PPWR Update: Week of August 24, 2026

Regulatory & Policy  |  August 25, 2026

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

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

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

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

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

Regulatory & Policy  |  August 25, 2026

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

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

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

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

Regulatory & Policy  |  August 25, 2026

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

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

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

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

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

Regulatory & Policy  |  August 25, 2026

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.