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
One-page 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.
Your download has started. If it did not, use the link below. The primer is one page, and it is yours to forward.
Latest developments
All updatesThe 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.
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)).
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.
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.
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?
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
- Get Ready, the step-by-step actions by role and packaging type
- Format Risk Screener, flag formats likely to miss the recyclability grade
- Fee Estimator, size your EU EPR fee exposure
- Acts Tracker, what is still pending and when it lands
The changes are coming in waves
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
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.
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]
- 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.
- 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.
- 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.
- Name one owner and brief leadership early, because PPWR is cross-functional and stalls without a clear owner and an executive mandate.
Does PPWR apply to your company, and in what role?
Brand owner or filler
Producer, if a limb appliesYou 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 appliesYou 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 labelYou 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 dutyYou make or supply empty packaging or components that end up on goods sold in the EU.
Marketplace or fulfillment
Facilitation dutyYou list, store, or dispatch other sellers' packaged goods bound for EU buyers.
See your duty list, by role and packaging type
Where to put your effort, phase by phase
Get the day-one basics locked
Before Aug 12, 2026Set up for the 2028 acts
2026 to 2028Design for 2030 and the grades beyond
2028 onwardMobilize 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.
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.
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Get in touchAll 27 Member States, EPR & DRS Summary
| Country | PRO / Registry | SME Threshold | DRS Status | Key Note |
|---|---|---|---|---|
| DE Germany | LUCID / Multiple PROs | ≤80,000 units AND ≤200 kg | DRS Active | Competitive multi-PRO market. Declaration of Completeness required above tonnage threshold. |
| FR France | CITEO / Léko | ~≤200 units or ≤5 kg (~€80/yr flat) | DRS In Development | Triman label still required. ICP B2B rate from Jan 1, 2026. CITEO bonus/malus up to ±100%. |
| IT Italy | CONAI (7 consortia) | Varies by consortium | DRS In Development | Alphanumeric codes required. Compostability Decree-Law 143/2026 in force, converted with amendments by Law No. 173 of October 5, 2026. |
| ES Spain | Ecoembes / Envalora | <15 tonnes/year | DRS In Development | SDDR 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 Netherlands | Verpact | <50 tonnes/year | DRS Active | Most generous SME threshold. Statiegeld fully operational. DRS-eligible formats require deposit marking. |
| PL Poland | Recovery organizations (e.g. Rekopol) / BDO | No de minimis | DRS Active | Product 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 Austria | ARA | Kleinstzeichner ~€150/yr flat rate | DRS Active | Strictest AR requirement in EU, zero de minimis. Omnibus AR suspension dropped from the Council negotiating mandate June 24, 2026; stalled, not adopted. |
| BE Belgium | Fost Plus (household) / IVC | Interregional | DRS Not Yet Operational | One interregional EPR system under the 2008 Cooperation Agreement. No deposit system decided. |
| SE Sweden | NPA (Näringslivets Producentansvar) | ~2 tonnes/year | DRS Active | Mature EPR system since 1994. Pantamera DRS operational. |
| DK Denmark | Dansk Retursystem | ~1 tonne/year | DRS Active | One of oldest DRS systems globally (1989). High return rates. |
| FI Finland | Rinki / Palpa | ~1 tonne/year | DRS Active | World-leading return rates (>93%). DRS since 1996. |
| CZ Czech Republic | EKO-KOM | 300 kg or 600 units | DRS In Development | DRS legislation under development. EKO-KOM well-established. |
| HU Hungary | OHÜ | ~200 kg | DRS Active | Centralized state system. DRS launched 2024 via MOHU. |
| RO Romania | ANPM / RetuRO | To confirm | DRS Active | DRS launched Nov 2023 via RetuRO. |
| BG Bulgaria | ECOBULPACK | To confirm | DRS Not Yet Operational | EPR system transitioning. PPWR application may outpace national readiness. |
| GR Greece | EOAN | To confirm | DRS In Development | EPR system in place. DRS Hellas is the sole DRS operator but is not yet collecting, with no go-live date published. |
| PT Portugal | SPV (Sociedade Ponto Verde) | ~1 tonne/year | DRS Active | DRS live since April 10, 2026 (SDR Portugal, Volta). SPV EPR system well-established. |
| IE Ireland | Repak / Re-Turn | ~1 tonne or €1M turnover | DRS Active | Re-Turn DRS launched 2024. Repak established EPR operator. |
| SK Slovakia | NATUR-PACK / ENVI-PAK | To confirm | DRS Active | DRS operational since 2022. |
| HR Croatia | FZOEU | To confirm | DRS Active | DRS operational since 2006 via FZOEU. |
| SI Slovenia | SLOPAK | To confirm | DRS In Development | DRS in development. SLOPAK EPR system established. |
| EE Estonia | Eesti Pandipakend | To confirm | DRS Active | DRS operational since 2005. |
| LV Latvia | Latvijas Zaļais Punkts | To confirm | DRS Active | DRS operational since 2011. |
| LT Lithuania | Green Dot Lithuania | To confirm | DRS Active | DRS operational since 2016. |
| LU Luxembourg | Valorlux | ~300 kg | DRS Not Yet Operational | Small market. Valorlux EPR established. PPWR DRS mandate by 2029. |
| CY Cyprus | GreenDotCyprus | To confirm | DRS Not Yet Operational | EPR system present. PPWR DRS mandate by 2029. |
| MT Malta | GreenPak / WasteServ | To confirm | DRS Not Yet Operational | Very small market. GreenPak EPR operational. PPWR DRS mandate by 2029. |
PPWR article finder
Corrigenda to the Regulation, none in English
Seven 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.
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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.)
| Case | Applicant(s) | Filed | Provisions challenged | Pleas, condensed |
|---|---|---|---|---|
| T-197/25 | Ceska asociace odpadoveho hospodarstvi and four others (Czech waste-management and municipal-services operators) | Mar 21, 2025 | Art. 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-237/25 | Fleggaard, Scandinavian Park, Scandlines Bordershop (German-Danish border-trade retailers) | Apr 11, 2025 | Art. 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-238/25 | IGG, the border-traders association (Flensburg) | Apr 11, 2025 | Art. 50 and Annex X (deposit and return) | Five pleas stated as identical to T-237/25 |
| T-236/25 | Raficon Trade SRL (Romania) | Apr 13, 2025 | Whole 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-241/25 | Schutz and seven others (German industrial packaging manufacturers) | Apr 13, 2025 | Whole 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-242/25 | Saier Verpackungstechnik (Germany) | Apr 13, 2025 | Whole 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-247/25 | Ecoplastica Srl (Italy) | Apr 14, 2025 | Whole 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-249/25 | Jokey SE and six others (German rigid plastic packaging manufacturers) | Apr 14, 2025 | Whole Regulation; Art. 29(1) to (3), (4)(c), (4)(d) | Six pleas stated as identical to T-242/25 |
| T-239/25 | Belfort International BV (Belgium, single-use plastic packaging supplier) | Apr 13, 2025 | Whole 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-244/25 | ILIP Srl (Italy, fresh-produce packaging) | Apr 13, 2025 | Whole Regulation; Art. 25(1), Annex V pts 2 and 3 | Wrong legal basis; equal treatment; failure to state reasons; proportionality of Annex V pts 2 and 3 |
| T-248/25 | Dynaplast (France), Nespak (Italy), Veripack Embalajes (Spain) | Apr 14, 2025 | Whole Regulation; Art. 25(1), Annex V pt 2 | Wrong legal basis; equal treatment; failure to state reasons; proportionality of Annex V pt 2 |
| T-243/25 | Silver-Plastics (Germany) | Apr 13, 2025 | Whole 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
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.
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/.
Key Labeling Dates
| Date | Requirement | Evidence |
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What Changes
About the Author
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.
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.
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.
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 Regulatory & Policy
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.
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.
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].
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.
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.
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.
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.
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.
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.
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.
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]
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.
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].
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.
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].
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.
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].
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.
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].
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].
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].
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].
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].
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].
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].
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.
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.
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
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.
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.
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.
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.
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.
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.
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.
| Country | PRO / Source | Year | Confidence | Notes |
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