace period for packaging placed after this date.
Feb 12, 20272027
Refill in hospitality
HORECA must let consumers bring their own container and must offer a refill option.
Jan 1, 20282028
Recyclability rules get defined
Deadline for the Commission to set the design-for-recyclability grades (A, B, C). The criteria you must design against become concrete. This is the critical path for the 2030 wall.
Feb 12, 20282028
Compostability mandates
EU-wide (Art. 9(1)): permeable tea, coffee and beverage bags, soft single-serve units, and sticky labels on fruit and vegetables must be industrially compostable. Rigid non-metal machine capsules and lightweight plastic carrier bags are a member state option only (Art. 9(2)(a)), not an EU mandate.
Aug 12, 2028or later
Labeling reset
From August 12, 2028, or 24 months after the Art. 12(6) or 12(7) implementing acts enter into force, whichever is the latest, a harmonized EU sorting label replaces national marks and QR or other standardized open digital-marking requirements begin (Art. 12). Expect a pan-EU artwork change. PPWR creates no Digital Product Passport; that is an ESPR instrument.
Jan 1, 20292029
Deposit return systems live
Every member state must operate a deposit return system for single-use plastic beverage bottles and metal beverage containers up to three liters, and hit 90% separate collection (Art. 50).
Feb 12, 20292029
Reusability label and reuse QR
Reusable packaging placed on the market from February 12, 2029, or 30 months after the Art. 12(6) implementing act enters into force, whichever is the latest, must bear a reusability label plus a QR code or other standardized open digital data carrier giving further reuse information (Art. 12(2)). Open loop systems that have no system operator, as defined under Annex VI, are exempt (Art. 12(3)).
Jan 1, 20302030
The design wallRedesign by here
Single-use format bans and reuse targets apply. The grade floor (A, B, or C, with anything below C off the EU market), the minimum recycled content for plastic, and the 50% empty-space cap apply from this date at the earliest, each waiting for its own act if that act is late: 24 months after the Art. 6(4) delegated acts, 3 years after the Art. 7(8) implementing act, and 3 years after the Art. 24(2) implementing acts, whichever is later in each case.
~ mid 20312031
Fees start to follow grade
Eco-modulated EPR fees keyed to recyclability grade begin to bite, 18 months after both the Art. 6(4) delegated acts and the Art. 6(5) implementing acts enter into force (Art. 6(8)). A low-grade format now costs more every year.
Jan 1, 20352035
Recyclable at scale
Art. 6(2)(b) adds the tougher "recyclable at scale" test to the 2030 design-for-recycling test from this date at the earliest, as an addition rather than a substitute. Its recycled-at-scale requirement applies from January 1, 2035, or five years after the Art. 6(5) implementing acts enter into force, whichever is the latest; from then packaging must satisfy both, and the grade floor still tightens to A or B in 2038.
Jan 1, 20382038
Top grades only
Only grades A and B may be placed on the market; grade C is phased out.
Jan 1, 20402040
Higher targets
Recycled-content minimums and reuse targets step up again.

Key terms, including Producer, Declaration of Conformity, eco-modulation, recyclability grades, PCR content, and PFAS, are defined on the Glossary tab.

About This Hub

This hub is provided for informational purposes only and does not constitute legal, regulatory, or compliance advice. The EU Packaging and Packaging Waste Regulation is still being operationalized: deadlines, thresholds, fee rates, and exemptions change as the delegated and implementing acts are finalized. Verify all information against the primary sources, including Regulation (EU) 2025/40 on EUR-Lex, the European Commission's official PPWR guidance, the DG Environment PPWR FAQ, second edition of July 31, 2026, the delegated and implementing acts as they are adopted, and the national EPR scheme (PRO) in each market where you sell, or with qualified legal counsel before taking compliance action.

PPWR Atlas is published by Hartter Advisory, LLC and is built and maintained by Dave Hartter, a packaging and product sustainability advisor with more than 20 years at global manufacturers, most recently as Director of Sustainability at Huber Engineered Materials and Newell Brands. He combines technical rigor with commercial logic, connecting regulation and customer requirements to real product and packaging decisions.

He now advises CPG brands and packaging suppliers on EU packaging compliance under the PPWR: where the fees land, how design and material choices change them, and how to turn early compliance into lower risk and a product advantage that holds up as the requirements tighten. PPWR Atlas is the public version of that work, updated weekly from primary sources.

For advisory engagements or corrections, reach Dave at dave@hartteradvisory.com. More about the author and advisory services

Get Ready for PPWR

PPWR at a glance

If your company puts packaging or packaged products on the EU market, PPWR applies wherever the company is based. The regulation is already in force and phases in through 2040, and the most expensive decisions are the design choices being made now, because product cycles run 18 to 36 months and the formats you sell in 2030 are being chosen today.

Deadline
The first hard date is August 12, 2026, when PFAS is banned in food-contact packaging and a Declaration of Conformity, producer marking, and EPR registration become mandatory in every market you sell into, with no grace period for new packaging.
The wall
The design wall arrives on January 1, 2030 at the earliest. Reuse targets apply that day, and the grade floor, the recycled-content minimums, and the 50% empty-space cap apply then or, whichever is later, 24 months after the Art. 6(4) delegated acts, 3 years after the Art. 7(8) implementing act, and 3 years after the Art. 24(2) implementing acts enter into force.
Cost
From about mid-2031, EPR fees begin to follow recyclability grade, so a low-grade format carries a cost your company pays every year rather than once.
Scope
Non-EU sellers are included and usually need an EU representative, and the design, substance, and labeling rules apply regardless of volume.
Before August 12

Three important points about August 12 that are easy to miss

These three points sit in the detail of the regulation and the Commission guidance rather than in the headline dates, and each one changes what you actually have to do. Sources are cited so you can check them.

1. The recyclability obligation starts on August 12, 2026. The grades start in 2030.

These are two different things and they have two different dates. The Commission guidance is explicit: "Article 6(1) requires that all packaging placed on the market is recyclable without providing a specific deadline for the application of this provision, which means that it applies from 12 August 2026." Until the Article 6(4) design-for-recycling act applies, you comply against the old Packaging and Packaging Waste Directive requirements and the related harmonized standard, EN 13430:2004, and your Declaration of Conformity attests to that. You do not run the Article 38 conformity assessment for recyclability until the Article 6(4) act is in force. [LOCKED, Commission Notice C/2026/3084, June 10, 2026]

2. Packaging already placed on the market does not have to be withdrawn

There is no transitional period for exhausting stocks. The guidance also says, though, that packaging "placed on the market before 12 August 2026 may remain on the market and does not need to be withdrawn." What matters is when placing on the market happens, and that is the transfer of ownership or possession, not the sale to a consumer. For imported packaging or packaged products, the relevant timestamp is release for free circulation at the end of the customs procedure. Stock that clears customs on August 11 is placed on the market. Note also that sales and grouped food-contact packaging are placed on the market when they are filled, while transport and service packaging are placed on the market empty. [LOCKED, Commission Notice C/2026/3084, section on PFAS enforcement and exhaustion of stocks]

3. Directive 94/62/EC is only partly repealed on August 12

Article 70 repeals Directive 94/62/EC with effect from August 12, 2026, but keeps several provisions running. Article 8(2) on marking continues until 30 months after the Article 12(6) implementing act enters into force. Article 9(1) and (2) continue for the first-indent essential requirements until December 31, 2029. Articles 5(2) and (3), 6(1)(d) and (e), and 6a continue until December 31, 2028, and Article 12(3a) to (4) until December 31, 2028, or 2029 for data transmission to the Commission. Decision 97/129/EC on the material identification system is not repealed until August 12, 2028. [LOCKED, Reg (EU) 2025/40 Art. 70]

Four moves, in order
  1. Map the whole portfolio first, every SKU and component, including secondary, transport, e-commerce, and imported packaging, because everything downstream keys off a complete map.
  2. Stand up the compliance file, meaning the Declaration of Conformity, producer marking, EPR registration, and removal of PFAS from food-contact formats, all required from August 12, 2026.
  3. Design to Grade A or B rather than the 2030 floor, since Grade C is legal in 2030 but banned in 2038, and designing once to the tougher bar avoids a second redesign.
  4. Name one owner and brief leadership early, because PPWR is cross-functional and stalls without a clear owner and an executive mandate.
Requirements attach to packaging formats, not individual SKUs. PPWR obligations (the Declaration of Conformity, the recyclability grade, and the recycled-content and design rules) apply per packaging type: a stable combination of format, structure, and materials. Every SKU that shares the same packaging is covered by one assessment and one Declaration of Conformity. You map SKUs to find your distinct formats, then comply format by format.
Expand any area below for the detail. The full milestone timeline, every date from 2026 to 2040, lives on the Overview tab.
Does PPWR apply to your company, and in what role?
Two separate questions. Whether PPWR reaches your packaging, and whether you are the producer for it. The design, substance and labeling rules bind packaging placed on the EU market wherever your company is based. Who carries the producer duties is a different question, answered by the five independent limbs of Art. 3(1)(15), which turn on where you are established, which territory you supply from, and whether you sell directly to end users, so it can differ per member state. Only limb (c) and (d) producers must appoint an authorized representative (Art. 45(3)); a non-EU seller supplying through an importer or a distributor established in the destination market may not be the producer there at all. National EPR schemes may set small-quantity reporting thresholds, but the design, substance, and labeling rules apply to your packaging regardless of size.

Brand owner or filler

Producer, if a limb applies

You sell products in EU packaging under your brand, whether you fill it yourself or a co-packer does it for you. Which Art. 3(1)(15) limb catches you depends on where you are established and which territory you first supply.

Importer or online seller

Producer, if a limb applies

You bring packaged goods into the EU, or sell into the EU from outside it. Importing does not by itself make you the producer: limb (a) or (b) catches you where you are established in the member state you first supply, limbs (c) and (d) where you supply another member state directly to end users. Art. 18 sets your importer duties either way.

Retailer or distributor

Verify + own label

You sell or move other brands' packaged goods within the EU. Art. 19 requires you to verify producer registration and Art. 12 labeling first. Private label normally makes you the manufacturer under Art. 3(1)(13)(a), which is a separate definition. One carve-out: under Art. 3(1)(13)(b) the manufacturer is your supplier instead, but only where the brand owner is a micro-enterprise under Recommendation 2003/361/EC AND that supplier is located in the same member state. Both conditions must hold together, so a micro-enterprise brand buying from another member state is still the manufacturer itself. Whether you are also the producer still follows the Art. 3(1)(15) limbs.

Packaging maker or supplier

Data duty

You make or supply empty packaging or components that end up on goods sold in the EU.

Marketplace or fulfillment

Facilitation duty

You list, store, or dispatch other sellers' packaged goods bound for EU buyers.

Your company is likely in scope if any of these is true: you sell packaged products in the EU; you import packaging or packaged goods into the EU; you ship to EU consumers online; or you make or supply packaging used on goods sold in the EU.
See your duty list, by role and packaging type
Pick your role and the packaging types you use to see which PPWR obligations apply to you, and when. Every date is taken from the EUR-Lex text of Regulation (EU) 2025/40 (fact base locked July 2, 2026); evidence labels show how settled each item is.
Your role
Packaging types (pick all that apply)
Role-wide duties (like EPR registration) always show; type-specific rows appear only for the types you pick.
Planning aid only, not legal advice. Dates marked LOCKED were read in the EUR-Lex text of Regulation (EU) 2025/40; SIGNALED items rest on official sources not yet final or not yet re-read; SPECULATIVE items are proposals. Several 2030+ dates shift if their delegated or implementing acts are adopted late (the row notes say so). Verify against primary sources before compliance decisions.
Where to put your effort, phase by phase
Now

Get the day-one basics locked

Before Aug 12, 2026
Map the whole portfolio first, including secondary, transport, e-commerce, and imported packaging.
Everything downstream (fees, the Declaration of Conformity, redesign priorities) keys off a complete SKU and component map. Gaps here show up late as compliance holes.
Stand up the compliance file: Declaration of Conformity, producer marking, and EPR registration in every market you sell into.
These are legal obligations on August 12, 2026 with no grace period for new packaging. Registration in each member state takes lead time.
Get PFAS out of food-contact formats and document it with third-party certificates.
The PFAS limit is one of the few hard bans that bites on day one. Supplier assurances are not enough; you need test certificates for your file.
Start collecting supplier data in a structured format (Article 16).
You cannot complete a Declaration of Conformity without accurate composition, recycled-content, and substance data from suppliers. Build the data spine now.
Next

Set up for the 2028 acts

2026 to 2028
Pre-assess recyclability against proxies (RecyClass, APR, JRC) before the 2028 grades are final.
Waiting for final criteria wastes the two-year runway to 2030. Product cycles run 18 to 36 months, so the formats sold in 2030 are being chosen now.
Get ready for the labeling change.
The 2028 harmonized label and the Art. 12 QR or digital data carrier mean a pan-EU artwork update, and the Art. 12(9) digital-only rule for EPR-scheme marks lands earlier, on February 12, 2027. Pre-build templates and data fields so it becomes a switch, not a scramble.
Attack minimization and empty space early.
The 50% empty-space cap and minimization rules land in 2030, but the redesigns and tooling changes take time. Overpackaging is the easiest early win.
Forward

Design for 2030 and the grades beyond

2028 onward
Design to Grade A or B, not the 2030 floor.
Grade C is legal in 2030 but banned in 2038. Designing once to the tougher bar avoids a second redesign a few years later.
Build certified recycled content into sourcing.
The 2030 recycled-content targets need certified chain-of-custody, and certified PCR capacity is constrained. Qualify supply ahead of demand.
Treat the EPR fee as total cost of ownership.
From about 2029 fees follow grade, so a low-grade format carries a recurring annual cost. Model that fee into format decisions, not just unit price.
Add reuse and refill where the format fits.
The 2030 reuse targets and refill obligations pull demand toward reusable formats, and a refill line also lowers the volume you place on the market.
Mobilize your team and brief leadership

Get your organization moving

  • Name one owner and pull in design, procurement, logistics, legal, and sustainability. PPWR is cross-functional and it stalls without a clear owner.
  • Find your at-risk SKUs and size the cost. Run the portfolio map, then use the Format Risk Screener to flag formats likely to miss the grade and the Fee Estimator to put a number on your EU exposure.
  • Turn it into a 90-day plan. PFAS and documentation first, then the redesign candidates the screener surfaces, sequenced against the phases above.

Brief your executives

  • The deadline is real and phased. It starts August 12, 2026 and tightens through 2030, 2038, and 2040.
  • The costly decisions are being made now, not in 2030. Product cycles run 18 to 36 months, so today's format choices lock in 2030 compliance and years of EPR fees.
  • It touches the whole business and the budget. Design, procurement, legal, and sustainability all have a part, and low-grade formats carry a fee we pay every year.
The 30-second version: PPWR is an EU packaging law that affects our market access and margins from 2026. If we act now on our top SKUs, we avoid a redesign scramble and lower our ongoing fees.
Frequently asked questions

The questions companies ask first when PPWR lands on their desk. Click any question to open the answer. Planning context, not legal advice.

Do I need a Declaration of Conformity for every SKU?

No. PPWR requirements attach to packaging formats, not individual SKUs. The Declaration of Conformity is drawn up per packaging type, a stable combination of format, component structure, material composition, and compliance-relevant features, so every SKU that uses the identical packaging shares one declaration. A change of material, supplier, weight, or format triggers a new version.

What does PPWR require on August 12, 2026, versus later?

From August 12, 2026 the substantive obligations are the Declaration of Conformity, EPR registration and fees in every market, and the PFAS limits for food-contact packaging. Minimization binds from day one too, but under the Directive 94/62/EC essential requirements that Article 70(1)(b) keeps in force until December 31, 2029, not yet under PPWR Article 10. The recyclability grade, recycled-content minimums, and the 50 percent empty-space cap apply from January 1, 2030 or a set time after the Commission act each depends on, whichever is the latest; the Article 10 minimization duty and reuse targets apply from January 1, 2030; and harmonized labeling from August 12, 2028, or 24 months after the Art. 12(6) or 12(7) implementing acts enter into force, whichever is the latest. So the Declaration of Conformity is required from day one, and today it covers the Article 5 substance limits, recyclability under Article 6(1), and minimization, the last two assessed against the Directive 94/62/EC requirements and their standards, EN 13430 and EN 13428, as Commission Notice C/2026/3084 explains. Each later requirement joins the declaration on the date it applies.

Where do I submit the Declaration of Conformity?

Nowhere. There is no EU portal or central authority for it. You hold it on file and produce it to a national market surveillance authority on request. That is different from EPR registration, which does go into national registers such as Germany's LUCID. The declaration follows the Annex VIII structure, and the manufacturer keeps it with the technical documentation for 5 years after the packaging is placed on the market, or 10 years for reusable packaging, while an importer keeps a copy for the same period.

Who must comply: the brand owner, the importer, or the supplier?

Whichever of them meets one of the five independent tests in Art. 3(1)(15), which is not a ranking. Limbs (a) and (b) catch a manufacturer, importer or distributor established in a member state that supplies for the first time from within that state on that same territory. Limbs (c) and (d) catch one established in a member state or a third country supplying another member state directly to end users, and a business customer that consumes what it buys is an end user under Art. 3(1)(23), so direct cross-border B2B is caught. Limb (e) catches unpacking without being an end user unless someone else is the producer under (a) to (d). There is no cascade and no test that turns on whether an EU manufacturer exists, so the producer can differ per member state and per route to market: selling through a distributor established in the destination market can make that distributor the producer there. Limb (c) and (d) producers must appoint an authorized representative by written mandate in each member state they supply other than their state of establishment (Art. 45(3)). Packaging suppliers and converters owe the manufacturer conformity information and Annex VII documentation (Art. 16), and distributors must verify producer registration, Art. 12 labeling and upstream duties (Art. 19). Online marketplaces are not producers under PPWR. Which limb applies to your company is a question about your route to market in each member state. Source: Regulation (EU) 2025/40, Arts. 3(1)(15), 3(1)(23), 16, 19, 44 and 45, read in the OJ PDF on August 8, 2026 [LOCKED]. Full breakdown: who is obligated, the warehouse trap and the private-label flip.

Do non-EU sellers have to comply, and do I need an EU representative?

Yes, but how it applies depends on the route to market. PPWR reaches any company that makes packaging or packaged products available on the EU market for the first time, wherever it is based. Selling directly to end users in a member state makes the seller the producer there under Art. 3(1)(15)(c) or (d), and Art. 45(3) then requires an authorized representative appointed by written mandate in each such member state. Selling instead through an importer or a distributor established in the destination market can put the producer obligation on that party under limb (a) or (b). Online marketplaces are not producers under PPWR; under Art. 45(4) and (6) a platform must obtain and assess the producer registration number and self-certification before allowing use of its service. EPR registration remains country-by-country, and some member states add their own requirements: Austria requires an authorized representative for cross-border distance sellers with no de minimis volume.

What are recyclability grades A, B, and C?

PPWR Annex II grades packaging recyclability by weight: Grade A is 95 percent or more recyclable, Grade B is 80 percent or more, and Grade C is 70 percent or more. Below 70 percent is non-recyclable and cannot be placed on the EU market from January 1, 2030. From January 1, 2038 only Grade A or B is allowed. Exact per-material criteria are pending the design-for-recycling delegated act (ACT-02, due January 1, 2028).

What is the empty-space limit for e-commerce and transport packaging?

From January 1, 2030, or 3 years after the Article 24(2) implementing acts enter into force, whichever is the latest, grouped, transport, and e-commerce packaging may not exceed a 50 percent empty-space ratio under Article 24. The figure is 50 percent, not the 40 percent that circulated in earlier drafts, and the calculation-method act is due February 12, 2028. Two related duties sit elsewhere: Article 24(4) requires empty space in sales packaging to be reduced to the functional minimum from February 12, 2028, and the general packaging minimization duty in Article 10 applies from January 1, 2030.

What is the PFAS threshold for food-contact packaging?

PFAS are banned from food-contact packaging from August 12, 2026 at three limits under Art. 5(5): 25 ppb for an individual PFAS, 250 ppb for the sum of PFAS, both excluding polymeric PFAS, and 50 ppm for total PFAS including polymeric. The Commission's June 2026 guidance recommends a stepwise test: total fluorine first, and under 50 mg/kg the sample can be treated as compliant. Test grease-resistant paper and board formats now, since reformulation lead times run 12 to 18 months.

When does eco-modulation of EPR fees become mandatory?

Grade-based eco-modulation of EPR fees is mandatory under Article 6(8), with the framework set by the Article 6(4)(d) delegated act, but binds later. Art. 6(8) sets the clock at 18 months from entry into force of BOTH the Art. 6(4) delegated acts (due January 1, 2028) and the Art. 6(5) implementing acts (due January 1, 2030). On the later of those, modulation binds around mid-2031, not 2029. National PROs already modulate fees by design today, so a low-grade format carries a recurring annual cost.

Need help preparing, or an exec-ready brief?

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Country Tracker
Click any country on the map to see EPR system details, fee thresholds, eco-modulation notes, and DRS status. All 27 member states are subject to PPWR direct application from August 12, 2026.
DRS Active
DRS In Development
DRS Deferred / Limited
DRS Not Yet Operational
Select a Country
Select any country to see EPR program details, thresholds, and DRS status.

All 27 Member States, EPR & DRS Summary

PPWR Art. 50 DRS mandate: By January 1, 2029, member states must collect separately at least 90 percent by weight of single-use plastic beverage bottles and single-use metal beverage containers of up to 3 liters, and must set up deposit return systems to achieve it. They may exempt containers under 0.1 liters where participation is not technically feasible. A member state can be exempted from the deposit duty itself if its separate-collection rate for a format was 80 percent or more by weight in 2026 and it notified the Commission with an implementation plan by January 1, 2028. Member states must endeavor to set up deposit return systems for single-use glass beverage bottles and beverage cartons (Art. 50(8)), and may cover other materials. Click a country for its deposit status, launch date, deposit amount, scope and operator.
Fee data note: Base EPR fee rates are indicative figures from 2025/early 2026 schedules. Eco-modulation adjustments can shift final liability significantly. Verify current tariffs directly with each national PRO.
CountryPRO / RegistrySME ThresholdDRS StatusKey Note
DE GermanyLUCID / Multiple PROs≤80,000 units AND ≤200 kgDRS ActiveCompetitive multi-PRO market. Declaration of Completeness required above tonnage threshold.
FR FranceCITEO / Léko~≤200 units or ≤5 kg (~€80/yr flat)DRS In DevelopmentTriman label still required. ICP B2B rate from Jan 1, 2026. CITEO bonus/malus up to ±100%.
IT ItalyCONAI (7 consortia)Varies by consortiumDRS In DevelopmentAlphanumeric codes required. Compostability Decree-Law 143/2026 in force, converted with amendments by Law No. 173 of October 5, 2026.
ES SpainEcoembes / Envalora<15 tonnes/yearDRS In DevelopmentSDDR statutory deadline Nov 2026 (RD 1055/2022) but operator authorization stalled; PPWR Art. 50 backstop is Jan 1, 2029. No PPWR national implementing measures enacted.
NL NetherlandsVerpact<50 tonnes/yearDRS ActiveMost generous SME threshold. Statiegeld fully operational. DRS-eligible formats require deposit marking.
PL PolandRecovery organizations (e.g. Rekopol) / BDONo de minimisDRS ActiveProduct fee only on a recycling-target shortfall, capped at PLN 4.50/kg. AR required for non-EU e-commerce sellers. BDO portal in Polish.
AT AustriaARAKleinstzeichner ~€150/yr flat rateDRS ActiveStrictest AR requirement in EU, zero de minimis. Omnibus AR suspension dropped from the Council negotiating mandate June 24, 2026; stalled, not adopted.
BE BelgiumFost Plus (household) / IVCInterregionalDRS Not Yet OperationalOne interregional EPR system under the 2008 Cooperation Agreement. No deposit system decided.
SE SwedenNPA (Näringslivets Producentansvar)~2 tonnes/yearDRS ActiveMature EPR system since 1994. Pantamera DRS operational.
DK DenmarkDansk Retursystem~1 tonne/yearDRS ActiveOne of oldest DRS systems globally (1989). High return rates.
FI FinlandRinki / Palpa~1 tonne/yearDRS ActiveWorld-leading return rates (>93%). DRS since 1996.
CZ Czech RepublicEKO-KOM300 kg or 600 unitsDRS In DevelopmentDRS legislation under development. EKO-KOM well-established.
HU HungaryOHÜ~200 kgDRS ActiveCentralized state system. DRS launched 2024 via MOHU.
RO RomaniaANPM / RetuROTo confirmDRS ActiveDRS launched Nov 2023 via RetuRO.
BG BulgariaECOBULPACKTo confirmDRS Not Yet OperationalEPR system transitioning. PPWR application may outpace national readiness.
GR GreeceEOANTo confirmDRS In DevelopmentEPR system in place. DRS Hellas is the sole DRS operator but is not yet collecting, with no go-live date published.
PT PortugalSPV (Sociedade Ponto Verde)~1 tonne/yearDRS ActiveDRS live since April 10, 2026 (SDR Portugal, Volta). SPV EPR system well-established.
IE IrelandRepak / Re-Turn~1 tonne or €1M turnoverDRS ActiveRe-Turn DRS launched 2024. Repak established EPR operator.
SK SlovakiaNATUR-PACK / ENVI-PAKTo confirmDRS ActiveDRS operational since 2022.
HR CroatiaFZOEUTo confirmDRS ActiveDRS operational since 2006 via FZOEU.
SI SloveniaSLOPAKTo confirmDRS In DevelopmentDRS in development. SLOPAK EPR system established.
EE EstoniaEesti PandipakendTo confirmDRS ActiveDRS operational since 2005.
LV LatviaLatvijas Zaļais PunktsTo confirmDRS ActiveDRS operational since 2011.
LT LithuaniaGreen Dot LithuaniaTo confirmDRS ActiveDRS operational since 2016.
LU LuxembourgValorlux~300 kgDRS Not Yet OperationalSmall market. Valorlux EPR established. PPWR DRS mandate by 2029.
CY CyprusGreenDotCyprusTo confirmDRS Not Yet OperationalEPR system present. PPWR DRS mandate by 2029.
MT MaltaGreenPak / WasteServTo confirmDRS Not Yet OperationalVery small market. GreenPak EPR operational. PPWR DRS mandate by 2029.
Glossary
Precise definitions for PPWR terminology. Legal definitions often differ from common usage.
ProducerArt. 3(1), point (15) PPWR
Any manufacturer, importer or distributor to which one of five independent tests applies, irrespective of the selling technique used. Limbs (a) and (b): established in a member state and making packaging, or products packaged in it, available for the first time from within that state and on that same territory. Limbs (c) and (d): established in a member state or a third country and making it available for the first time on the territory of another member state directly to end users. Limb (e): established in a member state and unpacking packaged products without being an end user, unless another person is the producer under (a) to (d).
Common misuse: reading the definition as a hierarchy in which the brand owner is the primary obligation holder and the importer stands in when there is no EU manufacturer. PPWR contains no such cascade; that is the pattern of the US state EPR laws, not of Regulation (EU) 2025/40. The limbs are independent, and because they turn on establishment, territory of first supply and whether the sale is direct to end users, the producer can differ per member state for the same product. Online marketplaces are not producers under PPWR; their duties sit in Art. 45(4) and (6). Source: Regulation (EU) 2025/40, Arts. 3(1)(15), 3(1)(23), 16, 19, 44 and 45, read in the OJ PDF on August 8, 2026 [LOCKED].
Packaging Types (Sales / Grouped / Transport / E-commerce)Art. 3(1), points (5) to (8) PPWR
Sales packaging constitutes a sales unit to the end user at the point of sale. Grouped packaging groups a number of sales units at the point of sale. Transport packaging eases handling and transport of sales units or groupings, excluding road, rail, ship and air containers. E-commerce packaging is transport packaging used to deliver products sold online or at a distance to the end user. The primary, secondary and tertiary labels come from Directive 94/62/EC and are still in common use.
Recyclability Grade A/B/CArt. 6 + ACT-02 (pending)
A classification of packaging recyclability by weight. Grade A = 95 percent or more, Grade B = 80 percent or more, Grade C = 70 percent or more. Packaging below 70 percent cannot be placed on the EU market from January 1, 2030, or 24 months after the Art. 6(4) delegated acts enter into force, whichever is the latest (Art. 6(3)).
Exact criteria are pending ACT-02 (Delegated Act on Design for Recycling). No final technical thresholds published, as at October 21, 2026.
Post-Consumer Recycled (PCR) ContentArt. 7 PPWR
Material recovered from waste generated by households or commercial/institutional facilities after use by end consumers. PPWR sets mandatory minimum PCR content targets by packaging type from January 1, 2030, or 3 years after the Art. 7(8) implementing act enters into force, whichever is the latest.
Distinct from post-industrial / pre-consumer recycled content. Only PCR content counts toward PPWR targets. Methodology for verification: pending ACT-03.
Mass Balance AccountingArt. 7 + ACT-03 (pending)
A chain-of-custody methodology that allows recycled feedstock inputs to be allocated to specific outputs without requiring physical separation throughout production. Relevant to chemical recycling credits for PCR content claims.
Heavily contested. NGOs argue mass balance overstates actual recycled content. Industry argues it is essential for chemical recycling viability. ACT-03 will define the permissible methodology.
Declaration of Conformity (DoC)Arts. 5–12 PPWR
The manufacturer's signed statement that a packaging format meets the requirements of Articles 5 to 12 that apply to it, drawn up after the Annex VII self-assessment and kept on file rather than filed with any authority. Required for packaging placed on the EU market from August 12, 2026. Its coverage grows as each requirement applies: substances, recyclability, and minimization today, then compostability, labels, recycled content, and the recyclability grades.
No direct US equivalent. The recyclability grade enters the technical documentation once the Art. 6(4) delegated act (ACT-02) sets the method; Annex VIII has no grade field. What the declaration covers, date by date
Authorized Representative (AR)Art. 3(1), point (20) and Art. 45 PPWR
A natural or legal person established in the member state where a producer supplies packaging for the first time, other than the state or third country where the producer is established, mandated to fulfill that producer's extended producer responsibility obligations there.
Austria requires an AR for all non-resident producers regardless of volume. The Environmental Omnibus proposal would suspend the AR requirement for EU-established producers until Jan 1, 2035; the EPR provisions were dropped from the Council negotiating mandate on June 24, 2026, so the suspension is stalled and not adopted.
Eco-ModulationArt. 6(8) PPWR (framework: Art. 6(4)(d))
Mandatory adjustment of EPR fees based on the environmental performance of packaging. Member states must ensure PROs apply higher fees to less recyclable, lower-recycled-content packaging and lower fees to more sustainable formats.
France's CITEO scheme is the most developed example: its 2026 maluses run in four levels from 10 to 100 percent of the contribution, and its bonuses include one proportional to the packaging reduction achieved [LOCKED, CITEO 2026 rate guide].
EPR / PROArt. 44–49 PPWR
Extended Producer Responsibility: policy requiring producers to bear financial responsibility for end-of-life management of their packaging. A PRO (Producer Responsibility Organization) is the collective scheme through which producers fulfill EPR obligations (e.g., CITEO, CONAI, Verpact, ARA).
Deposit Return System (DRS)Art. 50 PPWR
A system where consumers pay a deposit on beverage containers at point of sale, refunded when the container is returned to a collection point. By January 1, 2029, PPWR requires each member state to collect separately at least 90 percent of single-use plastic beverage bottles and single-use metal beverage containers up to three liters and to set up a DRS to reach it. A member state that collected 80 percent or more in 2026 can be exempted if it notifies the Commission with an implementation plan by January 1, 2028, and containers under 0.1 liters may be exempted where participation is not technically feasible (Art. 50).
Digital Product Passport (DPP)ESPR, not PPWR
A digital record of a product's composition and compliance data, reached through a data carrier. The DPP is created by the Ecodesign for Sustainable Products Regulation (ESPR), not by the PPWR. PPWR Art. 12 requires a harmonized sorting label plus, in defined cases, a QR code or other standardized open digital-marking technology; it does not mandate a packaging DPP. A packaging DPP would arrive only through ESPR delegated acts. Art. 13 governs the labeling of waste receptacles, not product passports. Scope boundary: PPWR vs ESPR and the DPP. [SIGNALED]
Substances of Concern (SoC)Art. 5 + Annex I PPWR
Hazardous substances present in packaging that may impair human health or hinder recycling. Includes PFAS and the heavy metals restricted under Art. 5(4). Annex I is the indicative list of what counts as packaging, not a list of substances. PFAS in food-contact packaging banned from Aug 12, 2026 (>25 ppb individual, >250 ppb sum, >50 ppm total including polymeric, Art. 5(5)).
Design for Recycling (DfR)Art. 6 + ACT-02 (pending)
Technical design criteria that packaging must meet to qualify for specific recyclability grades. Covers material composition, colorants, labels, adhesives, closures, barrier coatings, and separability. Exact criteria pending ACT-02 adoption.
PFAS (Per- and Polyfluoroalkyl Substances)Art. 5(5) PPWR
A class of approximately 4,700 synthetic fluorinated compounds. PPWR bans PFAS in food-contact packaging from August 12, 2026 at three limits under Art. 5(5): 25 ppb for any individual PFAS and 250 ppb for the sum of PFAS, both by targeted analysis excluding polymeric PFAS, and 50 ppm for total PFAS including polymeric PFAS. Where total fluorine exceeds 50 mg/kg, suppliers must on request evidence the split between PFAS and non-PFAS fluorine. Common in grease-resistant coatings on paper cups, fast-food wrappers, and microwave packaging.
PFAS testing and reformulation lead times are typically 12–18 months. Brands that have not started this process are now operating very close to the deadline.
Green Dot (Der Grüne Punkt)Art. 12(9) + 12(8) PPWR
The interlocking green arrows symbol historically used to indicate EPR fee payment to a national scheme. Two provisions bite, at different times. Article 12(9) is the operative one: from February 12, 2027, packaging in an EPR scheme may be identified only by a symbol carried in a QR code or other standardized open digital-marking technology. Read it precisely: Art. 12(9) does not compel anyone to mark EPR participation, it restricts the means. The practical effect is that a standalone printed EPR-fee mark can no longer serve that purpose. [LOCKED] on the date and the mechanism, read verbatim in the OJ text. Article 12(8) separately restricts marks, symbols or inscriptions that could mislead or confuse consumers about packaging waste management; it applies from August 12, 2026 and its practical reach widens when the harmonized label itself applies, on August 12, 2028, or 24 months after the Art. 12(6) or 12(7) implementing acts enter into force, whichever is the latest, because it is scope-limited to matters for which PPWR lays down harmonized labeling. It may not be used as a recycling instruction symbol.
Harmonized Sorting PictogramArt. 12 + ACT-04 (pending)
A standardized EU-wide graphical symbol indicating how a packaging component should be sorted. Replaces national sorting labels (e.g., France's Triman, Italy's alphanumeric codes). Required on consumer packaging from August 12, 2028, or 24 months after the Art. 12(6) or 12(7) implementing acts enter into force, whichever is the latest. Visual format pending ACT-04.
Compostable PackagingArt. 3(1), point (50) + Art. 9 + ACT-05 (pending)
Packaging that biodegrades in industrially controlled conditions, including through anaerobic digestion, but not necessarily in home composting. By February 12, 2028, permeable tea, coffee and other beverage bags, soft single-serve units, and sticky labels on fruit and vegetables must be compatible with industrial composting (Art. 9(1)); member states may also require it for rigid non-metal machine capsules and lightweight plastic carrier bags (Art. 9(2)). Technical criteria pending ACT-05.
Italy used the Art. 9(2)(b) option in Decree-Law No. 143 of August 7, 2026: four single-use plastic formats that Annex V restricts must be certified compostable to EN 13432 to be sold in Italy, a duty in force since August 8, 2026, with fines from January 1, 2030. Parliament approved the conversion law with amendments on September 30, 2026, and Law No. 173 of October 5, 2026, in force October 7, 2026, enacted it: listed prepacked fresh fruit, vegetables, herbs, and mushrooms are exempt from the first format's duty until the Commission's Art. 25(6) guidelines are implemented, and an operator holding conformity documentation from its supplier is not fined unless it knew of the non-conformity or it was evident.
Void Space / Minimization RuleArt. 24 and Art. 10 PPWR
Two separate duties, often confused. Empty space: for grouped, transport, and e-commerce packaging the void-space ratio may not exceed 50% from January 1, 2030, or 3 years after the Art. 24(2) implementing acts enter into force, whichever is the latest (Art. 24(1)); the calculation methodology is due February 12, 2028. Sales packaging is not covered by that cap, but Art. 24(4) requires its empty space to be reduced to the functional minimum from February 12, 2028. Minimization: Art. 10(1) requires weight and volume to be reduced to the minimum necessary for functionality, and applies from January 1, 2030. Minimization is not absent before then; Art. 70(1)(b) keeps the Directive 94/62/EC essential requirements and EN 13428:2004 in force until December 31, 2029.
Life Cycle Assessment (LCA)Not directly applicable under PPWR
A methodology for quantifying environmental impacts across a product's full life cycle. PPWR does not currently permit LCA-based arguments to override its specific format bans or reuse exemptions.
Common misconception: brands sometimes assume an LCA showing single-use outperforms reusable will earn an exemption. PPWR is prescriptive, LCA is not currently a permitted compliance pathway.

PPWR article finder

The articles compliance teams are most often handed by a customer, a lawyer or a supplier. Each links to a full page with the compliance date, who it binds, and the EUR-Lex text.
Delegated and Implementing Acts Tracker
Live status tracker for PPWR secondary legislation, where the technical details are actually defined. Each act shows its status, due date, evidence label, last-verified date, and what it does to your fees or formats.
Tracker last verified: October 1, 2026 (the EUR-Lex record for Regulation (EU) 2025/40 re-read; none of the eleven tracked items has been adopted)
Why this matters: PPWR's broad requirements apply from August 12, 2026, but the technical thresholds (recyclability grades, PCR methodology, design-for-recycling criteria) come from delegated and implementing acts, most of them still pending. None of the 11 tracked items below has been adopted or published in the Official Journal as at the last verification. Two related texts are final: Commission Delegated Decision (EU) 2026/429, adopted February 25, 2026 and published in the Official Journal (OJ L, 2026/429), exempts certain operators using pallet wrappings and straps from the 100 percent transport-packaging reuse targets, and Commission Notice C/2026/3084 of June 10, 2026 is the official interpretive guidance. Plan for acts that may be published at short notice.
Corrigenda to the Regulation, none in EnglishSeven corrigenda to Regulation (EU) 2025/40 have appeared in the Official Journal as at October 21, 2026 (May 22, 2025; September 9, 2025; November 25, 2025; November 28, 2025; July 21, 2026; August 4, 2026; and September 18, 2026). Each corrects one or more language versions other than English. The seventh, OJ L, 2026/90776, corrects the Italian Art. 3(1)(15)(c) and (d), the cross-border producer limbs, from "consumers" to "end users"; the English already reads "end users" in both. There has never been an English-language corrigendum, and none has changed the English operative text [LOCKED. The EUR-Lex register entry for Reg (EU) 2025/40 was read in full on October 1, 2026 and lists the language coverage of all seven: R(01) ES, FR and SV; R(02) BG, ES, CS and ET; R(03) SV; R(04) IT; R(05) CS and ES; R(06) DE; R(07) IT. English appears in none of them, so the claim is now evidenced across the whole set rather than inferred. Separately, all seven documents are held on disk, five as OJ PDFs and two as transcripts, each in a single language version rather than in every language it covers; the EN text of Arts. 3(1)(66), 24(2), 29(4)(b), 29(6) and 47(1) was checked directly and already reads the corrected way].

Competent authorities (Art. 40(3)). Fourteen of the 27 member states have notified the Commission of the authorities that apply and enforce the PPWR, as at October 21, 2026: Belgium, Czechia, Denmark, Germany, Estonia, Ireland, France, Croatia, Lithuania, Luxembourg (provisional), the Netherlands, Austria, Slovenia and Sweden. Norway and the United Kingdom are also listed. The contacts are on the Commission's PPWR implementation page.

ACT-01
Reuse Targets, Calculation Methodology (Art. 30(3))
Consequence: Determines how the Art. 29 percentages are counted (qualifying systems, trip counting, exemptions), which drives reuse-system planning for beverage and e-commerce brands ahead of the 2030 deadline. No direct fee effect.
Due: June 30, 2027 Status: Pending Not adopted, as at October 21, 2026.
More detail
The reuse targets themselves are self-executing in Article 29 (transport and e-commerce packaging 40% from 2030; beverages 10% from 2030; endeavour targets 70% and 40% from 2040). What is pending is the Article 30(3) implementing act defining how the targets are calculated and measured.
Evidence: Locked deadline (Art. 30(3), EUR-Lex read); Signaled status Last verified: 2026-10-21 Source: Art. 30(3) in Reg 2025/40
Pending
ACT-02
Design for Recycling (DfR) Criteria + Recyclability Grade A/B/C Methodology (Art. 6(4))
Consequence: The single most fee-relevant pending act. It delivers the Art. 6(4)(d) eco-modulation framework keyed to the Art. 45(1) EPR obligation, and starts the Art. 6(8) clock: harmonized grade-based fee modulation becomes mandatory in all 27 member states 18 months after both the Art. 6(4) and Art. 6(5) acts enter into force (roughly mid-2031 on the statutory deadlines), and grade assignments decide 2030 market access for every format in the Format Risk Screener.
Due: January 1, 2028 Status: Pending Not adopted, with no draft or register entry, as at October 21, 2026.
More detail
Defines the technical criteria for each recyclability grade (A, B, C) across all packaging material categories. Determines which formats fall below Grade C (and cannot be placed on the market from 2030, or 24 months after this act enters into force, whichever is the latest) and which earn Grade A fee discounts. JRC methodology work in development; not yet published for public consultation. The technical basis for these criteria is EN 18120:2026, the CEN design-for-recycling standard for plastic packaging (mandate M/584). It is voluntary until ACT-02 makes the method binding. See the Format Risk Screener for per-format traffic-light reads.
Blocks: EPR fee grade calculation, DoC recyclability field, packaging design investment decisions, non-recyclable (below Grade C) market-access planning
Evidence: Locked deadline (Art. 6(4), EUR-Lex read); Signaled status Last verified: 2026-10-21 Source: Art. 6(4) in Reg 2025/40
Pending
ACT-03
PCR Content Calculation Methodology, implementing act (Art. 7(8))
Consequence: Decides which recycled inputs count toward the Art. 7(1) 2030 minimums (30/10/30/35 by category), so it directly sets the compliance cost of PCR sourcing, whether chemical-recycling credits are usable, and eligibility for national PCR fee bonuses (Verpact 200 EUR/t discount, CITEO PCR prime, Ecoembes 20%+ PCR bonus).
Due: December 31, 2026 (Art. 7(8)) Status: Call for evidence closed Call for evidence closed on September 16, 2026 with 188 responses; draft awaited, as at October 21, 2026.
More detail
An implementing act under Art. 7(8), adopted by the Art. 65(2) examination procedure, not a delegated act. Defines how post-consumer recycled content must be calculated, verified, and certified, and sets the Annex VII technical documentation format. Determines whether mass balance accounting is permissible for chemical recycling inputs. Contested by NGOs and chemical recycling industry. Its timing moves the Art. 7(1) targets: those apply from January 1, 2030 or 3 years after this act enters into force, whichever is the latest.
Blocks: PCR target compliance claims, chemical recycling credit eligibility, PCR supply contract structuring
Register: Commission Have Your Say initiative 18753, call for evidence Ares(2026)7895997 (4 pp). A call for evidence is the early stage, so no draft text exists yet. The Art. 7(9) sustainability-criteria delegated act ran its own call for evidence in the same window (initiative 19033, see ACT-11). Read the filings here. Evidence: Signaled (register entry re-read in a browser 2026-09-22; the call-for-evidence document has not been read) Last verified: 2026-10-21 Source: Art. 7 in Reg 2025/40
Call for evidence closed
ACT-10
Third-Country Recycled Content Equivalence, implementing act (Art. 7(10))
Consequence: If your recyclate comes from outside the EU, this act decides whether it counts. Combined with ACT-03 it sets the whole shape of the PCR supply market: ACT-03 decides which processes count, this one decides which geographies do.
Due: December 31, 2026 (Art. 7(10)) Status: Call for evidence closed Call for evidence closed on September 16, 2026 with 142 responses; draft awaited, as at October 21, 2026.
More detail
An implementing act under Art. 7(10) setting the method for assessing whether recycled content recovered outside the EU was produced under conditions equivalent to EU rules. It decides whether imported recyclate counts toward the Art. 7(1) minimums at all. Distinct from the Art. 7(12) derogation power, which is gated on a January 1, 2028 assessment, and from the Art. 7(13) adjustment power.
Blocks: whether non-EU recyclate is usable for PPWR compliance; global PCR sourcing strategy; supplier qualification outside the EU
Register: Commission Have Your Say initiative 18752, titled "conditions for importing recycled materials into the EU for use in packaging", call for evidence Ares(2026)7896043 (4 pp). Read the filings here. Evidence: Signaled (register entry re-read in a browser 2026-09-22; the call-for-evidence document has not been read) Last verified: 2026-10-21 Source: Art. 7 in Reg 2025/40
Call for evidence closed
ACT-11
Sustainability Criteria for Plastic Recycling Technologies, delegated act (Art. 7(9))
Consequence: Together with ACT-03 and ACT-10 this sets the whole shape of the recycled-content market: ACT-03 decides how recycled content is counted, this act decides which processes can produce it, and ACT-10 decides which geographies can. If your recyclate comes from a process this act does not recognize, it does not count.
Due: December 31, 2026 (Art. 7(9)) Status: Call for evidence closed Call for evidence closed on September 16, 2026 with 223 responses; draft awaited, as at October 21, 2026.
More detail
A delegated act under Art. 7(9), due by December 31, 2026, that supplements the Regulation with sustainability criteria for plastic recycling technologies. Under Art. 7(9), recycled content counts toward the Art. 7(1) minimums only if it was recovered in EU installations whose technology meets these criteria, or in third-country installations meeting equivalent standards (which is where ACT-10 takes over).
Blocks: which recycling processes yield countable recycled content; chemical-recycling eligibility; recycler qualification and supply contracts
Register: Commission Have Your Say initiative 19033, "sustainability criteria for plastic recycling technologies", type of act delegated decision, expert group E03343, call for evidence Ares(2026)7896093 (4 pp). Read the filings here. Evidence: Locked duty and deadline (Art. 7(9), OJ text read); Signaled status (register entry read in a browser 2026-10-21; the call-for-evidence document has not been read) Last verified: 2026-10-21 Source: Art. 7 in Reg 2025/40
Call for evidence closed
ACT-04
Harmonized Labeling Implementing Act, Sorting Pictograms (Art. 12(6)/(7))
Consequence: Starts the 24-month clock to the harmonized label (applies Aug 12, 2028, or 24 months after this act if later), and widens the reach of the Art. 12(8) misleading-marks restriction, which has applied since August 12, 2026 and reaches only matters for which PPWR lays down harmonized labeling. Note that the Art. 12(9) digital-only rule for EPR-scheme marks such as the Green Dot runs on its own clock and applies from February 12, 2027 regardless of this act. Late adoption pushes the whole labeling timeline. The August 12, 2026 statutory deadline passed with no act. Because the 24-month clock runs from the act's entry into force, and no act was in force by mid-August 2026, the August 12, 2028 date is already out of reach; on the Commission's own plan the label cannot be required before about mid-2029, and every month of slippage moves it by a month. The only preparatory output is JRC technical proposal JRC141706 of January 13, 2026, which covers Art. 12(6) and Art. 13(2). Artwork and inventory cost effect, no fee-rate effect.
Due: August 12, 2026 Status: Deadline missed Deadline missed; in preparation, with adoption planned for the second quarter of 2027, as at October 21, 2026.
More detail
Defines the visual format, sizing, placement, and color specifications for EU-wide harmonized sorting pictograms replacing national labeling schemes from August 12, 2028, or 24 months after this act enters into force if that is later.
Blocks: Artwork planning for the 2028 label transition; national labels (Triman, IT alphanumeric) remain in force until adopted
Register: Commission Have Your Say initiative 19243, implementing decision, draft act feedback "Upcoming", adoption planned Q2 2027 (register entry read in a browser October 21, 2026) Evidence: Locked deadline (Art. 12, EUR-Lex read); Signaled status Last verified: 2026-10-21 Source: Art. 12 in Reg 2025/40
Deadline missed
ACT-05
Compostable Packaging Harmonized Standards, standardization request (Art. 9(6))
Consequence: Sets the test compostable packaging must pass, including the home-composting conditions Art. 9(6) names (retention times, temperatures and stirring); which formats may or must be compostable is fixed in Art. 9(1) and 9(2). Until the new harmonized standards are listed in the Official Journal there is no presumption of conformity for compostable packaging, and EN 13432 serves only as guidance (Commission Notice C/2026/3084). That decides how bioplastic SKUs are certified and priced under schemes like Italy's Biorepack (246 EUR/t from July 2026).
Due: February 12, 2026 (Art. 9(6) standardization request) Status: Not yet requested The Commission's implementation page says it will request the development of standards for home and industrial composting of packaging, as at October 21, 2026.
More detail
Not a delegated or implementing act. Article 9 empowers neither. What Art. 9(6) requires is a Commission request to the European standardization organizations, due February 12, 2026, to prepare or update harmonized standards for industrial and home compostability, covering retention times, temperatures and stirring. The permitted application categories are set directly in Art. 9(1) and 9(2) and already bind; Art. 9(5) allows the Commission to propose extending them by legislative proposal. Related to Italy's Decree-Law No. 143/2026 (TRIS notification 2026/0167/IT).
Blocks: Compostable packaging investment decisions; Italy's compostability decree interacts with this act
Evidence: Signaled Last verified: 2026-10-21 Source: Art. 9 in Reg 2025/40
Not yet requested
ACT-06
Reusable Packaging Minimum Rotations, delegated act (Art. 11(2))
Consequence: Sets the bar for what counts as reusable, which gates both the Art. 29 reuse targets and the large national reuse fee incentives (for example CITEO's reuse bonus, up to a full contribution discount for proven reuse systems).
Due: February 12, 2027 (Art. 11(2)) Status: Not published Not published, as at October 21, 2026.
More detail
A genuine delegated act, one of three here, listed in the Art. 64 empowerments. Art. 11(2) requires the Commission to establish a minimum number of rotations for the packaging formats most frequently reused, taking hygiene and logistics into account. The wider reusability criteria (emptying, unloading, refilling, reconditioning, recyclability) are set directly in Art. 11(1) and already bind.
Evidence: Signaled Last verified: 2026-10-21 Source: Art. 11 in Reg 2025/40
Not published
ACT-07
DRS Minimum Requirements, already in the regulation (Annex X)
Consequence: Shapes deposit-marking and interoperability requirements for beverage formats ahead of the January 1, 2029 Art. 50 collection target (a member state at 80 percent separate collection in 2026 can be exempted from the deposit duty if it notifies the Commission by January 1, 2028); affects label artwork and cross-border SKU planning in the 11 countries on this table without an operating DRS (6 in development, 5 not yet started). No EPR fee effect.
Due: n/a, Annex X is already in force Status: In the Regulation Not an act: the requirements are set in Annex X and already law, as at October 21, 2026.
More detail
Not a pending act. Article 50 empowers no delegated or implementing act. The DRS minimum requirements are set directly in Annex X and are already law. They apply from January 1, 2029 to systems established after entry into force; systems established earlier are grandfathered if they hit the 90 percent target by January 1, 2029, and otherwise must comply by January 1, 2035. Annex X does not apply in the outermost regions. The only act in this area is the Art. 56(7)(a) implementing act on reporting and calculation.
Evidence: Locked Last verified: 2026-10-21 Source: Art. 50 in Reg 2025/40
In the Regulation
ACT-08
Harmonized EPR Registration Format (Art. 44(14))
Consequence: Until adopted, every producer registers separately in each member state on national PRO formats, a large recurring admin cost for multi-country and non-EU sellers (27 registrations, 27 data structures). No fee-rate effect, pure compliance burden. The draft annex sets the data fields producers will report against, and feedback on it closed on September 10, 2026.
Due: February 12, 2026; draft published August 6, 2026 Status: Deadline missed Deadline missed; draft consultation closed, not adopted, as at October 21, 2026.
More detail
Required to establish a standardized registration format enabling producers to register across all 27 member states using a single data structure. Intended to reduce administrative burden of multi-country EPR compliance.
Statutory deadline of February 12, 2026 was MISSED, but a DRAFT ACT now exists: the Commission published a draft implementing regulation on August 6, 2026 and took feedback until September 10, 2026. That consultation is now closed, with 7,667 responses. The act has not been adopted, so producers must continue registering individually in each member state using national PRO formats.
Register: Commission Have Your Say initiative 15352, stage "Draft act, feedback closed", closed September 10, 2026. Documents: draft implementing regulation Ares(2026)7688068 (5 pp) plus its Annex (19 pp); 7,667 feedback submissions filed, final count as at October 21, 2026. Read the filings here. Knock-on: Art. 44(1) gives each member state 18 months from this act's entry into force to establish its national register, so that clock has still not started. Evidence: Locked deadline (Art. 44(14)); Signaled status (register entry read in a browser 2026-10-21; the draft text itself has not been read, so nothing here states what the draft requires) Last verified: 2026-10-21 Source: Art. 44(14) in Reg 2025/40
Deadline missed
ACT-09
Digital Marking Methodology, implementing acts (Art. 12(7))
Consequence: Determines the QR/data-carrier spec that must sit alongside (or carry) the 2028 harmonized label, including where a fee-paid symbol like the Green Dot may still appear (inside the QR only). Artwork and data-systems cost, no fee-rate effect.
Due: August 12, 2026 for material composition; January 1, 2030 for the substances-of-concern methodology (Art. 12(7)) Status: Deadline missed Deadline missed for the material-composition methodology, with no register entry, as at October 21, 2026.
More detail
Defines the technical specification for the QR code or other standardized open digital-marking technology that carries packaging marking information, the minimum data it must convey, and interoperability standards. Do not confuse the ACT deadline with the obligation date: the Art. 12(7) implementing acts were due August 12, 2026, while the Art. 12(1) labeling obligation that depends on them runs from August 12, 2028 or 24 months after these acts, whichever is the latest. The second subparagraph of Art. 12(7), the substances-of-concern marking methodology, is due January 1, 2030. This is PPWR digital marking under Art. 12, not an ESPR Digital Product Passport.
Evidence: Signaled Last verified: 2026-10-21 Source: Art. 12 in Reg 2025/40
Deadline missed
Legal Challenges to the Regulation
Twelve actions for annulment against Regulation (EU) 2025/40 are pending before the EU General Court, as at October 21, 2026. Nine of the twelve seek annulment of the whole Regulation; the other three are confined to Art. 50 and Annex X. All twelve case notices have been read in full on EUR-Lex, and the "Affected by case" register was re-read on October 21, 2026: no new case, no withdrawal, no order, no judgment and no reported interim relief since. A pending annulment action suspends nothing: no case has been reported as winning interim relief, so every date on this site stands and you should plan against all of them. Locked for case identity, applicants, provisions and pleas (OJ C-series notices read August 20, 2026); stage is Pending for all twelve, with no order or judgment on the EUR-Lex register.

How to read this table. The cases cluster on four provision groups, and the plea sets repeat: nearly every case argues the PPWR was adopted on the wrong legal basis (internal market, Article 114 TFEU, instead of environment, Article 192 TFEU), that the reasons given are insufficient (Article 296 TFEU), and that the challenged provision is disproportionate or unequal in its treatment of the applicant's format or sector. Every applicant is an industry party: waste-management operators, border-trade retailers, and packaging manufacturers or suppliers. No member state has sued. All twelve actions were filed between March 21 and April 14, 2025, inside the standard two-month challenge window from the January 22, 2025 OJ publication. One procedural note as read from the notices: T-197/25 names the European Commission as defendant, while the other eleven run against the European Parliament and the Council. A note on the counts below: the groupings in this table are taken from the twelve case notices, which state each applicant's own form of order. The EUR-Lex "Affected by case" register, re-read on October 21, 2026, indexes the twelve actions the same way: nine against the Regulation as a whole, five against Art. 29, three against Art. 25 and Annex V, three against Art. 50 (two of them also against Annex X), and one against Art. 7. (Correction, October 1, 2026: an earlier version of this note, based on an August 25 reading, said the register showed five Art. 29 cases where the notices give six and three Art. 25 cases where they give four; the notices give five and three, so the two sources agree.)

CaseApplicant(s)FiledProvisions challengedPleas, condensed
T-197/25Ceska asociace odpadoveho hospodarstvi and four others (Czech waste-management and municipal-services operators)Mar 21, 2025Art. 50(1) to (7), (9) to (12) (deposit and return)Discrimination against existing recycling operators; non-retroactivity and legal certainty; a Czech negotiated derogation disregarded; subsidiarity; financial damage
T-237/25Fleggaard, Scandinavian Park, Scandlines Bordershop (German-Danish border-trade retailers)Apr 11, 2025Art. 50 and Annex X (deposit and return)Wrong legal basis (Art. 114 vs 192 TFEU); Committee of the Regions not involved; freedom to conduct a business (deposit without interoperability); freedom to choose an occupation; free movement of goods
T-238/25IGG, the border-traders association (Flensburg)Apr 11, 2025Art. 50 and Annex X (deposit and return)Five pleas stated as identical to T-237/25
T-236/25Raficon Trade SRL (Romania)Apr 13, 2025Whole Regulation; Art. 29(1) to (3), (4)(d) (reuse targets)Wrong legal basis; failure to state reasons; proportionality of Art. 29(1), (2) and (3)
T-241/25Schutz and seven others (German industrial packaging manufacturers)Apr 13, 2025Whole Regulation; Art. 29(1) to (3) (reuse targets)Wrong legal basis; failure to state reasons; proportionality of Art. 29 as applied to intermediate bulk containers
T-242/25Saier Verpackungstechnik (Germany)Apr 13, 2025Whole Regulation; Art. 29(1) to (3), (4)(c), (4)(d)Wrong legal basis; failure to state reasons; proportionality of Art. 29 as applied to pails; equal treatment against the Art. 29 exceptions
T-247/25Ecoplastica Srl (Italy)Apr 14, 2025Whole Regulation; Art. 29(1) to (3), (4)(d)Wrong legal basis; failure to state reasons; proportionality of Art. 29 as applied to plastic crates; equal treatment under Art. 29(4)(d)
T-249/25Jokey SE and six others (German rigid plastic packaging manufacturers)Apr 14, 2025Whole Regulation; Art. 29(1) to (3), (4)(c), (4)(d)Six pleas stated as identical to T-242/25
T-239/25Belfort International BV (Belgium, single-use plastic packaging supplier)Apr 13, 2025Whole Regulation; Art. 25(1) and Annex V pt 2 (restricted formats)Wrong legal basis; equal treatment of single-use plastic against other materials for the same uses; failure to state reasons; proportionality
T-244/25ILIP Srl (Italy, fresh-produce packaging)Apr 13, 2025Whole Regulation; Art. 25(1), Annex V pts 2 and 3Wrong legal basis; equal treatment; failure to state reasons; proportionality of Annex V pts 2 and 3
T-248/25Dynaplast (France), Nespak (Italy), Veripack Embalajes (Spain)Apr 14, 2025Whole Regulation; Art. 25(1), Annex V pt 2Wrong legal basis; equal treatment; failure to state reasons; proportionality of Annex V pt 2
T-243/25Silver-Plastics (Germany)Apr 13, 2025Whole Regulation; Art. 7(1), (2), (5)(b) (recycled content)Equal treatment on account of the Art. 7 exception; Art. 7(5)(b) against Art. 11 TFEU and Art. 37 of the Charter; wrong legal basis; failure to state reasons

Stage: pending for all twelve, no order, no judgment, no reported interim relief, as at October 21, 2026. Sources: EUR-Lex record for Regulation (EU) 2025/40, "Affected by case" panel, re-read October 21, 2026, and the twelve OJ C-series case notices (C/2025/2903, C/2025/3066, C/2025/3068, C/2025/3069, C/2025/3070, C/2025/3073, C/2025/3074, C/2025/3075, C/2025/3302, C/2025/3303, C/2025/3304, C/2025/3305), each read in full on EUR-Lex on August 20, 2026 Locked. Plea wording is condensed from the notices; open each case link for the full text.

PPWR Toolkit / Format Risk Screener

Format Risk Screener
Quick recyclability and compliance risk lookup by packaging format, now with an EN 18120 design-for-recycling score per format.

Design for Recycling: Grade Ladder (preview)

PPWR Annex II grades packaging recyclability by weight (Grades A, B, C only; below 70 percent is non-recyclable). The per-category technical criteria are pending the design-for-recycling delegated act (ACT-02, due Jan 1, 2028), so the assignments below are provisional, for orientation only.

Market-access ladder: from Jan 1, 2030, or 24 months after the Art. 6(4) delegated acts enter into force, whichever is the latest, packaging must reach at least Grade C to be placed on the EU market; from Jan 1, 2035, or five years after the Art. 6(5) implementing acts enter into force, whichever is the latest, the recyclable-at-scale test applies; from Jan 1, 2038 only Grade A or B is permitted.

Grade A: 95%+

Expected to attract the largest EPR fee discounts. Clear PET bottles, natural HDPE, aluminum cans, glass, uncoated kraft board.

Grade B: 80%+

Moderate discount. PP tubs, mono-material PE flexibles where collection exists.

Grade C: 70%+

Minimum to stay on the market from 2030, or 24 months after the Art. 6(4) act, whichever is the latest. Beverage cartons, some flexibles, coated fiber.

Below Grade C

Non-recyclable. Off the market from 2030. Multilayer laminates, PVC, carbon-black plastic, EPS.

Risk ratings reflect current best assessment based on PPWR text and JRC draft guidance. ACT-02 (DfR criteria) has not been finalized, so exact Grade A/B/C assignments are pending. PPWR Annex II defines only Grades A, B, and C; packaging below 70 percent recyclability is non-recyclable. Use for planning; verify against ACT-02 once adopted.

Format risk ratings, with EN 18120 design read

Each format card shows two reads: a PPWR recyclability risk rating (the badge on the right, based on the PPWR text and JRC draft guidance), and an EN 18120:2026 design-for-recycling traffic-light for plastic formats. EN 18120 (CEN/TC 261/SC 4/WG 10) is the new European Design for Recycling standard for plastic packaging; it classifies design features by compatibility with real recycling infrastructure: Green compatible, Yellow limited, Red incompatible. Developed under Commission mandate M/584 to feed the PPWR method, it is voluntary for now and covers plastics only, so non-plastic formats show Out of scope. The traffic-light is an indicative design screen, not the binding PPWR grade; the legal method is the pending Article 6(4) delegated act (ACT-02, due Jan 1, 2028).

What drives a format risk rating

These are the design factors the screener scores against. They are public recycling-infrastructure principles, not the per-format ratings, and they are worth knowing before you unlock the screener. Full detail at ppwratlas.com/format-risk-screener/.

See the full screener

You are previewing the risk screener. Add your details to unlock every format, the search, and the full risk detail.

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Clear PET Bottle (beverage)
Mono-material clear or light-blue PET, separable closure. Standard beverage bottle format.
EPR: Lower rate under eco-modulation. DRS: In scope in DE, NL, FI, SE, DK, EE, LV, LT, HR, RO, SK, HU, IE and others.
EN 18120: Green Parts 4/10 (PET bottles). Mono-material clear PET with a separable closure, the reference recyclable design.
Grade A Likely
HDPE Rigid Container (natural/white)
Milk bottles, detergent bottles, shampoo containers in natural HDPE. Mono-material, sortable.
EPR: Lower eco-modulation rate. Favored format for DfR compliance.
EN 18120: Green Parts 6/12 (PE/PP rigid). Mono-material natural HDPE, NIR-sortable.
Grade A/B Likely
Aluminum Beverage Can
Standard aluminum can. Highly recyclable, established collection infrastructure across EU.
EPR: Lower rate. DRS: In scope across most active DRS markets. PCR content achievable via closed-loop recycling.
EN 18120: Out of scope Plastic packaging only. Metal recyclability sits under EN 13430; well-established stream.
Grade A Likely
Glass Bottle / Jar
Standard soda-lime glass packaging. Well-established recycling stream across EU.
EPR: Lowest fee rates in most markets. DRS scope varies, excluded from some DRS systems.
EN 18120: Out of scope Plastic packaging only. Glass recyclability sits under EN 13430.
Grade A Likely
PP Rigid Container / Tub
Yogurt pots, margarine tubs, food containers in polypropylene.
EPR: Moderate eco-modulation rate. Clear/natural PP preferred. Label/sleeve compatibility important for grade.
EN 18120: Green Parts 6/12 (PE/PP rigid). Clear or natural PP is design-aligned; full-body sleeves or dark pigment move it to Yellow.
Grade B Likely
Mono-Material PE Flexible Pouch / Film
Stand-up or lay-flat pouch in a single polyethylene family, no barrier layers or foil laminate.
EPR: Medium rate. Grade B in markets with flexible PE infrastructure; Grade C where collection is limited. Market-dependent.
EN 18120: Yellow Parts 7/13 (PE/PP flexible). The mono-PE structure is design-aligned, but flexible-PE collection and sorting are immature in many markets.
Grade B/C, Market Dependent
Opaque / Dark-Pigmented PET Bottle or Container
PET packaging colored with dark or opaque pigments, including most black-pigmented containers.
FR: CITEO applies its 100% malus to dark rigid plastic that optical sorting cannot detect, carbon black named, and withdrew its separate opaque-PET malus for 2026. DE: Higher dual-system fee for non-recyclable formats under the VerpackDG design-incentive structure. IT: High Corepla band. Carbon black prevents NIR sorting, high risk across EU.
EN 18120: Red Parts 4/5/10/11 plus Part 3 (sortability). Carbon black or dark pigment blocks NIR detection, so the pack fails sorting.
Grade C / Non-Recyclable Risk
Multi-Layer Flexible Laminate / Foil Pouch
Stand-up or flat pouches combining PE/PP/PET layers with aluminum foil or EVOH barrier. Non-separable composite.
High-risk format. Non-separable composite is effectively unrecyclable. ACT-02 expected to classify it as non-recyclable (below Grade C). In FR it is priced at the CITEO complex-packaging tariff (140.01 ct/kg, against 77.01 for PE film) rather than by malus; high band in IT. 2030 market-access risk is high.
EN 18120: Red Parts 7/13 (PE/PP flexible). Non-separable multi-material and barrier layers are incompatible with mechanical recycling.
Non-Recyclable Risk, 2030 Market Ban
Expanded Polystyrene (EPS), Food Contact
EPS foam trays, cups, boxes for food service or perishable packaging.
SUP Directive restrictions apply to some food-service EPS formats. Non-recyclable (below Grade C) risk under ACT-02. Limited collection infrastructure. Eco-modulation treatment varies by national scheme.
EN 18120: Red Parts 9/15 (EPS). Sparse collection and sorting plus food-contact contamination make it incompatible in practice.
Non-Recyclable Risk
PVC Packaging (clamshell, blister)
Rigid PVC clamshells and blister packs for retail consumer electronics, hardware, food.
PVC is incompatible with most plastic recycling streams. Below Grade C in draft JRC guidance. Design substitution to PET clamshell strongly recommended.
EN 18120: Red No dedicated EN 18120 part; the protocols treat PVC as a cross-stream disruptor. Substitute to PET.
Below Grade C, Substitution Needed
PFAS-Coated Paper / Board (cups, wrappers, trays)
Paper cups, fast-food wrappers, bakery trays, microwave packaging with fluorinated grease-resistant coatings.
BANNED from Aug 12, 2026 if PFAS content exceeds 25 ppb individual, 250 ppb sum, or 50 ppm total including polymeric PFAS. Test all grease-resistant paper and board formats immediately. Reformulation lead time: 12–18 months.
EN 18120: Out of scope Plastic packaging only; this is fiber-based. Also banned from Aug 12, 2026 above the PFAS limits regardless of recyclability.
BANNED Aug 2026
Composite Beverage Carton (aseptic / chilled)
Carton formats combining paperboard, PE layers, and aluminum foil (e.g., Tetra Pak, Elopak).
Recyclable in dedicated carton streams only. Grade C anticipated, composite structure impairs recyclability. Some markets lack dedicated carton collection.
EN 18120: Out of scope Fiber-based composite, outside EN 18120 (plastic only). Assess under fiber schemes (4evergreen) and dedicated carton streams.
Grade C Anticipated
Recycled Paperboard / Kraft Board Carton
Secondary and tertiary packaging in recycled paperboard. Widely collected. High PCR content often already present.
EPR: Low rates, below every plastic category in each market priced here. Grade A likely. Barrier coatings (PE, wax) may reduce grade, specify barrier-free where possible.
EN 18120: Out of scope Plastic packaging only; this is fiber-based. Strong recyclability under EN 13430 and fiber schemes (4evergreen).
Grade A Likely
Compostable PLA / Bio-Based Plastic
Packaging from polylactic acid or other bio-based compostable materials. Often used for cups, trays, cutlery.
Bio-based origin does not determine PPWR recyclability grade. PLA not recyclable in standard plastic streams. Permitted only for specific applications (ACT-05 pending). Italy TRIS notification may affect scope.
EN 18120: Out of scope EN 18120 covers PET, PE, PP, PS and EPS, not PLA. PLA is a composting route, not recyclable in mainstream plastic streams.
Pending ACT-05
Carbon-Black Pigmented Plastic
Any plastic packaging colored with carbon black pigment (black trays, containers, lids).
Carbon black absorbs NIR light, invisible to NIR sorting equipment. CITEO applies its 100% malus to dark rigid plastic that optical sorting cannot detect. ACT-02 expected to classify it as non-recyclable (below Grade C). Substitute with carbon-black-free alternatives.
EN 18120: Red Part 3 (sortability). Carbon black absorbs NIR, so the pack is invisible to standard sorting. Use detectable pigments.
Non-Recyclable Risk
Full-Body Shrink Sleeve on PET/HDPE
PVC or PET shrink sleeve applied to a PET bottle for decoration/branding.
PVC sleeves on PET bottles: contamination risk, downcycles bottle. PET sleeves: better compatibility. Specify PET sleeve with perforation for easy removal.
EN 18120: Red Parts 4/5 (PET) plus label and sleeve criteria. A PVC or full-coverage sleeve is a disruptor (Red); a perforated PET sleeve is Yellow.
Grade C Risk (PVC sleeve)
Labeling Requirements
Consolidated view of PPWR packaging labeling: harmonized pictograms, deposit and reuse marks, the Green Dot transition, and surviving national marks. Evidence labels show how settled each item is.
Article 12 harmonized labeling. PPWR replaces the national label patchwork with one EU label that uses pictograms for material composition and sorting. The Commission implementing act that specifies the pictograms was due by August 12, 2026 [SIGNALED, not adopted as at October 21, 2026; Have Your Say initiative 19243 plans adoption in the second quarter of 2027]. The label then applies from August 12, 2028, or 24 months after the Art. 12(6) or 12(7) implementing acts enter into force, whichever is the latest [LOCKED date].

Key Labeling Dates

DateRequirementEvidence

What Changes

Pictogram artwork and minimum sizes are not final until the Art. 12 implementing act publishes. Treat label redesign specifications as provisional until then. This section is updated when the act is adopted. Full detail at ppwratlas.com/labeling/.
About PPWR Atlas
Who builds and maintains this hub, the advisory work behind it, and how the data is kept current and trustworthy.

About the Author

Dave Hartter

I'm Dave Hartter, a packaging and product sustainability advisor based in Charlotte, NC, with more than 20 years of sustainability, R&D and quality experience inside global manufacturers. I view sustainability as a driver of business performance, not just a reporting requirement: understand the market and regulatory environment, identify the risks and opportunities, and build programs that go beyond compliance to drive business value.

As Director of Sustainability, I led product sustainability at Huber Engineered Materials, a division of J.M. Huber. There, I applied tools such as Life Cycle Assessment and Portfolio Sustainability Assessment to understand the regulatory environment, market trends, and customer requirements to drive sustainability into business decisions and customer messaging. At Newell Brands, I led the development of the packaging sustainability program from the ground up, from developing 2025 goals aligned to internal and external stakeholders to building out the tools, systems and training that delivered measurable results. Sustainability programs succeed only when cross-functional teams are engaged and have the tools and training to deliver on the goals.

Today, I advise manufacturers and packaging suppliers directly. The Atlas hubs are the public side of that work. I built them so teams spend less time getting up to speed and more time delivering results. Connect with me on LinkedIn.

Hartter Advisory

Advisory Services

The Atlas provides the information necessary to understand what the PPWR requires and what it costs. Companies throughout the packaging supply chain can then understand the near and long-term risks and opportunities to their business. Whether your company is just starting to scope its PPWR obligations or already understands the financial impact of EU EPR fees and needs a customized strategy to reduce them, I can help.

Engagements I can help you with:

  • PPWR strategy and fee-reduction roadmaps: where your fees will land across EU markets, and which design, material, and data moves reduce them.
  • Design for recyclability: assessing a portfolio against the PPWR recyclability grades and eco-modulation criteria, and prioritizing the changes that pay back.
  • LCA and packaging sustainability programs: building the measurement and design capability in-house, from a first LCA to portfolio coverage.
  • Regulatory readiness: registration, Authorized Representative appointment, reporting, and data requirements, and getting a company through its first compliance cycle without surprises.

To discuss PPWR compliance, fees, or packaging redesign for your portfolio, email Dave Hartter at dave@hartteradvisory.com.

About the Site

The EU Packaging and Packaging Waste Regulation is moving fast. Regulation (EU) 2025/40 applies from August 12, 2026, its recyclability, recycled-content, labeling, reuse and deposit return rules phase in through a series of delegated and implementing acts, and each national EPR scheme modulates fees its own way. Most coverage assumes you already know the rules or sits behind a consulting paywall. PPWR Atlas is one free place that tracks all of it: deadlines, recyclability grades, eco-modulation, EPR fees, labeling and the pending acts across the EU and its key national markets, updated weekly.

How the data is maintained

Regulatory data is only useful if you can trust it and if it's current, so PPWR Atlas runs on a few standing rules.

Every date, threshold, grade, and fee is tied to a primary source: the regulation text on EUR-Lex, an adopted delegated or implementing act, official Commission guidance, or a national PRO's published schedule. Each figure carries a visible evidence label, LOCKED for a settled rule, SIGNALED for one that is expected but not yet adopted, and SPECULATIVE for a projection, so you can see the difference between a rule that is fixed and one that is still forming. A national scheme's rule is never presented as a harmonized PPWR requirement.

The site is not to be viewed as legal advice. Rules change, and your obligations depend on the specifics of your company. Verify anything consequential against the primary sources or with qualified legal counsel before acting on it.

The other Atlases

PPWR Atlas is one of three regulatory intelligence sites:

  • PPWRAtlas.com: the EU Packaging and Packaging Waste Regulation (this site)
  • EPRAtlas.com: U.S. packaging Extended Producer Responsibility
  • ESPRAtlas.com: the EU Ecodesign for Sustainable Products Regulation and Digital Product Passports
Latest Updates
Recent PPWR developments, split into regulatory and policy movement and site updates. Updated October 21, 2026. Every entry below has its own page: read the latest weekly update or browse the full dated archive.

Jump to Site Updates

Latest Regulatory & Policy

Regulatory & Policy October 21, 2026

The EU Sorting Label Act Slips to Mid-2027

The Commission now plans to adopt the implementing decision that sets the EU's harmonized sorting label in the second quarter of 2027, not in the fourth quarter of 2026 as its register showed earlier this month. The draft has still not been released for comment.

What this means for your artwork. Under Article 12(1) the label applies from August 12, 2028, or 24 months after the implementing acts enter into force, whichever is the latest. On the Commission's new plan the earliest realistic date for the EU label is about mid-2029, so artwork printed for 2028 does not need it. The February 12, 2027 change for EPR-scheme marks such as the Green Dot (Art. 12(9)) is not affected.

What to do. Do not budget a 2028 label changeover. Subscribe at Have Your Say initiative 19243 to hear when the draft opens for comment, because that window is the one chance to shape the pictograms and placement rules. Source: European Commission, Have Your Say initiative 19243, read October 21, 2026; Reg (EU) 2025/40 Art. 12(1), OJ text. [SIGNALED] on the plan; the mid-2029 floor is derived from Art. 12(1) and the plan, not stated by the Commission.

Regulatory & Policy October 20, 2026

Parliament Votes to Limit the Representative Suspension to Small Firms

On October 20, 2026 Parliament adopted its amendments to the proposal that would pause the duty to appoint an authorized representative for EPR in each EU country where you sell directly to end users (Art. 45(3)). Its version limits the pause to micro and small enterprises established in the EU, ends it on January 1, 2035 or when a new EU-wide EPR law applies, whichever is earlier, and keeps the duty in place for producers outside the EU.

What this means for you. The law has not changed and the duty applies today. Parliament sent the file back to its environment committee to negotiate with the Council, which dropped these EPR proposals from its own mandate in June, so no final text is in sight. Medium and large firms would get no relief under Parliament's version. Separately, the Commission's new guide for small businesses says it has asked member states to enforce the duty in a constructive and pragmatic way and not to sanction operators while the proposal is examined. That is a request to national authorities, not a suspension.

What to do. Keep appointing representatives where you sell directly to end users in another member state. A micro or small business should follow procedure file 2025/0395(COD) and read the Commission guide for small businesses. Source: European Parliament, texts adopted P10_TA(2026)0345 of October 20, 2026 and committee report A10-0266/2026 of October 9, 2026, Art. 2 as amended; European Commission, DG ENV small-business EPR guide, read October 21, 2026. [SIGNALED]: Parliament's amendments are a negotiating position, not law.

Regulatory & Policy October 7, 2026

Tell the Commission Where Recycling Targets Will Be Missed

The Commission has opened a call for evidence for its 2027 early warning report, the exercise that names which member states are at risk of missing the 2030 recycling targets, including the packaging material targets. Feedback is open to anyone until midnight Brussels time on October 26, 2026.

This is not a PPWR act and it creates no new duty on your packaging. It matters for a different reason. The countries the report names are the ones most likely to respond by raising producer fees or tightening collection rules, and the report is built partly from what industry puts on the record now. If you place packaging in a market you believe is behind, this is the cheapest way to say so before the conclusions are written.

What to do. Read the three-page call for evidence and file a response at the Have Your Say page. Source: European Commission, Have Your Say initiative 17712, call for evidence Ares(2026)9129916, feedback period September 28 to October 26, 2026, read October 6, 2026. [LOCKED].

Regulatory & Policy September 22, 2026

The EU Sorting Label Act Is Now Scheduled for Late 2026

The Commission has opened a register entry for the implementing decision that will set the EU's harmonized sorting label and the related labels for reusable packaging, deposit packaging, and recycled or bio-based content. Adoption is planned for the fourth quarter of 2026, after a draft goes out for comment.

What this means for your artwork. Under Article 12(1) the label cannot be required until 24 months after the act takes effect, or August 12, 2028, whichever is later. With no act in force by August 2026, the 2028 date in most guidance is out of reach, and on the Commission's own plan the earliest realistic date is late 2028. Do not lock sorting-label artwork to a 2028 changeover.

What to do. Comment on the draft when it appears, because that window is the one chance to shape the pictograms and placement rules. You can subscribe for a notification at Have Your Say initiative 19243. The February 12, 2027 date for ending the standalone printed Green Dot as an EPR-scheme mark (Art. 12(9)) is unaffected and close.

Source: European Commission, Have Your Say initiative 19243, register entry read September 22, 2026; Reg (EU) 2025/40 Art. 12(1), OJ text. [SIGNALED] on the plan; the late-2028 floor is derived from Art. 12(1) and the plan, not stated by the Commission. Current status is at ACT-04 on the Delegated Acts tab.

Update, October 21, 2026. The register now plans adoption in the second quarter of 2027, which moves the earliest realistic label date to about mid-2029.

Regulatory & Policy September 22, 2026

Three Recycled-Content Consultations Have Closed

The Commission's three early consultations on recycled plastic in packaging closed on September 16, 2026. They cover how recycled content is calculated and verified (Article 7(8), 188 responses), the sustainability criteria that decide which plastic recycling technologies count (Article 7(9), 223 responses), and the conditions for counting recycled material imported from outside the EU (Article 7(10), 142 responses). All three acts are due by December 31, 2026.

Correction. The August 25 entry missed the Article 7(9) call, which the Delegated Acts tab now carries as ACT-11.

What changes for you today: nothing. The 2030 recycled-content minimums apply from January 1, 2030 or three years after the calculation act takes effect, whichever is later, so these acts can still move that date. If your plan leans on chemical recycling, Article 7(9) decides whether that output counts, and if it leans on imported recyclate, Article 7(10) does.

Source: European Commission Have Your Say initiatives 18753 (Ares(2026)7895997), 19033 (Ares(2026)7896093) and 18752 (Ares(2026)7896043), register entries read September 22, 2026; Reg (EU) 2025/40 Art. 7(8), 7(9) and 7(10), OJ text. [SIGNALED] on status.

Regulatory & Policy September 18, 2026

A Seventh PPWR Corrigendum Fixes the Italian Producer Definition

A seventh PPWR corrigendum was published in the Official Journal on September 18, 2026, and like the six before it, it changes one language version only, this time the Italian. It fixes the producer definition for packaging or packaged goods sold directly into another EU country (Article 3(1)(15)(c) and (d)), where the Italian said "consumers" in place of "end users" and point (d) was garbled.

What this means for you. If you sell directly to business customers in another member state, you are the producer there, and the Italian text now says so too. The English text has never had a corrigendum, so nothing moves for anyone working from it. If you or your Italian counsel work from the Italian, use the corrected version, especially for authorized-representative decisions under Article 45(3), which turn on these two points.

Source: Corrigendum to Regulation (EU) 2025/40, OJ L, 2026/90776, September 18, 2026, read September 22, 2026; EUR-Lex register for CELEX 32025R0040, "Corrected by" table, seven entries as at September 22, 2026. [LOCKED] The current corrigenda count is on the Delegated Acts tab.

Regulatory & Policy September 15, 2026

The EU Producer-Register Consultation Has Closed

The rule that would let you register once for the whole EU instead of 27 times took its last comments on September 10, 2026. The draft implementing regulation under Article 44(14) drew 7,667 responses, one of the heaviest turnouts for any packaging consultation, many from small sellers arguing that country-by-country registration keeps them out of other member states.

What changes for you today: nothing. You still register in every country where you count as a producer, on its own portal and in its own format. The draft was due on February 12, 2026, and the 18 months member states get to set up registers in the EU format start only when the act enters into force, on a date nobody has given. (Corrected October 2, 2026: the 18 months run from entry into force, not adoption.)

What to do. Do not delay a registration you owe now in the hope this lands first. If you sell into several member states, keep your packaging data in one structure of your own, so a single EU format means reformatting one dataset rather than reconciling 27. The draft and the filed responses are at Have Your Say initiative 15352. Source: European Commission, draft implementing regulation Ares(2026)7688068 and its Annex, feedback period August 6 to September 10, 2026, register read September 15, 2026.

Regulatory & Policy September 1, 2026

Do Not Plan Around the Authorized-Representative Suspension

If you sell packaged goods straight to consumers in an EU country where your company is not established, you must appoint an authorized representative for EPR there. The duty is live now, whether you are based inside or outside the EU (Art. 45(3)), and waiting for Brussels to switch it off is a mistake.

What happened. COM(2025) 982, procedure 2025/0395(COD), which covers the Batteries Regulation and the PPWR together, proposes suspending the duty for EU-established producers until January 1, 2035. The Council dropped the extended-producer-responsibility proposals from its negotiating mandate on June 24, 2026. In Parliament, where the file awaits an environment committee decision, the rapporteur's draft report would limit the relief to micro and small enterprises trading cross-border inside the EU, make it strictly temporary pending the Circular Economy Act review, and leave producers established outside the EU where they are. The Legislative Observatory then gave October 5, 2026 as the indicative first-reading plenary date.

What this means for you. Nothing has been adopted, and the Parliament version is much smaller than the proposal. A large or mid-sized business should appoint representatives country by country and treat any relief as a bonus. A micro or small business selling cross-border inside the EU is the group the draft would help, so the file is worth watching, but the duty is owed today. Track it at procedure file 2025/0395(COD)

Update, October 7, 2026. The Legislative Observatory now records a vote in committee on October 5, 2026, and gives October 19, 2026 as the indicative first-reading plenary date. No committee report has been published and the file still reads "Awaiting committee decision", so what the committee actually adopted cannot be read yet. Nothing about the duty has changed. [SIGNALED]: a rapporteur draft report is one member's proposal, not Parliament's position, and the committee vote has no published text behind it.

Update, October 21, 2026. Parliament adopted its amendments on October 20, 2026 and sent the file back to committee for negotiations with the Council. The duty still applies; see the October 20 entry.

Regulatory & Policy August 25, 2026

Greece Has an Operator, a Scope and Two Deposit Tiers. It Just Has No Date

This site had listed Greece's deposit operator and deposit as "to be confirmed". Enough is now published to start work on artwork.

What is settled. DRS Hellas S.A., incorporated on October 7, 2025, is the sole Collective Alternative Management System for the Greek scheme, founded by soft drinks, juice, beer, and bottled water producers with retail through the Hellenic Supermarket Union. Scope is plastic bottles and metal beverage containers up to 3 liters, matching the PPWR Article 50 scope, and in-scope containers need three markings, the DRS logo, a barcode, and the deposit value.

The deposit has two tiers. It is 0.10 euro up to 0.5 liters and 0.15 euro between 0.5 and 3 liters, so a single figure, or the range without the 0.5 liter boundary, prices it wrong. The refund is a voucher spendable in participating stores rather than the cash most European schemes pay, which matters if you model return rates in Greece.

What is NOT settled: the date. DRS Hellas is still pending licensing by the Hellenic Recycling Agency (EOAN), activation is phased with tenders open, and no go-live date has been published. The operator targets up to 90 percent collection by 2029, in line with the Article 50(1) duty on Greece. Plan the artwork now, but do not accept a launch date from anyone, because there is not one yet.

Source: DRS Hellas S.A., drshellas.gr, company and scheme pages read August 25, 2026. [LOCKED] on the operator, scope and deposit tiers.

Regulatory & Policy August 25, 2026

Draft Rules for One EU Producer Register Are Open for Comment Until September 10

Registering separately in every member state, on 27 different data structures, is the biggest recurring admin cost in EU packaging compliance. The act meant to fix that, under Article 44(14), was due on February 12, 2026. The Commission published it as a draft implementing regulation with a 19-page annex on August 6, 2026 and took feedback until September 10, 2026, drawing 7,667 responses.

What this changes today: nothing. You still register country by country, and will for a while after adoption, because member states get 18 months from the act's entry into force to establish their national registers. (Corrected October 1, 2026: the 18 months run from entry into force, not adoption.) What changes is the planning horizon, since there is now a text and a timetable.

What to do. If you register in more than two member states, read the draft annex, because it sets the data fields you will report against for years. Most of the 6,333 responses filed by August 25 came from small cross-border sellers arguing about the authorized-representative burden. The draft and the filings are at the Commission's Have Your Say register.

Source: European Commission Have Your Say, initiative 15352, draft implementing regulation Ares(2026)7688068, register entry read August 25, 2026. [SIGNALED] on status.

Regulatory & Policy August 25, 2026

Two Recycled Content Consultations Close September 16

On August 14 the Commission opened calls for evidence on three acts that decide how recycled content gets counted: the Article 7(8) methodology for calculating and verifying recycled content in plastic packaging, the Article 7(9) sustainability criteria for plastic recycling technologies, and the Article 7(10) rules for recognizing recycled material imported from outside the EU. All three took feedback until September 16, 2026 and drew 188, 223, and 142 responses. (Corrected September 22, 2026: added the Article 7(9) call, which this entry first missed.)

Why the methodology matters. It decides whether chemical recycling counted through mass balance can be used toward the 2030 minimums. If it can, your sourcing options widen considerably, and if it cannot, mechanical recyclate is the only route and supply tightens. It also moves the deadline, because the Article 7(1) targets apply from January 1, 2030 or three years after this act enters into force, whichever is later.

Why the import rules matter. If any of your recyclate comes from outside the EU, this act decides whether it counts at all.

What to do. A call for evidence comes before any draft text, while the shape of the rule is still open. The filings are public on the Article 7(8) methodology and the Article 7(10) import rules.

Source: European Commission Have Your Say, initiatives 18753 (Ares(2026)7895997) and 18752 (Ares(2026)7896043), register entries read August 25, 2026. [SIGNALED]

Regulatory & Policy August 25, 2026

The Labeling Deadline Passed With No Act, So 2028 Is Now a Floor

Articles 12(6) and 12(7) required the Commission to publish the implementing acts setting the harmonized sorting label by August 12, 2026. That date has passed with no act, and the Commission's implementation page says only that it is "currently preparing" one, with no draft or consultation on the register. Current status is in the September 22 entry and at ACT-04 on the Delegated Acts tab.

What that means for artwork planning. The harmonized label applies from August 12, 2028, or 24 months after these acts enter into force, whichever is later. With the acts unwritten, the 24-month leg governs, so 2028 is the earliest possible date and each month of delay moves the label date by a month.

What does not move. The Article 12(9) rule ending the standalone printed Green Dot as an EPR-scheme identifier runs on its own clock and applies from February 12, 2027. Article 12(8), the restriction on misleading marks for matters PPWR harmonizes, has applied since August 12, 2026. National labels such as Triman in France and the Italian alphanumeric scheme stay in force meanwhile.

The practical read. Do not commission harmonized-label artwork yet or accept that 2028 is fixed, but do prepare for the Green Dot change on February 12, 2027.

Source: Reg (EU) 2025/40 Arts. 12(6), 12(7), 12(8) and 12(9), OJ text; European Commission PPWR implementation page, read August 25, 2026. [LOCKED] on the provisions, [SIGNALED] on the act's status.

Regulatory & Policy August 12, 2026

PPWR Applies From Today in All 27 Member States

Regulation (EU) 2025/40 applies from today in all 27 member states, and as a regulation it binds directly with no national law needed. Four things start now: the PFAS restriction on food-contact packaging, which sets three limits that all apply together, 25 ppb for any single PFAS and 250 ppb for the sum, both excluding polymeric PFAS, plus 50 ppm for total PFAS including polymeric; the Declaration of Conformity under Art. 39; the deadline to appoint an authorized representative for EPR under Art. 45(3), which binds any producer selling directly to end users in a member state other than the one it is established in, inside the EU or outside it; and Germany's VerpackDG. Art. 67(5) is the one exception and waits until February 12, 2029.

What this means for you. The duty exists today everywhere, whether or not the member state has named an enforcement authority, and thirteen have not. Recyclability grades, recycled content minimums, the empty space cap, and the reuse targets sit at 2030 or later, and each of those dates is a floor that moves later if the act it depends on is late. Nothing you print today needs a harmonized sorting label.

What to do. Confirm your Declaration of Conformity exists and is signed. If you are outside the EU, confirm your authorized representative is appointed in writing in each member state. If you use fluorinated food-contact materials, ask suppliers for total fluorine evidence now, because that duty is triggered on request above 50 mg/kg. Source: Regulation (EU) 2025/40, Art. 71, OJ L, 2025/40, 22.1.2025 [LOCKED].

Regulatory & Policy August 12, 2026

Twelve Annulment Actions Against the PPWR Are Pending at the EU General Court

Twelve actions for annulment against the PPWR are pending before the EU General Court, filed during 2025 and confirmed on the EUR-Lex record for the Regulation as at August 11, 2026: T-197/25, T-236/25, T-237/25, T-238/25, T-239/25, T-241/25, T-242/25, T-243/25, T-244/25, T-247/25, T-248/25 and T-249/25. Nine of the twelve ask the Court to strike the whole Regulation: T-236/25, T-239/25, T-241/25, T-242/25, T-243/25, T-244/25, T-247/25, T-248/25 and T-249/25. The other three are limited to Art. 50 and Annex X, the deposit and return system rules: T-197/25, T-237/25 and T-238/25.

Each whole-Regulation case still argues from a particular provision, in three groups: Art. 29, the reuse targets, in five (T-236/25, T-241/25, T-242/25, T-247/25, T-249/25); Art. 25 and Annex V, the restricted packaging formats, in three (T-239/25, T-244/25, T-248/25); and Art. 7, the recycled content minimums, in one (T-243/25). Read those as where each grievance starts, not the limit of what is asked. (Corrected September 9, 2026: the counts were first given as seven, six, and four.)

What this means for you. Nothing changes today. A pending annulment action does not suspend a regulation, and none of these cases has been reported as winning interim relief, so every date on this site stands. The cases show where the legal risk sits, in the four provision groups that make up most of the expensive part of the Regulation and whose detail is still being written in delegated and implementing acts. A 2030 capital plan that depends on one reading of the reuse targets or the format bans carries more legal uncertainty than the text suggests.

What to do. Keep complying, because delaying a 2030 program for a case that fails loses years, and flag the cases to whoever signs off your capital spend. Source: EUR-Lex record for Regulation (EU) 2025/40, "Affected by case", read August 11, 2026: EUR-Lex CELEX 32025R0040. The live case table, with applicants, provisions and pleas from the case notices, is on the Delegated Acts tab.

Regulatory & Policy August 12, 2026

The Labeling Implementing Act Missed Its Deadline, Which Pushes 2028 Back

Art. 12(6) and 12(7) required the Commission to adopt the harmonized labeling implementing acts by today, and it has not. On August 11, 2026 the EUR-Lex record listed no implementing act completing Art. 12, and the only act completing the Regulation at all is the pallet wrap exemption. The technical groundwork is the Joint Research Centre's proposal for harmonized waste-sorting labels on packaging and waste receptacles, published in January 2026 (JRC141706, EUR 40581) to inform the Art. 12(6) and 13(2) implementing acts. (Corrected September 30, 2026: a description of the label design was replaced with this citation.)

What this means for you. The labeling obligation applies from August 12, 2028 or 24 months after those acts enter into force, whichever is later. That "whichever is later" now governs, so 2028 moves with every month of delay and is a floor rather than a deadline. You also do not yet know what the label will look like.

What to do. Do not commission final sorting-label artwork yet. Watch for the draft act and its consultation, your only chance to comment on the pictogram set before it is fixed. Source: absence of any Art. 12 implementing act on the EUR-Lex record for Regulation (EU) 2025/40, read August 11, 2026: EUR-Lex CELEX 32025R0040; JRC technical proposal JRC141706 (EUR 40581), January 2026 [SIGNALED].

Regulatory & Policy August 4, 2026

Half the EU Has Not Named a PPWR Enforcement Authority, Eight Days Out

Article 40(3) requires every member state to tell the Commission which authorities apply and enforce the PPWR. As of August 4, fourteen have done so: Belgium, Czechia, Denmark, Germany, Estonia, Ireland, France, Croatia, Lithuania, Luxembourg, the Netherlands, Austria, Slovenia and Sweden, plus Norway and the United Kingdom. Thirteen have not: Bulgaria, Greece, Spain, Italy, Cyprus, Latvia, Hungary, Malta, Poland, Portugal, Romania, Slovakia and Finland. Luxembourg's designation is marked provisional pending national law.

What this means for you. Your obligations start on August 12 everywhere, whether or not an authority has been named. What differs is who comes asking and how soon. In the fourteen that have notified, expect questions and inspections on time. In Italy, Spain, and Poland, three of the largest markets on this site, there is no published body for a compliance question, a Declaration of Conformity query, or a dispute. That is a timing gap, not a holiday, because the duty accrues from August 12.

What to do. Check the list before you file, since it is updated as notifications arrive, and save each authority's contact now. Several countries split the role. Estonia names three bodies, Ireland divides obligations article by article between the EPA, the Minister, and local authorities, and the Netherlands names both ILT and Rijkswaterstaat with a mailbox at PPWR@ilent.nl. Current list: European Commission, PPWR implementation page. Source: European Commission PPWR implementation page, Article 40(3) notifications, read August 4, 2026 [LOCKED]. The current tally is on the Delegated Acts tab.

Regulatory & Policy August 4, 2026

A Sixth PPWR Corrigendum, in German, and Still Nothing Changes in English

The Official Journal published a German-language corrigendum to Regulation (EU) 2025/40 on August 4, 2026. On page 59, Article 29(4)(b) now reads "Waren" (goods) where it read "Rohstoffe" (raw materials), in the clause exempting custom-designed transport packaging for large-scale machinery, equipment, and goods from the Article 29 reuse targets.

What this means for you. If you work from the German text and read that exemption as covering machinery, equipment, and raw materials only, it is broader than you thought and may now cover finished goods in custom-built transport packaging. Nothing changes in English, where Article 29(4)(b) has read "commodities" since publication.

The wider point. This is the sixth PPWR corrigendum, after May 22 2025, September 9 2025, November 25 2025, November 28 2025, and July 21 2026, and none has corrected the English text, which stands as published on January 22, 2025. If your team quotes the Regulation from another language version, re-check those quotations against the current version. Read it at EUR-Lex, OJ L, 2026/90654. Source: OJ L, 2026/90654, August 4, 2026 [LOCKED].

Regulatory & Policy July 31, 2026

Commission Publishes a Second Edition of Its PPWR FAQ, Without Announcing It

DG Environment published a second edition of its PPWR FAQ through the Publications Office on July 31, 2026, without announcement (ISBN 978-92-68-42316-5, catalog number KH-01-26-068-EN-N, DOI 10.2779/4868962; the March edition was ISBN 978-92-68-37678-2). It has 20 sections and 155 numbered questions across 69 pages, against 19 sections and 50 pages, with every change tagged NEW or UPDATED. The DG ENV landing page still displays "30 March 2026", but its download link now redirects to the new record. New Section XVI covers enforcement after August 12, 2026. The Commission states that "the enforcement of the obligations applicable as from 12 August 2026 should not disrupt trade flows, supply chains or consumer access to goods", that Article 62 requires a Member State to first require the operator to end the non-compliance and give it an opportunity to correct before prohibiting, recalling or withdrawing packaging, and that market surveillance authorities should support responsible operators rather than follow a sanction-oriented approach. A new Section X question settles the stock question: packaging produced before August 12, 2026 but not yet placed on the market does not have to be destroyed, remanufactured or relabeled, and "Packaging that has been placed on the market before 12 August 2026 can remain on the market, even if it is non-compliant with PPWR." Section VII states that "Both Article 10(1) and (2) apply by 1 January 2030. Until the end of 2029, the essential requirements from the PPWD continue to apply". Section II grows from 8 to 15 questions, adding manufacturer and producer tests for transport and branded packaging and ruling that envelopes containing correspondence are not packaging while empty envelopes are. Section III points to Annex C of EN 13428:2004 for Article 5(1) and CEN report CR 13695-1/2000 for the Article 5(4) heavy-metal limits. Section XVIII confirms that Article 44(5) lets a Member State require information beyond the PPWR list where necessary and proportionate for monitoring EPR compliance. Read this as a Commission interpretive document, not as the Official Journal text. It says so itself: "This document complements the Commission Notice - Guidance document for Regulation 2025/40 (EU) on packaging and packaging waste." [LOCKED] on what the Commission says, read August 3, 2026. Not [LOCKED] on what the Regulation requires; for that, Regulation (EU) 2025/40 governs.

Regulatory & Policy July 29, 2026

Three August 12 Points That Are Easy to Miss

With two weeks to go, three points sit in the detail rather than the headline dates. First, recyclability. The A, B, and C grades are a 2030 obligation, but the recyclability requirement is not, because the Commission guidance states that Article 6(1) "applies from 12 August 2026," measured against the old Directive and EN 13430:2004 until the Article 6(4) act lands. Second, stock. No transitional period exists for exhausting stocks, but packaging already placed on the market "may remain on the market and does not need to be withdrawn," and placing on the market means transfer of ownership or possession, with imports timestamped at release for free circulation. Third, the old Directive. Article 70 repeals Directive 94/62/EC from August 12 but keeps parts running to 2028 and 2029, and Decision 97/129/EC on material identification codes survives to August 2028. Detail and citations are on the Prepare for PPWR tab. Sources: Reg (EU) 2025/40 Arts. 6, 70; Commission Notice C/2026/3084, June 10, 2026 [LOCKED].

Regulatory & Policy July 27, 2026

Deposit Systems Post First Hard Numbers

Two live deposit return systems published performance data this month. Romania's RetuRO reported more than 2.4 billion containers returned in the first half of 2026, an 82 percent return rate, up three points year on year, and coverage of 92 percent of localities above 1,500 inhabitants. Portugal's Volta, live since April 10, 2026, passed 100 million containers and an estimated 38 percent collection rate by the end of July, across more than 2,500 automated collection points. Both are benchmarks for the member states that must stand up a system by January 1, 2029 under Article 50. Source: RetuRO H1 2026 barometer, July 27, 2026; SDR Portugal, July 21, 2026 [SIGNALED].

Regulatory & Policy July 21, 2026

The July PPWR Corrigendum, and Still No Change to the English Text

The Official Journal published a corrigendum on July 21, 2026 correcting the Spanish version of recitals 130 and 131, Article 3(1)(66), and Article 47(1) of Regulation (EU) 2025/40, replacing "sistema de responsabilidad ampliada del productor" with "organizacion competente en materia de responsabilidad del productor." It is the fifth PPWR corrigendum, after May 22, 2025, September 9, 2025, November 25, 2025, and November 28, 2025, and none has changed the English text. The English Article 3(1)(66) already reads "producer responsibility organisation" and Articles 24(2) and 29(6) already carry the corrected wording. If you work from a Spanish or French text, re-check your quotations against the consolidated version. Read it at EUR-Lex, OJ L of July 21, 2026. Source: OJ L, 2026/90604, July 21, 2026 [LOCKED].

Regulatory & Policy July 8, 2026

Spain's Deposit Authorization Stalls at Regional Level

Spain's deposit mandate under Real Decreto 1055/2022 has a November 2026 statutory deadline, and operator authorization has stalled. MITECO reports that between June 29 and July 8, 2026 the Madrid regional coordination commission issued three requests for supplementary documentation without passing them to the four applicant operators, leaving the authorizations unresolved, and more than 130 organizations have written to the regional government about it. Spanish producers should plan on the November 2026 date slipping, with the PPWR Article 50 mandate of January 1, 2029 as the binding EU backstop. Source: MITECO procedural record and Spanish reporting, June to July 2026 [SIGNALED].

Fees July 7, 2026

Verpact Publishes 2027 Rate Bandwidths for the Netherlands

Verpact set indicative bandwidths for its 2027 Dutch packaging EPR tariffs. Glass, paper and board, wood, other metals, and the system contribution are stable, beverage cartons and aluminum rise, and plastic is held flat despite cost increases, with final rates due in September 2026. The main change is a new eco-modulation deduction for recyclate sourced from European countries and customs zones, scaling with recyclate share, on top of the existing 20 cent per kg recycled-content discount. Deposit producer contributions rise for plastic bottles and cans. Current rates: verpact.nl/nl/tarieven. Source: Verpact, July 7, 2026 [LOCKED].

Fees July 2, 2026

Ecoembes Publishes Its 2027 Spanish Schedule Early

Ecoembes has published full 2027 Punto Verde prices, unusually early in the year, and its rate page now leads with 2027. Headline 2027 domestic lines: PET beverage bottles up to 3L at 0.278 EUR/kg, other PET bottles 0.267, PET trays and other rigid items 0.682, HDPE rigid 0.282, other rigid plastics 0.773, flexible film 1.269, paper and cardboard 0.117, beverage cartons 0.544, steel 0.197, aluminum 0.040. Spanish household producers can model 2027 exposure now. Ecoembes covers household packaging only; glass sits with Ecovidrio, and industrial and commercial packaging with Envalora and the other industrial schemes. Rates: ecoembesempresas.com/precios. Source: Ecoembes Precios 2027 sheet, document dated July 2, 2026 [LOCKED].

Regulatory & Policy June 30, 2026

France Sets a January 1, 2029 Deposit Deadline

At the June 30, 2026 plenary session of the Plan plastique consultation, France's ecology minister stated that a deposit for recycling will be mandatory from January 1, 2029, citing a 58.4 percent beverage container collection rate in 2024 against a 90 percent goal. Local authority associations and NGOs walked out, and the Senate committee had formally opposed the measure on May 19, 2026, so the delivery route is contested, but the date is on the record and corroborated in a Senate written question of May 28, 2026. France moves from developing a DRS to a dated national commitment. Source: French Ministry for Ecological Transition consultation, June 30, 2026 [SIGNALED].

Regulatory & Policy July 17, 2026

Germany's VerpackDG Enters the Statute Book

Germany promulgated its Packaging Law Implementation Act (Verpackungsdurchführungsgesetz, VerpackDG) on July 17, 2026 (Bundesgesetzblatt Teil I 2026 Nr. 207). It adapts national law to Regulation (EU) 2025/40, replaces the Verpackungsgesetz (VerpackG), and takes effect in its core provisions on August 12, 2026, alongside the PPWR. The Bundestag adopted it June 11, 2026 and the Bundesrat approved it July 10, 2026, after the European Commission withdrew its notification objections on May 29, 2026. It expands the system-participation obligation to certain primary-production and transport packaging, adds an authorization requirement for producers of non-system-participation packaging, and keeps existing system participations valid until December 31, 2026. The LUCID register continues and will be aligned once the PPWR Article 44(14) registration-format act is adopted. Source: Bundesgesetzblatt I 2026 Nr. 207, July 17, 2026 Locked.

Regulatory & Policy June 24, 2026

Council Drops EPR Provisions from Environmental Omnibus Mandate

On June 24, 2026 the Council agreed a partial negotiating mandate on the Environmental Omnibus covering industrial emissions, circular economy, and geospatial data. The EPR provisions, including the proposed suspension of the Article 45(3) Authorized Representative requirement for EU-established producers until 2035 (COM/2025/982), did not secure agreement and were removed, so the suspension cannot go to trilogue as drafted while the Presidency continues work. Non-EU producers were never covered and must still appoint an AR by August 12, 2026. Source: Council of the EU press release, June 24, 2026.

Regulatory & Policy June 10, 2026

PPWR Guidance Document Published in the Official Journal

The Commission's guidance document for Regulation (EU) 2025/40 was published in the Official Journal on June 10, 2026 as Commission Notice C/2026/3084 (adopted June 5, 2026 as C(2026) 3702 final). It formalizes the guidance released March 30, 2026, covers definitions, the PFAS food-contact restriction, recyclability, recycled content, labeling, reuse, DRS, and compostable packaging, and is the authoritative interpretive reference for the August 12, 2026 application date. Read it at EUR-Lex, C/2026/3084. Source: EUR-Lex, C/2026/3084, June 10, 2026.

Site Updates

Site Update October 21, 2026

The Atlas Now Covers Environmental Claims on Packaging

Article 14 of the PPWR sets the conditions for environmental claims about the packaging properties the Regulation regulates, such as recyclability and recycled content in plastic packaging, and it has applied since August 12, 2026. A new Article 14 page sets out both conditions: the claim must relate to a property that exceeds the Regulation's minimum requirement, and it must say whether it covers the packaging unit, part of the unit, or all packaging the company places on the market. Compliance is shown in the Annex VII technical documentation. The obligation is now on the timeline, and the labeling page and the declaration of conformity page link to it.

Site Update October 2, 2026

The Atlas Now Has a Deadline Timeline, a One-Page Primer, and a Shorter First Read

The Atlas adds a deadline timeline, a Declaration of Conformity guide, a one-page primer, and deposit return status by country.

Deadline timeline. The new PPWR timeline lists every dated obligation from August 12, 2026 to 2040, grouped by year, with the condition on each date, the act it waits on, and the article. A filter narrows it to manufacturers, importers and brands, distributors and e-commerce, HORECA, or member states.

Declaration of Conformity guide. A new Declaration of Conformity page sets out who signs and keeps the declaration and which requirements of Articles 5 to 12 it covers on each date.

One-page PPWR primer. A free one-page PDF covers what PPWR requires and when. Request it from the Overview tab or the One-Page PPWR Primer button at the top of every page.

Deposit return status by country. The Country Navigator adds a DRS Status column showing where each member state's deposit return system stands.

A shorter first read. Each tab opens with a short summary and keeps the detail under "More detail". Acronyms show their definitions on hover, and the Glossary is searchable.

Site Update July 16, 2026

New "Prepare for PPWR" tab

Added the "Prepare for PPWR" tab, a walkthrough of what producers should do ahead of the August 12, 2026 application date.

Site Update July 2, 2026

Interactive Fee Estimator and EU map

Expanded the Fee Estimator with per-SKU and country-specific fee structures for France, Italy, and the Netherlands, added a clickable EU map to the Country Navigator, and built a status tracker for the nine pending delegated acts.

Site Update June 30, 2026

Format Risk Screener and Labeling tab

Added the Format Risk Screener with the A/B/C recyclability grade ladder and market-access dates, plus a consolidated Labeling requirements tab.

About This Tab

This tab shows recent PPWR developments in two sections. Regulatory & Policy covers new EU delegated and implementing acts, official guidance, national scheme changes, enforcement, comment periods, and legislative movement. Site Updates covers new features on the site.

The primary sources monitored each week (EUR-Lex, the European Commission, national PRO portals, the JRC, and trade and legal press) are listed in the footer.

PPWR Toolkit
Two tools for sizing PPWR exposure: the Fee Estimator prices packaging against each country's published EPR rates, and the Format Risk Screener flags the formats most likely to miss the recyclability grade. Each opens in its own view.

Fee Estimator

What will EU EPR fees cost?

Two modes: a portfolio estimate from annual tonnage by material, or a per-SKU estimate from each packaging component. Rates come from the 2025 and 2026 PRO schedules. Eco-modulation is left out of the portfolio estimate and offered as an illustrative layer in the per-SKU estimator.

Prefer to read the rates? The EU packaging fee tables list base fees by country and material.

Format Risk Screener

Which formats are likely to miss the grade?

A recyclability and compliance risk lookup by packaging format, with an EN 18120 design-for-recycling score per format.

Prefer to read? The format risk page explains the method and the design factors behind a rating.

PPWR Toolkit / Fee Estimator

EU Packaging Fee Estimator

Estimate annual EPR compliance fees across EU member states. Two modes: portfolio-level (enter annual tonnage by material) or per-SKU (enter each packaging component). Rates from verified 2025/2026 PRO schedules. Eco-modulation is excluded from the portfolio estimate and offered as an illustrative layer in the per-SKU estimator; design attributes can move fees by 10 to 100 percent.

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Enter annual tonnage by material for a given market. 12 categories reflecting how major EU PROs actually price packaging, plastic is split by format (rigid/flexible) and recyclability grade. Formula: Tonnes × PRO base rate (€/tonne) = annual fee. Eco-modulation adjustments (±10–100%), SME flat rates, and SUP per-unit fees not applied.
Annual Tonnage by Material
Countries to Compare
Estimated Annual EPR Fees
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Planning estimates only, not for compliance reporting. Rates are verified base fees from PRO schedules; eco-modulation (±10–100%) excluded. Netherlands: Rigid Recyclable and Rigid Hard-to-Recycle show the same base rate, Verpact differentiates recyclability through eco-mod, not the base fee. Italy plastic rates from CONAI 9-band Corepla system. Germany: compliance rates not public [SIGNALED, not yet read at source]. Spain uses Ecoembes household rates; industrial and commercial packaging goes to Envalora and is materially cheaper. Spanish glass is managed by Ecovidrio and carries a weight factor plus a unit factor; only the weight factor is shown here. France: CITEO 2026 official weight-based rates (the per-unit component is excluded here; use the Per-SKU Estimator to include it). CZ rates converted at 25.3 CZK/EUR; SE at 10.9 SEK/EUR. Sweden rates are among the EU's highest; NPA cut 2026 fees as the property-near (curbside) collection rollout ran slower than planned, with increases due again Jan 2027.

Rate Data Sources & Coverage

14 countries with confirmed or indicative primary-source rates. 1 country (Germany) does not publish compliance rates publicly [SIGNALED, not yet read at source]. Italy (CONAI), Netherlands (Verpact), and Belgium (Fost Plus): plastic sub-categories from primary per-format rates. Other countries: rigid/flex sub-split estimated from published recyclable/non-recyclable rates.

CountryPRO / SourceYearConfidenceNotes

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