PPWR current status: which acts are missing, which drafts are under way and what changed recently

As at 28 October 2026. This page is updated on an ongoing basis. The change log is at the end.

The EU Packaging Regulation has applied since 12 August 2026. That does not make it complete: several acts the Commission should have adopted by February or August 2026 are still missing, more are due by the end of the year, and a proposal would suspend an obligation for foreign producers again. This page shows what is currently open and what it means for companies.

In brief

• The Regulation applies. Regulation (EU) 2025/40 has applied since 12 August 2026. In Germany the VerpackDG has applied since the same day; the former Packaging Act (VerpackG) expired at the end of 11 August 2026.
• Two acts are overdue. The format for registration and reporting in the register of producers was due by 12 February 2026, harmonised labelling by 12 August 2026. There is a draft for the register and only a planning entry for labelling.
• Four more are due by the end of 2026. Calculation of recycled content, sustainability criteria for recycling technologies, equivalence for recycled content from third countries and a report on substances of concern.
• Missing acts move dates. Sorting labels apply at the earliest 24 months, and the recycled content targets at the earliest three years, after the relevant act enters into force, where that is later than the statutory date.
• The authorised representative could be dropped for small companies. The Commission proposes suspending the obligation under Article 45(3) until January 2035. On 20 October 2026 Parliament adopted amendments under which the suspension only applies to EU-based micro and small enterprises, and referred the file back to the environment committee for negotiations with the Council. The Council, which had shelved the file in the first half of the year, has been discussing a solution for small producers again since September. Until a decision is published in the Official Journal the obligation applies; the Commission asks Member States not to sanction in the meantime.

Which acts are missing

Register of producers. The act sets out what producers must state when registering and how granular their reporting must be, that is by which packaging types and material categories (Article 44(14)). Each Member State must set up its register within 18 months of the entry into force of this first act (Article 44(1)). Until then registration in Germany continues through LUCID at the Central Agency Packaging Register. The Commission had planned adoption for the first quarter of 2026; the draft came in August. At the Environment Council on 12 October 2026 Austria, Czechia and Estonia asked for the act to be held back until a single EU-wide registration portal for all product groups exists; nothing has been decided.

Labelling. What the pictograms look like will only be fixed by the decision. The sorting label obligation starts on 12 August 2028 or 24 months after the act enters into force, whichever is later (Article 12(1)); Member States must label waste receptacles by 12 August 2028 or 30 months after adoption (Article 13(1)). Details are in the article on PPWR labelling.

Recycled content. The minimum recycled content targets for plastic packaging apply from 1 January 2030 or three years after the calculation act enters into force, whichever is later (Article 7(1)). If that act only enters into force after 1 January 2027, the date moves back by the same time. What already applies to recyclability and recycled content is explained in the article on recyclability and recycled content.

Substances of concern. The report is to show how far such substances impair re-use and recycling, and may list them (Article 5(2)). It does not change the limit values that have applied since 12 August 2026; those are set out in the article on PFAS and heavy metals.

Get a PPWR Software Demo

Save up to 80% of your time and costs with our software!

Book a 30-minute demo →Or start with the 2‑minute PPWR check

Proposals that would change the PPWR

Authorised representative for extended producer responsibility. Anyone established in another Member State or a third country who supplies packaging or packaged goods directly to end users in a Member State has had to appoint an authorised representative there since 12 August 2026 (Article 45(3) read with Article 3(1)(15)(c) and (d)). On 10 December 2025 the Commission proposed suspending this obligation until January 2035 (COM(2025) 982, procedure 2025/0395(COD)). Until a decision is published in the Official Journal, the obligation applies. Anyone appointing a representative now should agree a termination right in case of suspension.

Parliament. The environment committee adopted its position on 5 October 2026 (74 votes in favour, none against, 4 abstentions according to report A10-0266/2026) and narrowed the proposal: the suspension is to apply only to EU-based micro and small enterprises, that is fewer than 50 employees and no more than 10 million euros in turnover or balance sheet total, and is to end at the latest when the announced Circular Economy Act applies, if that is before 2035. For producers from third countries Article 45(3) remains unchanged under the committee text; the Commission proposal would have left their obligation to the Member States. Registration, reporting and fees remain for everyone. The plenary debated report A10-0266/2026 on 19 October 2026 and adopted amendments on 20 October (text adopted P10_TA(2026)0345): the suspension is to apply only to micro and small enterprises established in the EU, until 1 January 2035 or until a horizontal EU framework for extended producer responsibility with rules on authorised representatives applies, whichever is earlier; it does not apply to producers that split their activities to qualify. This is not yet a final first-reading position: Parliament referred the file back to the environment committee for negotiations with the Council (Legislative Observatory). It will vote again on any agreement with the Council.

Council. Under the Cyprus Presidency in the first half of 2026 the Permanent Representatives Committee discontinued the examination of both suspension proposals (this Regulation and the parallel Directive on representatives in other waste legislation) and referred the issue to the forthcoming Circular Economy Act. At the working party meetings of 7 and 21 September 2026 several Member States asked to reopen the file, limited to the representative obligation for small producers; thresholds between 600 kilograms and 10 tonnes of packaging per year are under discussion (Council note 13583/26 of 28 September 2026). At the Environment Council on 12 October 2026 Austria, Czechia and Estonia tabled a paper (14126/26): a genuine de minimis exemption from registration, fees and the representative, above it a simplified regime with a flat-rate fee, more responsibility for online platforms, a single EU-wide registration portal and, until then, no implementing act on the register of producers. According to Agence Europe, Poland and Belgium backed a de minimis threshold, Italy a targeted, time-limited suspension of the representative alone with registration, reporting and fees maintained; France wants to keep the representative and is open only to a targeted, temporary postponement for packaging; Spain insisted on protecting the funding of waste management, Luxembourg on the effectiveness of the systems. Commissioner Roswall urged a quick agreement on the representative alone; the Irish Presidency is working on a time-limited solution for small producers. No decision was taken.

Enforcement in the meantime. On its page on producer responsibility for small businesses the Commission asks Member States to enforce the obligation pragmatically and not to sanction companies for now. That is not an exemption.

Public procurement. In its proposal for new public procurement rules (COM(2026) 590 of 9 September 2026, procedure 2026/0265(COD)), the Commission wants to delete Article 63 PPWR on green public procurement and replace it with a general rule in the new procurement regulation. This concerns contracting authorities, not the obligations of economic operators.

These proposals have not changed the application dates of the Regulation. There is no proposal to postpone the date of application as a whole.

Guidance and corrigenda

Commission guidelines. Notice C/2026/3084 (OJ C of 10 June 2026) explains terms such as manufacturer, producer and packaging. It is not binding, but in practice it guides the authorities.

Commission FAQ. The Commission's questions and answers on the PPWR are available in their second edition of August 2026.

Corrigendum to the German version. On 4 August 2026 the EU corrected the German version of Article 29(4)(b) (OJ L, 2026/90654): the exemption from the re-use targets concerns packaging for large-scale machinery, equipment and commodities, as the English text has always said. What this means for transport packaging is in the article on B2B and transport packaging.

Germany: VerpackDG

Since 12 August 2026 the German Packaging Implementation Act (VerpackDG) has applied. It governs registration, participation in a take-back scheme, reporting, the declaration of completeness and sanctions. Two transitional deadlines are still running: anyone already registered under the former Packaging Act must add the new details by 12 November 2026, and existing scheme participations continue until 31 December 2026 at the latest (Section 68). The fines under Section 66(2) only apply from 12 February 2027. The obligations are explained in the article on the PPWR and the German Packaging Act.

What to do now

1. Implement what already applies. The declaration of conformity, technical documentation, substance limits and the manufacturer details on the packaging do not depend on any missing act. A template is in the article on the declaration of conformity.
2. Do not print pictograms. As long as the labelling decision is missing, there is no binding design. Collect the material data per component from which the label will later be derived.
3. Prepare reporting data. Structure your packaging data so that you can output it per Member State, packaging type and material; that is exactly what the new reporting format will require.
4. Appoint representatives with an exit clause. The obligation applies, but the suspension proposal is in the legislative process; after Parliament's vote of 20 October 2026 it would relieve only EU-based micro and small enterprises.
5. Plan recycled content for the long term. The targets are coming; the exact date depends on the calculation act.

Which role you hold and what follows from it is what the PPWR check settles. Every date on one timeline is in the overview of PPWR deadlines.

Get a PPWR Software Demo

Save up to 80% of your time and costs with our software!

Book a 30-minute demo →Or start with the 2‑minute PPWR check

Change log

28 October 2026: Labelling: according to the EU portal, the Commission has planned the decision for the second quarter of 2027 since 19 October, instead of the fourth quarter of 2026; by our calculation sorting labels will therefore not apply before 2029. Authorised representative: debate in Parliament on 19 October, amendments adopted on 20 October (P10_TA(2026)0345) and referral back to the environment committee for negotiations with the Council. Added: proposal COM(2026) 590, which would delete Article 63. Planning for the acts on recycled content (18753) and recycling technologies (19033) unchanged in the fourth quarter of 2026. In brief, table, proposals section, recommendations and FAQ updated.

13 October 2026: Authorised representative: Parliament's environment committee voted on 5 October for a suspension limited to micro and small enterprises, plenary vote expected on 19 October; the Council has been discussing a solution for small producers again since September; paper by Austria, Czechia and Estonia at the Environment Council on 12 October (de minimis exemption, EU registration portal, hold back the register act). In brief, proposals section, table, recommendations and FAQ updated.

29 September 2026: Page created. Status: draft on the register of producers published on 6 August 2026, labelling decision registered as initiative 19243, recycled content acts at planning stage, proposal to suspend Article 45(3) in Parliament.

Our PPWR software generates the technical documentation and declaration of conformity per packaging unit from the captured data.

Frequently asked questions

Does the PPWR already apply?

Yes. Regulation (EU) 2025/40 has applied since 12 August 2026. Some obligations start later, some on fixed dates, some only after an act of the Commission.

Has the PPWR been postponed?

No. The date of application has not been postponed. The Commission has only proposed suspending the obligation to appoint an authorised representative under Article 45(3) until January 2035; no decision has been taken. Individual dates do move by themselves, however, if the Commission adopts an act they are linked to later.

When will harmonised labelling come?

The Commission plans the decision for the second quarter of 2027 (planning on the EU portal, as at 19 Oct 2026). The labelling obligation starts on 12 August 2028 or 24 months after its entry into force, whichever is later; with adoption in the second quarter of 2027, by our calculation not before 2029.

When will the new register of producers come?

First the Commission must adopt the format for registration and reporting; a draft has been available since 6 August 2026. Member States then have 18 months to set up their registers. In Germany registration continues through LUCID until then.

Do I have to appoint an authorised representative now?

Yes, if you supply packaging directly to end users in a Member State where you are not established. The proposed suspension only applies once Parliament and Council have adopted it and it has been published in the Official Journal. After the debate on 19 October 2026, Parliament adopted amendments on 20 October that limit it to micro and small enterprises established in the EU, and referred the file back to the environment committee for negotiations with the Council; there is no final first-reading position yet. While the proposal is in the legislative process, the Commission asks the authorities not to sanction.

Sources and status: Regulation (EU) 2025/40, Articles 5, 7, 12, 13, 44 and 45. Commission planning entries on the "Have your say" portal: initiatives 15352 (registration and reporting), 19243 (labelling), 18753 (recycled content) and 19033 (recycling technologies), retrieved on 29 September 2026 and 28 October 2026. Proposal COM(2025) 982 of 10 December 2025 and European Parliament procedure file 2025/0395(COD). Commission Notice C/2026/3084. Commission FAQ on the PPWR, 2nd edition (August 2026). Corrigendum OJ L, 2026/90654 of 4 August 2026. German Packaging Implementation Act of 13 July 2026 (BGBl. 2026 I No 207), Sections 66 and 68. Council notes 13583/26 of 28 September 2026 and 14126/26 of 9 October 2026, outcome page of the Environment Council of 12 October 2026, report A10-0266/2026 of the environment committee and procedure file 2025/0395(COD) (Legislative Observatory), Commission page on producer responsibility for small businesses, Agence Europe, Bulletin 13958 (report on the Environment Council of 12 October 2026); all retrieved on 13 October 2026. European Parliament text adopted P10_TA(2026)0345 of 20 October 2026, proposal COM(2026) 590 of 9 September 2026 and EUR-Lex document information on Regulation (EU) 2025/40, retrieved on 28 October 2026. As at 28 October 2026. This article is not legal advice.

Photo: Towfiqu barbhuiya via Unsplash.