EPR Obligations EU → PPWR 2026
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.
Last reviewed: · Sources linked below
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- Directive 94/62/EC, generally repealed on 12 August 2026 (some provisions continue).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 situation | Authorized 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 users | Yes, in each country of sale (Art. 45) |
| Non-EU company supplying EU businesses only | Depends on the member state |
| Company selling only in its own EU member state | No 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.
| Topic | Status (October 2026) | Expected timing |
|---|---|---|
| Harmonised material labels | Implementing acts not adopted as of September 2026 | From 12 August 2028 or 24 months after the implementing acts |
| EU fee modulation by recyclability grade | Delegated acts due by 1 January 2028 | Around 2028–2030 |
| National fee modulation | Already applies, e.g. Germany (§ 26 VerpackDG), France (eco-modulation), UK (RAM) | Now |
| National labels | France: 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.
| Date | Institution | Content | Status |
|---|---|---|---|
| 10 Dec 2025 | European Commission | Environmental Omnibus COM(2025) 982 proposes suspending the representative duty for EU-established producers | Proposal – not yet law |
| 20 Oct 2026 | European Parliament | Position: exemption for EU micro and small enterprises until 2035 | Proposal – not yet law |
| 21 Oct 2026 | Council of the EU | Negotiating position: EU-established producers placing under 1 tonne of packaging per year in another member state would not need a representative there; suspension until 2032 | Proposal – not yet law |
| Next | Trilogue | Parliament, Council and Commission negotiate a final text | Open |
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:
| Country | National implementation | Representative / key point |
|---|---|---|
| Germany | VerpackDG (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 |
| France | Loi n° 2026-602 of 8 Jul 2026, Art. L. 541-10-9-1 Code de l'environnement | Mandataire for all producers not established in France, all EPR streams, since 10 Jul 2026 |
| Belgium | Authority EPRiBEL (formerly IVCIE); cooperation agreement amendment not yet approved | Foreign producers need a Belgium-established representative registered with EPRiBEL since 12 Aug 2026; annual registration fees from 2027 |
| Sweden | New national rules: one producer responsibility register at Naturvårdsverket; approved PROs NPA and TMR | EU-established producers need an "auktoriserat ombud" from 12 Aug 2026; first report by 31 Mar 2027 |
| Czech Republic | Ministry of the Environment guidance (19 Oct 2026): § 15a small-producer exemption no longer applies since 12 Aug 2026 | Representatives report to EKO-KOM; Green Dot only via QR/digital marking after 12 Feb 2027 |
| Denmark | BEK 851 of 28/09/2026 (PPWR supplementary rules) in force since 15 Oct 2026; DPA register | EU companies need a Danish representative |
| Spain | MITECO note: the PPWR prevails, RD 1055/2022 applies where compatible; new packaging royal decree in drafting | Producers established elsewhere appoint a representante autorizado |
| Austria | Verpackungsverordnung §§ 16a–16e; registration via EDM | Foreign distance sellers to private consumers must appoint a Bevollmächtigter |
| Netherlands | Verpact (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
| Date | Scope | What happens |
|---|---|---|
| 11 Feb 2025 | EU | PPWR enters into force |
| 12 Aug 2026 | EU | PPWR applies; Directive 94/62/EC generally repealed |
| 12 Nov 2026 | DE | Update LUCID registration data |
| 31 Dec 2026 | DE | Old dual-system participations end at the latest |
| 1 Jan 2027 | BE / DE | EPRiBEL annual registration fees start; German dual systems must prove additional requirements |
| 12 Feb 2027 | EU / DE / CZ | National PPWR penalty rules due; German PPWR-related fines apply; Czech Green Dot only via QR/digital marking |
| 31 Mar 2027 | SE | First producer report (12 Aug–31 Dec 2026) |
| 17 May 2027 | DE | Completeness declaration for 2026 |
| 1 Jan 2028 | EU | Delegated acts on fee modulation due |
| 12 Aug 2028 | EU | Harmonised labelling at the earliest (or 24 months after implementing acts) |
| Pending | EU | Proposal – not yet law Representative exemption for EU-established producers (trilogue) |
Full calendar including WEEE, batteries and the UK: EPR deadlines.
How Certify helps
- Free obligation check: we map your sales countries and channels to the PPWR and national rules.
- Registrations and representatives: Certify GmbH registers you in each country and acts as authorized representative where Article 45 or national law requires one.
- Updates: when the exemption proposal or national rules change, we tell you what it means for your countries.
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.
- EUR-Lex – Regulation (EU) 2025/40 (PPWR)
- European Commission – Packaging waste
- European Commission – EPR for packaging and small businesses
- Council of the EU – negotiating position of 21 October 2026
- Packaging Europe – Parliament vote of 20 October 2026 (secondary source)
- ZSVR (Germany) – What changed on 12 August 2026
- Légifrance – Loi n° 2026-602 du 8 juillet 2026
- Fost Plus (Belgium) – mandatory registration in the producer register
- Naturvårdsverket (Sweden) – new national rules following the PPWR
- MŽP (Czech Republic) – methodological guidance on Regulation 2025/40 (19 Oct 2026)
- Dansk Producentansvar (Denmark) – producer responsibility FAQ
- MITECO (Spain) – packaging producer register FAQ
- USP (Austria) – Bevollmächtigte for packaging
- Verpact (Netherlands) – Do you need to register under the PPWR?
This page is general information, not legal advice. Last reviewed 27 October 2026.
Country guides
EPR obligations are national: registers, schemes and representative rules differ from country to country.
Free PPWR check: which countries, which representatives?
Tell us where your company is established and to which EU countries you sell. We check where the PPWR and national rules require registrations and an authorized representative, and which 2027 deadlines apply to you. Your message is delivered directly to Certify — specialists in EU-wide producer responsibility compliance. Free first consultation, no obligation. Response within 24 hours.