๐ฐ Latest developments
All updates โThe PPWR applies from today in all 27 member states. PFAS limits on food-contact packaging, the Declaration of Conformity and the authorized-representative deadline for non-EU producers all start now. Recyclability grades, recycled content, empty space and reuse targets do not; those sit at 2030 or later and each is a floor that moves if its act is late.
Twelve annulment actions against the PPWR are pending at the EU General Court. Seven target the whole Regulation. The rest cluster on the deposit-return rules, the reuse targets, the restricted formats and recycled content. Nothing is suspended and every date still stands, but that is where the legal risk sits.
The labeling implementing act missed its deadline today. No Art. 12 act appears on the EUR-Lex record. Because the obligation applies 24 months after the act or on August 12, 2028, whichever is later, 2028 is now a floor rather than a date. Do not finalize sorting-label artwork yet.
Thirteen member states still have not named a PPWR enforcement authority. Article 40(3) requires every member state to tell the Commission which authorities enforce the Regulation. Fourteen have. Italy, Spain, Poland, Portugal, Greece and eight others have not, eight days before the rules apply. Your obligations start August 12 everywhere regardless, so treat this as uneven timing, not a reprieve.
A sixth corrigendum, in German, and the English text still has not moved. Article 29(4)(b) now reads "Waren" (goods) instead of "Rohstoffe" (raw materials), so the reuse exemption for custom-designed transport packaging is wider in German than it appeared. The English has always read "commodities" and is unchanged. If your team quotes a non-English text, re-check it against the current version.
Read this week's update or browse the full dated archive, one page per development with its source.
What is the PPWR?
๐ฏ 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
- Harmonize EPR fees across all 27 member states via eco-modulation
- Mandate DRS for beverage containers by 2029
- Eliminate PFAS from food-contact packaging (from Aug 12, 2026)
๐ 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].
๐งญ Where to Start
- Prepare for PPWR, 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
- Delegated 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.
โน๏ธ 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 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 risk mitigation and a product advantage that future-proofs the portfolio. PPWR Atlas is the public version of that work, updated weekly from primary sources.
For advisory engagements or corrections, reach Dave at info@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 due by 12 August 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 12 Aug 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 12 August 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, the Article 10 minimization duty, the 50 percent empty-space cap, 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 day one, but mainly attests identity, substances, and minimization, with the design attestations added as their delegated acts arrive.
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 travels through the supply chain with the packaging.
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].
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, 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?
Get hands-on support to map your portfolio, size your exposure, build the compliance file, and brief your leadership.
Get in touchAll 27 Member States, EPR & DRS Summary
| Country | PRO / Registry | SME Threshold | DRS Status | Key Note |
|---|---|---|---|---|
| ๐ฉ๐ช Germany | LUCID / Multiple PROs | โค80,000 units AND โค200 kg | DRS Active, โฌ0.25 | Competitive multi-PRO market. Declaration of Completeness required above tonnage threshold. |
| ๐ซ๐ท France | CITEO / Lรฉko | ~โค200 units or โค5 kg (~โฌ80/yr flat) | DRS Developing | Triman label still required. ICP B2B rate from Jan 1, 2026. CITEO bonus/malus up to ยฑ100%. |
| ๐ฎ๐น Italy | CONAI (7 consortia) | Varies by consortium | DRS Developing | Alphanumeric codes required. TRIS notification 2026/0167/IT in EC review. |
| ๐ช๐ธ Spain | Ecoembes / Envalora | <15 tonnes/year | DRS Stalled | 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. |
| ๐ณ๐ฑ Netherlands | Verpact | <50 tonnes/year | DRS Active, โฌ0.15/โฌ0.25 | Most generous SME threshold. Statiegeld fully operational. DRS-eligible formats require deposit marking. |
| ๐ต๐ฑ Poland | NFOลiGW / BDO | PLN 150/quarter waiver | DRS Not Yet | All private PROs liquidated. AR required for non-EU e-commerce sellers. BDO portal in Polish. |
| ๐ฆ๐น Austria | ARA | Kleinstzeichner ~โฌ150/yr flat rate | DRS Limited / Voluntary | Strictest AR requirement in EU, zero de minimis. Omnibus AR suspension dropped from the Council negotiating mandate June 24, 2026; stalled, not adopted. |
| ๐ง๐ช Belgium | Fost Plus / Bruxelles-Propretรฉ | Varies by region | DRS Developing | Three separate regional EPR schemes (Flanders, Wallonia, Brussels). |
| ๐ธ๐ช Sweden | FTI (Fรถrpacknings- och Tidningsinsamlingen) | ~2 tonnes/year | DRS Active, SEK 1โ2 | Mature EPR system since 1994. Pantamera DRS operational. |
| ๐ฉ๐ฐ Denmark | Dansk Retursystem | ~1 tonne/year | DRS Active, DKK 1โ3 | One of oldest DRS systems globally (1989). High return rates. |
| ๐ซ๐ฎ Finland | Rinki / Palpa | ~1 tonne/year | DRS Active, โฌ0.10โโฌ0.40 | World-leading return rates (>93%). DRS since 1996. |
| ๐จ๐ฟ Czech Republic | EKO-KOM | 300 kg or 600 units | DRS Developing | DRS legislation under development. EKO-KOM well-established. |
| ๐ญ๐บ Hungary | OHร | ~200 kg | DRS Active, HUF 50 | Centralized state system. DRS launched 2024 via MOHU. |
| ๐ท๐ด Romania | ANPM / RetuRO | To confirm | DRS Active, RON 0.50 | DRS launched Nov 2023 via RetuRO. |
| ๐ง๐ฌ Bulgaria | ECOBULPACK | To confirm | DRS Not Yet | EPR system transitioning. PPWR application may outpace national readiness. |
| ๐ฌ๐ท Greece | EOAN | To confirm | DRS Not Yet | EPR system in place. Limited DRS development. PPWR mandate by 2029. |
| ๐ต๐น Portugal | SPV (Sociedade Ponto Verde) | ~1 tonne/year | DRS Not Yet | DRS in planning. SPV EPR system well-established. |
| ๐ฎ๐ช Ireland | Repak / Re-Turn | ~1 tonne or โฌ1M turnover | DRS Active, โฌ0.15/โฌ0.25 | Re-Turn DRS launched 2024. Repak established EPR operator. |
| ๐ธ๐ฐ Slovakia | NATUR-PACK / ENVI-PAK | To confirm | DRS Active, โฌ0.15 | DRS operational since 2022. |
| ๐ญ๐ท Croatia | FZOEU | To confirm | DRS Active | DRS operational since 2006 via FZOEU. |
| ๐ธ๐ฎ Slovenia | SLOPAK | To confirm | DRS Developing | DRS in development. SLOPAK EPR system established. |
| ๐ช๐ช Estonia | Eesti Pandipakend | To confirm | DRS Active, โฌ0.10 | DRS operational since 2005. |
| ๐ฑ๐ป Latvia | Latvijas Zaฤผais Punkts | To confirm | DRS Active, โฌ0.10 | DRS operational since 2011. |
| ๐ฑ๐น Lithuania | Green Dot Lithuania | To confirm | DRS Active, โฌ0.10 | DRS operational since 2016. |
| ๐ฑ๐บ Luxembourg | Valorlux | ~300 kg | DRS Not Yet | Small market. Valorlux EPR established. PPWR DRS mandate by 2029. |
| ๐จ๐พ Cyprus | GreenDotCyprus | To confirm | DRS Not Yet | EPR system present. PPWR DRS mandate by 2029. |
| ๐ฒ๐น Malta | GreenPak / WasteServ | To confirm | DRS Not Yet | Very small market. GreenPak EPR operational. PPWR DRS mandate by 2029. |
PPWR article finder
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 packaging must reach at least Grade C to be placed on the EU market; from Jan 1, 2035 the recyclable-at-scale test applies; from Jan 1, 2038 only Grade A or B is permitted.
Grade A: 95%+
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 |
|---|
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 are only successful when cross-functional teams are engaged and empowered with the tools and training necessary 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.
If you are working to future-proof your product and packaging portfolio, let's talk: info@hartteradvisory.com
About the Site
The EU Packaging and Packaging Waste Regulation is moving fast and is difficult to keep up with. 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 national EPR schemes each modulate fees their own way. Most coverage assumes you already know what you're doing, or sits behind a consulting paywall. Sustainability, packaging, and regulatory leaders needed one trusted place that tracks all of it, stays current, and is free to use.
That is what PPWR Atlas is: a live intelligence hub covering deadlines, recyclability grades, eco-modulation, EPR fees, labeling, and the pending delegated acts across the EU and its key national markets, updated weekly from primary and trusted sources.
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
PPWR Applies From Today in All 27 Member States
Regulation (EU) 2025/40 applies from today in all 27 member states. It is a regulation, not a directive, so it binds directly with no national law needed first. Four things start now rather than later: 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 for non-EU producers to appoint an authorized representative under Art. 45(3); 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. Thirteen still have not. What is NOT due today is most of the headline material: recyclability grades, recycled content minimums, the empty space cap and the reuse targets all sit at 2030 or later, and every one 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, per 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. Seven ask the Court to strike the whole Regulation. The rest target specific provisions, and they cluster: Art. 50 and Annex X, the deposit and return system rules, in three cases; Art. 29, the reuse targets, in six; Art. 25 and Annex V, the restricted packaging formats, in four; and Art. 7, the recycled content minimums, in one.
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 still stands and you should plan against all of them. What it does tell you is where the legal risk sits. The four provision groups under attack are, between them, most of the expensive part of the Regulation, and they are the parts whose detail is still being written in delegated and implementing acts. If your 2030 capital plan depends on a single reading of the reuse targets or the format bans, that plan carries more legal uncertainty than the text alone suggests.
What to do. Keep complying. Do not treat litigation as a reason to delay a 2030 program, because if a case fails you will have lost years. Do flag it 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 case notices themselves have not been read, so the applicants and their arguments are not reported here [SIGNALED].
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. It has not. As at August 11, 2026 the EUR-Lex record for the Regulation lists no implementing act completing Art. 12, and the only act completing the Regulation at all is the pallet wrap exemption. The technical groundwork exists: the Commission's Joint Research Centre published a technical proposal for a harmonized sorting label in early 2026, taking a material-based approach built on pictograms, color coding and minimal text rather than the old alphanumeric codes.
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" is now doing the work. Every month the act slips, 2028 slips with it, so treat 2028 as a floor and not a deadline. The flip side is that you still do not 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, because that is 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. The JRC proposal has not been read in full, so no date or document number is stated for it [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 in every member state, whether or not an authority has been named. What changes is who comes asking and how soon. In the fourteen that have notified, expect questions and inspections to start on time. In Italy, Spain and Poland, three of the largest markets on this site, there is currently no published body to contact with a compliance question, no address for a Declaration of Conformity query, and no obvious route to resolve a dispute. That is a timing gap, not a holiday: the duty accrues from August 12 and enforcement catches up later.
What to do. Check the list before you file anything, because it is updated as notifications arrive. Where an authority exists, save the contact now rather than hunting for it during an inquiry. Note also that several countries split the role, so there is no single number to call: 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 dedicated 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].
A Sixth PPWR Corrigendum, in German, and Still Nothing Changes in English
The Official Journal published a German-language correction to Regulation (EU) 2025/40 on August 4, 2026. On page 59, Article 29(4)(b) now reads "Waren" (goods) where it previously read "Rohstoffe" (raw materials), in the clause exempting transport packaging that is custom-designed for the carriage of large-scale machinery, equipment and goods from the Article 29 reuse targets.
What this means for you. If you run compliance 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 you ship in custom-built transport packaging. Nothing changes for anyone working from English: Article 29(4)(b) has read "commodities" since publication and is untouched.
The wider point. This is the sixth corrigendum to the PPWR, after May 22 2025, September 9 2025, November 25 2025, November 28 2025 and July 21 2026. Every one has corrected a language version other than English. There has never been an English-language corrigendum, and the English operative text stands exactly as published on January 22, 2025. If your team quotes the Regulation from a German, Spanish, Czech, Italian, Swedish or French text, re-check those quotations against the current version rather than a copy saved last year. Read it at EUR-Lex, OJ L, 2026/90654. Source: OJ L, 2026/90654, August 4, 2026, read in the OJ PDF [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, with no announcement and no coverage in the trade or legal press. The record carries ISBN 978-92-68-42316-5, catalogue number KH-01-26-068-EN-N and DOI 10.2779/4868962, against ISBN 978-92-68-37678-2 for the March edition. It runs to 20 sections and 155 numbered questions across 69 pages, where the first edition had 19 sections and 50 pages, and every change is tagged NEW or UPDATED in the text itself. The DG ENV landing page still displays "30 March 2026" and still describes the March edition, yet its download link now returns a 302 to the new Publications Office record, so the change is invisible to anyone re-reading that page. Section XVI is entirely new and covers enforcement immediately 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", which independently confirms the Article 10 minimization position this Atlas corrected on July 30. Section II grew from 8 questions to 15, adding manufacturer and producer tests for transport packaging and branded packaging and the ruling that envelopes containing correspondence are not packaging while empty envelopes are. Section III adds three questions on how to demonstrate compliance, pointing 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 adds one question, confirming that Article 44(5) lets a Member State require information beyond the PPWR list where that is 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 in the PDF on 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, C grades are a 2030 obligation, but the recyclability requirement itself is not: the Commission guidance states that Article 6(1) "applies from 12 August 2026," with compliance measured against the old Directive and EN 13430:2004 until the Article 6(4) act lands. Second, stock. There is no transitional period 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 is the transfer of ownership or possession, with imports timestamped at release for free circulation. Third, the previous Directive. Article 70 repeals Directive 94/62/EC from August 12 but keeps parts of it running to 2028 and 2029, and Decision 97/129/EC on material identification codes survives to August 2028. The full detail, with citations, is 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, with coverage now reaching 92 percent of localities above 1,500 inhabitants. Portugal's Volta, live since April 10, 2026, passed 100 million containers returned and an estimated 38 percent collection rate by the end of July, running more than 2,500 automated collection points. Both figures matter as 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 to Regulation (EU) 2025/40 on July 21, 2026 correcting the Spanish language version of recitals 130 and 131, Article 3(1)(66) and Article 47(1), replacing "sistema de responsabilidad ampliada del productor" with "organizacion competente en materia de responsabilidad del productor." It is the fifth corrigendum to the PPWR, following corrections published on May 22, 2025, September 9, 2025, November 25, 2025 and November 28, 2025. Every one has corrected a language version other than English. The English text of Article 3(1)(66) already reads "producer responsibility organisation" and the English Articles 24(2) and 29(6) already carry the corrected wording, so nothing in the English operative text has moved. 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 own deposit mandate under Real Decreto 1055/2022 carries a November 2026 statutory deadline, and the process to authorize an operator has stopped. MITECO reports that between June 29 and July 8, 2026 the Madrid regional coordination commission issued three requests for supplementary documentation without transmitting them to the four applicant deposit operators, leaving the authorizations unresolved. More than 130 organizations have written to the regional government about the blockage. 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 aluminium rise; plastic is held flat despite cost increases. Final 2027 rates follow in September 2026. The notable change is a new eco-modulation deduction rewarding 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 both 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 and its rate page now leads with 2027 rather than 2026, unusually early in the year. 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, aluminium 0.040. Spanish household producers can model 2027 exposure now. Note that 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, framing it as "anticipate or endure" and citing a 58.4 percent beverage container collection rate in 2024 against a 90 percent goal. Local authority associations and NGOs walked out of the session, and the Senate committee had formally opposed the measure on May 19, 2026, so the delivery route is contested even though the date is now on the record. The date is 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 (Verpackungsdurchfรผhrungsgesetz, VerpackDG) in the Federal Law Gazette on July 17, 2026 (Bundesgesetzblatt Teil I 2026 Nr. 207). The act adapts national packaging law to Regulation (EU) 2025/40 and replaces the old Verpackungsgesetz (VerpackG); its core provisions take effect August 12, 2026, in parallel with 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. Notable national changes include an expanded system-participation obligation (now reaching certain primary-production and transport packaging), a new authorization requirement for producers of non-system-participation packaging, and a transition rule keeping existing system participations valid until December 31, 2026; the LUCID register continues, to 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 extended producer responsibility 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 from the mandate. The suspension cannot proceed to trilogue as drafted; 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 European 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 first released March 30, 2026 and covers definitions, the PFAS food-contact restriction, recyclability, recycled content, labeling, reuse, DRS, and compostable packaging. It is now the authoritative interpretive reference ahead of 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
Correction: the Private Label Rule Has a Small Business Exception
If you sell under your own brand and you are a very small business, the packaging obligation may not be yours. We had this wrong in two places and have corrected it.
The general rule is that putting your brand on packaging makes you the manufacturer, which is why private label normally lands on the retailer rather than the factory. There is one exception. If the brand owner is a micro-enterprise and its packaging supplier is in the same member state, the obligation belongs to the supplier instead. Both of those have to be true at once. A micro-enterprise buying its packaging from another member state is still on the hook itself.
What this means for you. If you are a micro-enterprise brand owner, check where your packaging supplier is based, because that single fact decides whether this is your obligation or theirs. If you are a packaging supplier, check whether any of your customers are micro-enterprises in your own country, because for those accounts the duty is yours, not theirs. Corrected on the Roles & Obligations tab and in the article guide. Source: Regulation (EU) 2025/40, Art. 3(1)(13)(a) and (b).
New "Prepare for PPWR" tab
Added a "Prepare for PPWR" tab, an action-oriented 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 SVG map of the EU 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.
โน๏ธ About This Tab
This tab shows PPWR developments from the last 60 days, organized into 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 hub features and enhancements.
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.
๐ถ 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.
๐ Rate Data Sources & Coverage
14 countries with confirmed or indicative primary-source rates. 1 country (Germany) does not publish compliance rates publicly. 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 |
|---|