Regulatory & Policy August 12, 2026
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 September 8, 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, not just a part of it: 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. Only three are limited to specific provisions, and all three attack Art. 50 and Annex X, the deposit and return system rules: T-197/25, T-237/25 and T-238/25.
Each of the nine whole-Regulation cases still argues from a particular provision, and those arguments cluster: 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. Read those as where each applicant's grievance starts, not as the limit of what it is asking for.
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. Update, August 20, 2026: all twelve case notices have now been read in full, and the applicants, provisions and pleas are reported case by case in the litigation table on the Delegated Acts tab [LOCKED].
This entry is part of the PPWR Atlas update log. The Atlas is re-checked against the Official Journal, Commission guidance, and each national PRO's published schedule, and everything that changes gets logged with its source. See the week of August 10, 2026 or the full update archive.