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PPWR 2026: What Changed on 12 August 2026 and What Comes Next

The EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) has applied in all 27 member states since 12 August 2026. This page tracks what is already law, what each country has changed and which proposals are still being negotiated. Updated monthly.

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Short answer: The PPWR is an EU regulation, so it applies directly in every member state without national transposition. Since 12 August 2026 it has replaced most of the old Packaging Directive 94/62/EC. For online sellers the most important change is Article 45: anyone who sells packaged products directly to end users in another member state must appoint an authorized representative there. National registers and schemes (LUCID, Verpact, EKO-KOM and others) continue to apply.

PPWR at a glance

Legal act
Regulation (EU) 2025/40 on packaging and packaging waste; in force since 11 February 2025, applicable since 12 August 2026.
Replaces
Directive 94/62/EC, generally repealed on 12 August 2026 (some provisions continue).
Authorized representative
Art. 45: required for producers — EU or non-EU — who sell directly to end users in another member state; member states may require one from other non-EU producers.
Penalties
Member states must lay down penalty rules by 12 February 2027.
Labelling
Harmonised labels from 12 August 2028 or 24 months after the implementing acts (not adopted as of September 2026).
Fee modulation
National modulation already applies (e.g. Germany, France, UK); EU-harmonised modulation by recyclability grade expected around 2028–2030.
Exemption proposal
Proposal – not yet law Suspension of the representative duty for some EU-established producers; trilogue after the Parliament (20 Oct 2026) and Council (21 Oct 2026) positions.
Next update
This page is reviewed monthly; see the update log at the end.

What the PPWR is

The Packaging and Packaging Waste Regulation (PPWR) is Regulation (EU) 2025/40, the EU's directly applicable law on packaging design, labelling, extended producer responsibility and packaging waste. It entered into force on 11 February 2025 and has applied since 12 August 2026.

Because it is a regulation rather than a directive, the core rules are the same in all 27 member states. But the PPWR leaves important parts to national law: the registers, the producer responsibility schemes, the fees and the penalties. That is why a seller still needs a registration in each country — and why countries such as Germany, France, Sweden or Denmark adopted national implementing rules in 2026.

What changed on 12 August 2026

On 12 August 2026 the PPWR became applicable and the Packaging Directive 94/62/EC was generally repealed. For sellers, five changes matter most:

  • Authorized representative for distance sellers (Art. 45): see below.
  • New or adapted national rules: Germany replaced the VerpackG with the VerpackDG; Sweden adopted new national rules with one producer responsibility register at Naturvårdsverket; the Czech small-producer exemption no longer applies; in Belgium, foreign producers need a representative registered with EPRiBEL (formerly IVCIE).
  • Marketplace checks: Amazon announced packaging EPR compliance checks across the EU from 12 August 2026 and may need to stop selling non-compliant products; eBay requires packaging EPR numbers per country where the seller is the producer and may hide listings.
  • Transitional periods: several countries set transitional dates, e.g. Germany (LUCID data updates by 12 November 2026, old dual-system contracts until 31 December 2026 at the latest).
  • Pragmatic enforcement: the European Commission asked member states to enforce the representative duty "in a constructive and pragmatic" way while an exemption is negotiated. This is guidance, not an exemption.

Article 45: who needs an authorized representative

Under Article 45 PPWR, producers who sell packaged products directly to end users in another member state — distance sellers within the meaning of Article 3(1)(15)(c) and (d) — must appoint an authorized representative in each member state where they first make packaging available, other than the state in which they are established. This applies to EU and non-EU established producers alike. For other producers established outside the EU, member states may require an authorized representative.

Your situationAuthorized representative under the PPWR?
EU company selling directly to consumers in another EU country (e.g. German shop shipping to France)Yes, in each country of sale (Art. 45)
Non-EU company (e.g. China, UK, US) selling directly to EU end usersYes, in each country of sale (Art. 45)
Non-EU company supplying EU businesses onlyDepends on the member state
Company selling only in its own EU member stateNo representative under Art. 45; national registration still applies

National rules can go further than Article 45. France, for example, requires a mandataire for every producer not established in France, in all EPR streams, since 10 July 2026; Germany's § 5 VerpackDG applies to producers without a German branch who sell directly to end users. See the country snapshot.

Penalty rules due by 12 February 2027

Member states must lay down penalty rules for PPWR infringements by 12 February 2027 (Art. 68 PPWR). Until then, national packaging fines continue to apply.

  • Germany: fines under § 66 VerpackDG reach up to €200,000, €100,000 or €10,000 depending on the offence; the PPWR-related fines in § 66(2) apply from 12 February 2027.
  • Czech Republic: from 12 February 2027 the Green Dot may only be shown via QR code or digital marking.
  • Other countries: see the individual country guides.

Labelling and fee modulation: the timeline

Harmonised EU packaging labels and EU-harmonised fee modulation are not yet in application. According to the current timetable, both depend on Commission implementing or delegated acts.

TopicStatus (October 2026)Expected timing
Harmonised material labelsImplementing acts not adopted as of September 2026From 12 August 2028 or 24 months after the implementing acts
EU fee modulation by recyclability gradeDelegated acts due by 1 January 2028Around 2028–2030
National fee modulationAlready applies, e.g. Germany (§ 26 VerpackDG), France (eco-modulation), UK (RAM)Now
National labelsFrance: Triman still mandatory (CJEU referral of 17 July 2025, no ruling)Now

The authorized-representative exemption proposal

Proposal – not yet law

The EU is negotiating a suspension of the Article 45 representative duty for EU-established producers. It is a proposal, not law, and it would not help sellers established outside the EU.

DateInstitutionContentStatus
10 Dec 2025European CommissionEnvironmental Omnibus COM(2025) 982 proposes suspending the representative duty for EU-established producersProposal – not yet law
20 Oct 2026European ParliamentPosition: exemption for EU micro and small enterprises until 2035Proposal – not yet law
21 Oct 2026Council of the EUNegotiating position: EU-established producers placing under 1 tonne of packaging per year in another member state would not need a representative there; suspension until 2032Proposal – not yet law
NextTrilogueParliament, Council and Commission negotiate a final textOpen

What this means for you today: the Article 45 duty applies as long as no amending act is adopted and published. The proposals cover only EU-established producers, and national duties such as the French mandataire rule (Loi n° 2026-602) are separate from them. The Omnibus would also suspend the representative duty for batteries — again a proposal only (Parliament vote 20 October 2026; Council position pending).

Country implementation snapshot

Each member state keeps its own register, schemes and fees; many adapted their rules to the PPWR in 2026. Status as of 27 October 2026:

CountryNational implementationRepresentative / key point
GermanyVerpackDG (BGBl. 2026 I Nr. 207) replaced the VerpackG on 12 Aug 2026; LUCID registration free§ 5: only producers without a German branch selling directly to end users; LUCID data updates by 12 Nov 2026
FranceLoi n° 2026-602 of 8 Jul 2026, Art. L. 541-10-9-1 Code de l'environnementMandataire for all producers not established in France, all EPR streams, since 10 Jul 2026
BelgiumAuthority EPRiBEL (formerly IVCIE); cooperation agreement amendment not yet approvedForeign producers need a Belgium-established representative registered with EPRiBEL since 12 Aug 2026; annual registration fees from 2027
SwedenNew national rules: one producer responsibility register at Naturvårdsverket; approved PROs NPA and TMREU-established producers need an "auktoriserat ombud" from 12 Aug 2026; first report by 31 Mar 2027
Czech RepublicMinistry of the Environment guidance (19 Oct 2026): § 15a small-producer exemption no longer applies since 12 Aug 2026Representatives report to EKO-KOM; Green Dot only via QR/digital marking after 12 Feb 2027
DenmarkBEK 851 of 28/09/2026 (PPWR supplementary rules) in force since 15 Oct 2026; DPA registerEU companies need a Danish representative
SpainMITECO note: the PPWR prevails, RD 1055/2022 applies where compatible; new packaging royal decree in draftingProducers established elsewhere appoint a representante autorizado
AustriaVerpackungsverordnung §§ 16a–16e; registration via EDMForeign distance sellers to private consumers must appoint a Bevollmächtigter
NetherlandsVerpact (formerly Afvalfonds Verpakkingen)Registration with Verpact only above 50,000 kg per year placed on the Dutch market

Still pending: Poland's packaging EPR reform bill UC100, Spain's new packaging and battery royal decrees, the Belgian cooperation agreement amendment and the Czech packaging law amendment — all Proposal – not yet law.

PPWR timeline: the next dates

DateScopeWhat happens
11 Feb 2025EUPPWR enters into force
12 Aug 2026EUPPWR applies; Directive 94/62/EC generally repealed
12 Nov 2026DEUpdate LUCID registration data
31 Dec 2026DEOld dual-system participations end at the latest
1 Jan 2027BE / DEEPRiBEL annual registration fees start; German dual systems must prove additional requirements
12 Feb 2027EU / DE / CZNational PPWR penalty rules due; German PPWR-related fines apply; Czech Green Dot only via QR/digital marking
31 Mar 2027SEFirst producer report (12 Aug–31 Dec 2026)
17 May 2027DECompleteness declaration for 2026
1 Jan 2028EUDelegated acts on fee modulation due
12 Aug 2028EUHarmonised labelling at the earliest (or 24 months after implementing acts)
PendingEUProposal – not yet law Representative exemption for EU-established producers (trilogue)

Full calendar including WEEE, batteries and the UK: EPR deadlines.

How Certify helps

  1. Free obligation check: we map your sales countries and channels to the PPWR and national rules.
  2. Registrations and representatives: Certify GmbH registers you in each country and acts as authorized representative where Article 45 or national law requires one.
  3. Updates: when the exemption proposal or national rules change, we tell you what it means for your countries.

Start the free PPWR check

Frequently asked questions — PPWR 2026

What is the PPWR?

The PPWR is the EU Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40. It entered into force on 11 February 2025 and has applied directly in all EU member states since 12 August 2026, generally replacing the Packaging Directive 94/62/EC. National registers, schemes and fees continue to apply alongside it.

What changed on 12 August 2026?

The PPWR became applicable and the Packaging Directive was generally repealed. Distance sellers now need an authorized representative in each member state other than their own where they sell directly to end users, several countries adopted new national rules (for example the German VerpackDG), and Amazon and eBay announced packaging EPR checks across the EU.

Who needs an authorized representative under Article 45 PPWR?

Producers who sell packaged products directly to end users in another member state must appoint an authorized representative in each member state where they make packaging available, other than their own. This applies to EU and non-EU established producers. For other non-EU producers, member states may require one.

Is the authorized representative exemption already law?

No. The exemption is a proposal. The Commission proposed it on 10 December 2025, the European Parliament adopted its position on 20 October 2026 and the Council agreed its negotiating position on 21 October 2026. Trilogue negotiations follow. The proposals cover only EU-established producers and do not help non-EU sellers.

When do PPWR penalties apply?

Member states must lay down their penalty rules for PPWR infringements by 12 February 2027. In Germany, the PPWR-related fines under § 66(2) VerpackDG apply from 12 February 2027. National packaging fines already apply today.

When will harmonised packaging labels apply?

Harmonised labelling under the PPWR applies from 12 August 2028 or 24 months after the Commission's implementing acts. The implementing acts had not been adopted as of September 2026, so national rules such as the French Triman logo still apply.

Update log

We review this page monthly and whenever an EU institution or a member state publishes a relevant change.

  • — Guide created. Council negotiating position (21 October 2026) and European Parliament position (20 October 2026) on the authorized-representative exemption added.

Free PPWR check: which countries, which representatives?

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