PPWR Update: Week of August 24, 2026

Regulatory & Policy  |  August 25, 2026

This site previously described Greece as having limited deposit-system development, with the operator and the deposit both "to be confirmed". That understated it. Enough is published now to start work on artwork.

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

The deposit is two tier, and this is the detail to get right. It is 0.10 euro for containers up to 0.5 litres and 0.15 euro for containers between 0.5 and 3 litres. Anyone quoting a single figure, or the range without the 0.5 litre boundary, will price it wrong.

One Greek specific worth knowing. The refund is a voucher spendable in participating stores, and it cannot be exchanged for money. Most European deposit schemes refund cash. If you are modelling return rates or consumer response in Greece, that is a real difference.

What is NOT settled: the date. DRS Hellas is still pending licensing by the Hellenic Recycling Agency (EOAN), the system is in phased activation with tenders open, and no go-live date has been published. The operator targets up to 90 percent collection by 2029, which lines up with the Article 50(1) duty on Greece. So: build the artwork requirement into your plans now, but do not let anyone sell you a launch date, 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; the EOAN licensing decision itself was not read, as eoan.gr could not be reached this session.

Regulatory & Policy  |  August 25, 2026

Until today this site told you Poland had no deposit return system and that one was coming with the 2029 PPWR mandate. That was wrong, and it had been wrong for some time. Poland's system has been operating since October 2025 and had collected 3.2 billion containers by August 21, 2026.

What is actually in scope. Plastic bottles up to 3 litres and metal cans up to 1 litre carry a 0.50 PLN deposit. Reusable glass bottles up to 1.5 litres carry 1.00 PLN. Two details catch people out: the metal limit is 1 litre, lower than the 3 litre PPWR scope, and reusable glass is included, which PPWR does not require. Collection is mandatory at every shop above 200 square metres selling in-scope drinks, and at smaller shops that sell reusable glass.

What to do. If you sell beverages into Poland, this is a live obligation and not a 2029 one. Your in-scope packaging must already carry the deposit mark and the deposit amount, and you must already be registered with a licensed operator. If you had this on a 2029 plan, move it. Check the Ministry of Climate and Environment's own scheme pages at gov.pl/web/klimat/system-kaucyjny.

On the error itself. It reached the country navigator, the Poland country page and the fee tables, and every internal consistency check passed because all three agreed with each other. The fix and the reason it survived review are logged in full. Source: Ministerstwo Klimatu i Środowiska, official deposit-system portal, read August 25, 2026. [LOCKED]

Regulatory & Policy  |  August 25, 2026

The single biggest recurring admin cost in EU packaging compliance is registering separately in every member state, on 27 different data structures. The act meant to fix that, under Article 44(14), was due on February 12, 2026 and never appeared. It has now appeared as a draft. The Commission published a draft implementing regulation with a 19-page annex on August 6, 2026 and is taking feedback until September 10, 2026, midnight Brussels time.

What this changes today: nothing. You still register country by country, and you will keep doing so until the act is adopted and then for a while after, because member states get 18 months from adoption to bring their national registers into line. That clock has not started. What changes is the planning horizon. There is now a text and a timetable instead of an open question.

What to do. If you register in more than two member states, read the draft annex and file feedback. It sets the data fields you will be reporting against for years. 6,333 responses have already been filed, most from small cross-border sellers arguing about the authorized-representative burden. If your operation looks different from theirs, the file currently does not say so. Comment 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; the draft text itself has not been read here, so nothing above states what the draft requires.

Regulatory & Policy  |  August 25, 2026

On August 14 the Commission opened calls for evidence on the two acts that decide how recycled content gets counted. One is the Article 7(8) methodology for calculating and verifying recycled content in plastic packaging. The other is the Article 7(10) rules for recognising recycled material imported from outside the EU. Both take feedback until September 16, 2026.

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

Why the second one matters. 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 is the early stage, so there is no draft text yet. That is the point: this is when the shape of the rule is still open, and it is a much cheaper moment to be heard than after a draft exists. Comment on the Article 7(8) methodology or on the Article 7(10) import rules.

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

Regulatory & Policy  |  August 25, 2026

The Commission was required to publish the implementing acts setting the harmonized sorting label by August 12, 2026, under Articles 12(6) and 12(7). That date has passed and no act exists. The Commission's implementation page says only that it is "currently preparing" one, and there is still no draft and no consultation on the register.

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 still unwritten, the 24-month leg now governs, so 2028 is the earliest possible date rather than the actual one. Every further 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 still 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, Triman in France and the Italian alphanumeric scheme, stay in force meanwhile.

The practical read. Do not commission harmonized-label artwork yet, and do not let a supplier tell you 2028 is fixed. Do handle February 12, 2027 for the Green Dot, because that one is real and close.

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.