PPWR: what Regulation (EU) 2025/40 asks of you now, and what waits

PPWR is the Packaging and Packaging Waste Regulation. Its application rule delays only one article, Art. 67(5)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 67, paragraph 5Click opens the article on EUR-Lex., to 12 February 2029. Many duties carry their own later start date inside their articles; the timeline below lists them.

Art. 6(3)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 6, paragraph 3Click opens the article on EUR-Lex.: “from 1 January 2030 or 24 months from the entry into force of the delegated acts adopted pursuant to paragraph 4 of this Article, whichever is the latest, packaging shall not be placed on the market unless it is recyclable within grades A, B or C”, and “from 1 January 2038 packaging shall not be placed on the market unless it is recyclable within grades A or B”. Art. 12(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12, paragraph 1Click opens the article on EUR-Lex.: “From 12 August 2028 or 24 months from the date of entry into force of the implementing acts adopted pursuant to paragraphs 6 or 7 of this Article, whichever is the latest”.

What PPWR is, and since when it binds you

The Regulation shall apply “from 12 August 2026”, with one named exception: “Article 67(5) shall apply from 12 February 2029” (Art. 71Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 71Click opens the article on EUR-Lex.). That is the whole of the timing rule. Unless an article carries its own later date, as Art. 67(5)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 67, paragraph 5Click opens the article on EUR-Lex. does, PPWR has bound every obligated party since 12 August 2026.

It binds producers. A producer is “any manufacturer, importer or distributor” to whom one of five cases applies, “irrespective of the selling technique used, including by means of distance contracts” (Art. 3(15)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 15Click opens the article on EUR-Lex.). Two of the five are about your own country: you are established in an EU country and you make transport, service or primary production packaging, or products packaged in other packaging, available for the first time from within that territory and on that same territory (Art. 3(15)(a)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 15, point (a)Click opens the article on EUR-Lex., Art. 3(15)(b)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 15, point (b)Click opens the article on EUR-Lex.). Two are about selling into another EU country, and they carry a condition the first two do not: the first making available there must be “directly to end users” (Art. 3(15)(c)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 15, point (c)Click opens the article on EUR-Lex., Art. 3(15)(d)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 15, point (d)Click opens the article on EUR-Lex.). The fifth covers unpacking packaged products without being an end user, unless someone else is the producer under points (a) to (d) (Art. 3(15)(e)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 15, point (e)Click opens the article on EUR-Lex.).

“Economic operator” covers the manufacturer, supplier, importer, distributor, authorised representative, final distributor and the fulfilment service provider (Art. 3(12)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 12Click opens the article on EUR-Lex.). “E-commerce packaging” has its own definition: “transport packaging used to deliver products in the context of sale online or through other means of distance sales to the end user” (Art. 3(8)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 8Click opens the article on EUR-Lex.).

None of those definitions states a size threshold. Article 3Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3Click opens the article on EUR-Lex. states one elsewhere, and it is written about the word “manufacturer”. Where the person that has packaging or a packaged product designed or manufactured under its own name or trademark “falls within the definition of micro-enterprise set out in Recommendation 2003/361/EC as applicable on 11 February 2025”, and the person that supplies that packaging to it “is located in the same Member State”, then “‘manufacturer’ means the natural or legal person that supplies the packaging” (Art. 3(13)(b)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 13, point (b)Click opens the article on EUR-Lex.).

The two definitions are joined, because Art. 3(15)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 15Click opens the article on EUR-Lex. opens on “any manufacturer, importer or distributor”. So moving the manufacturer label under Art. 3(13)(b)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 13, point (b)Click opens the article on EUR-Lex. changes which of those three words a micro-enterprise brand owner answers to. Whether it also moves producer status is not settled by either text; it is under “What the law leaves open” below.

Whether it binds you now: the registration test

Registration is the plainest live duty. A producer “shall not make available packaging or packaged products on the territory of a Member State for the first time… if they… are not registered in that Member State” (Art. 44(4)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44, paragraph 4Click opens the article on EUR-Lex.). You register “by submitting an application for registration to the competent authority” (Art. 44(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44, paragraph 2Click opens the article on EUR-Lex.). Nothing in Art. 71Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 71Click opens the article on EUR-Lex. delays Art. 44Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44Click opens the article on EUR-Lex., so the duty has run since 12 August 2026 for anyone making packaging or packaged products available for the first time in an EU country.

The new national register under Art. 44(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44, paragraph 1Click opens the article on EUR-Lex. is due within 18 months of a Commission implementing act on the register’s format, which the Commission owed “by 12 February 2026” (Art. 44(14)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44, paragraph 14Click opens the article on EUR-Lex.). That act had not been adopted as of 5 October 2026, so the 18-month clock has not started.

Which duties are already live for online platforms and fulfilment providers

Sell through an online platform, or use an EU fulfilment service provider, and four more duties are running. None of them carries a date of its own.

Art. 45Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45Click opens the article on EUR-Lex. carries no date anywhere in its text, and neither does Art. 20Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 20Click opens the article on EUR-Lex.. Since Art. 71Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 71Click opens the article on EUR-Lex. names only Art. 67(5)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 67, paragraph 5Click opens the article on EUR-Lex. as delayed, all four rows have run since 12 August 2026.

The suspension duty belongs to Art. 45(8)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45, paragraph 8Click opens the article on EUR-Lex. itself. Art. 45(9)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45, paragraph 9Click opens the article on EUR-Lex., which gives the producer a right to challenge “the decision of the fulfilment service provider”, describes that provider as one that “suspends the provision of its services pursuant to paragraph 8”. The home paragraph is (8), not (9).

Why packaging minimisation is a design duty that runs now

Art. 10(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 10, paragraph 2Click opens the article on EUR-Lex. carries no date of its own and bans two things, not one. The manufacturer or importer must keep off the market both “packaging which does not comply with the performance criteria set out in Annex IV of this Regulation” and “packaging with characteristics that aim only to increase the perceived volume of the product, including double walls, false bottoms and unnecessary layers”. Two things lift that ban: a design or shape protected as a design right or trademark before 11 February 2025, where the ban would strip the protection of effect, and a packaged product carrying a protected geographical indication or falling under an EU quality scheme.

The Annex IV half of that ban is a design-and-documentation duty. Annex IV Part A sets out eight performance criteria the packaging design is assessed against: product protection, packaging manufacturing processes, logistics, packaging functionality, information requirements, hygiene and safety, legal requirements, and recycled content, recyclability and re-use. Part B says the assessment of the minimum necessary volume and weight “shall be explained in the technical documentation”, and must contain, for each criterion in Part A, “a description which explains the design requirement that prevents further reduction of the packaging weight or volume without endangering the packaging functionality”, the calculation behind that minimum, and any test results, market research or studies used. Part B also rules one answer out: “substitution of one packaging material with another shall not be considered sufficient”.

Art. 10(4)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 10, paragraph 4Click opens the article on EUR-Lex. puts that documentation in Annex VII and requires “an explanation of the technical specifications, standards and conditions used to assess the packaging against the performance criteria and methodology set out in Annex IV”. Unlike the weight-and-volume minimisation duty in Art. 10(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 10, paragraph 1Click opens the article on EUR-Lex., which starts “by 1 January 2030”, neither Art. 10(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 10, paragraph 2Click opens the article on EUR-Lex. nor Annex IV carries a date of its own, so both run from 12 August 2026 (Art. 71Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 71Click opens the article on EUR-Lex.). The 50% ratio test is not part of Article 10Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 10Click opens the article on EUR-Lex..

The Commission’s guidance reads it differently: after the end of 2029, “both paragraphs 1 and 2 of Article 10 will apply (from 1 January 2030)” (Commission Notice C/2026/3084, section 10; guidance, not law). Its basis is Art. 70(1)(b)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 70, paragraph 1, point (b)Click opens the article on EUR-Lex., which keeps the old Packaging Directive’s minimisation requirement and its standard in force until 31 December 2029; that point does not say Art. 10(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 10, paragraph 2Click opens the article on EUR-Lex. waits. The text wins over a notice, so put the Annex IV assessment in the file now.

What paperwork the manufacturer owes: assessment, documentation, declaration

Before a manufacturer places packaging on the market it carries out the conformity assessment under Art. 38Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 38Click opens the article on EUR-Lex., draws up the technical documentation of Annex VII and signs an EU declaration of conformity; none of the three carries a date of its own, so all have run since 12 August 2026 (Art. 15(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 15, paragraph 2Click opens the article on EUR-Lex., Art. 39Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 39Click opens the article on EUR-Lex., Art. 71Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 71Click opens the article on EUR-Lex.). Who counts as the manufacturer, what the declaration says and for how long it is kept are in the PPWR declaration of conformity guide.

What the PPWR declaration of conformity template contains

The template is Annex VIII of the Regulation (Art. 39(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 39, paragraph 2Click opens the article on EUR-Lex.). Its eight points, the signature block and two filled-in samples are in the PPWR declaration of conformity guide.

What applies to PFAS in food-contact packaging since 12 August 2026

“From 12 August 2026, food-contact packaging shall not be placed on the market” if it holds PFAS at or above any one of three limits (Art. 5(5)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 5, paragraph 5Click opens the article on EUR-Lex.):

The ban applies only “to the extent that the placing on the market of packaging containing such a concentration of PFAS is not prohibited pursuant to another Union legal act”, so a stricter rule elsewhere still governs. The article defines PFAS as any substance with at least one fully fluorinated methyl (CF3-) or methylene (-CF2-) carbon atom, with the exceptions it lists.

Compliance is shown in the technical documentation of Annex VII (Art. 5(6)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 5, paragraph 6Click opens the article on EUR-Lex.). Where total fluorine is above 50 mg/kg, the manufacturer, importer or downstream user under the REACH Regulation must, on request, give the packaging’s manufacturer or importer proof of the quantity of fluorine measured, whether it comes from PFAS or from other substances, so the file can be completed. The manufacturer and the importer may place on the market only packaging that meets the requirement (Art. 15(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 15, paragraph 1Click opens the article on EUR-Lex., Art. 18(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 18, paragraph 1Click opens the article on EUR-Lex.), and a distributor that has reason to believe packaging does not meet it may not make that packaging available until it does (Art. 19(3)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 19, paragraph 3Click opens the article on EUR-Lex.). The other rules for a material that touches food, such as migration limits and the declaration of compliance, are in food contact materials.

PPWR labeling requirements: what goes on the packaging and when

PPWR puts several different marks on packaging. They do not start together. The manufacturer’s and importer’s identification is live now. The main mark, the harmonised sorting label, waits for a Commission act that does not exist yet.

The harmonised material label and the date that has not been set

From 12 August 2028, or 24 months from the entry into force of the Commission’s implementing acts, “whichever is the latest”, packaging “shall be marked with a harmonised label containing information on its material composition in order to facilitate consumer sorting” (Art. 12(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12, paragraph 1Click opens the article on EUR-Lex.). The label is based on pictograms. The Commission owed those acts “by 12 August 2026” (Art. 12(6)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12, paragraph 6Click opens the article on EUR-Lex., Art. 12(7)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12, paragraph 7Click opens the article on EUR-Lex.). As of 5 October 2026 they have not been adopted.

That has a plain effect on the date. An act that enters into force after 12 August 2026 starts a 24-month clock that ends after 12 August 2028, and the later date wins. So the label cannot apply on 12 August 2028 any more. The real date is 24 months after the later of the acts under Art. 12(6)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12, paragraph 6Click opens the article on EUR-Lex. and Art. 12(7)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12, paragraph 7Click opens the article on EUR-Lex. enters into force, and nobody can name it until those acts are adopted. The reusable label works the same way, with 30 months and 12 February 2029.

The obligation does not reach transport packaging, “with the exception of e-commerce packaging”, or packaging in a deposit and return system. The duty to meet it sits on the manufacturer of the packaging and on the importer (Art. 15(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 15, paragraph 1Click opens the article on EUR-Lex., Art. 18(2)(b)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 18, paragraph 2, point (b)Click opens the article on EUR-Lex.). A mailer or box that carries your name or trademark makes you its manufacturer (Art. 3(13)(a)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 13, point (a)Click opens the article on EUR-Lex.). For a stock mailer with no brand on it, the Commission’s guidance says the manufacturer is normally the company that makes it, and the user only when the user clearly brands it (Commission Notice C/2026/3084, section 2; guidance, not law). If you ship sales packaging as it is, the same rule reaches it as packaging placed on the market.

Where the label cannot fit on the packaging because of its nature and size, it goes on the grouped packaging, and if that does not work either, in a single electronically readable code. It must be affixed, printed or engraved “visibly, legibly and firmly”, and the information must also be available to buyers before purchase when you sell online. The language is the one the EU country of sale sets (Art. 12(5)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12, paragraph 5Click opens the article on EUR-Lex.). Stock made in or imported into the Union before the date and not carrying the label may be sold until 3 years after the labelling requirement enters into force (Art. 12(12)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12, paragraph 12Click opens the article on EUR-Lex.).

Packaging with substances of concern is marked by standardised, open, digital technologies. The method for that comes in a second act, due by 1 January 2030 (Art. 12(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12, paragraph 1Click opens the article on EUR-Lex., Art. 12(7)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12, paragraph 7Click opens the article on EUR-Lex.). The Commission’s guidance says it does not intend to prioritise the act on digital marking of material composition (Commission Notice C/2026/3084, opening section “Subject matter and scope”; guidance, not law).

Reusable packaging: label plus QR code

Reusable packaging placed on the market from 12 February 2029, or 30 months after the Commission’s label act if later, must “bear a label informing users that the packaging is reusable”. Further detail, such as the re-use system and the collection points, goes in a QR code or other open digital data carrier (Art. 12(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12, paragraph 2Click opens the article on EUR-Lex.). Open-loop systems without a system operator are exempt from the label and the QR code (Art. 12(3)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12, paragraph 3Click opens the article on EUR-Lex.). Reusable sales packaging must also be clearly told apart from single-use packaging at the point of sale.

Deposit-return packaging: a clear label, not the harmonised one

Packaging in a mandatory deposit and return system under Art. 50(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 50, paragraph 1Click opens the article on EUR-Lex. (single-use plastic beverage bottles and single-use metal beverage containers up to three litres, with the exceptions in Art. 50(4)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 50, paragraph 4Click opens the article on EUR-Lex., such as wine, spirits and milk) “shall be marked with a clear and unambiguous label”. The harmonised pictogram label does not apply to it (Art. 12(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12, paragraph 1Click opens the article on EUR-Lex.). The national label stays. A harmonised colour label will come in the Commission’s act, and an EU country may require it, provided that creates no trade barriers. Other EU countries’ deposit labels may stay on your goods: a country “shall not prohibit” them (Art. 12(10)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12, paragraph 10Click opens the article on EUR-Lex.).

Compostable packaging: three words on the label

For the compostable formats of Art. 9(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 9, paragraph 1Click opens the article on EUR-Lex., which are permeable tea, coffee or other beverage bags, soft after-use single-serve units, and sticky labels on fruit and vegetables, the harmonised label must say the material is compostable, that it is not suitable for home composting, and that it is not to be discarded in nature. The same applies to the formats in Art. 9(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 9, paragraph 2Click opens the article on EUR-Lex. “where applicable”, which an EU country may require to be compostable (Art. 3(1)(f)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 1, point (f)Click opens the article on EUR-Lex., Art. 9(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 9, paragraph 1Click opens the article on EUR-Lex., Art. 9(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 9, paragraph 2Click opens the article on EUR-Lex., Art. 12(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12, paragraph 1Click opens the article on EUR-Lex.).

Your name and address on the packaging, already

This one has no later date, so it runs from 12 August 2026 (Art. 71Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 71Click opens the article on EUR-Lex.). The manufacturer of the packaging must make sure it bears a type, batch or serial number or another element that identifies it. Where the size or nature of the packaging does not allow that, the information goes in a document that comes with the packaged product (Art. 15(5)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 15, paragraph 5Click opens the article on EUR-Lex.). The manufacturer must also indicate, on the packaging or on a QR code or other data carrier, “their name, registered trade name or registered trademark” and a postal address, which “shall indicate a single point at which the manufacturer can be contacted”, plus electronic contact where available. Only where that is not possible does it go in the information given through the QR code or data carrier of Art. 12Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12Click opens the article on EUR-Lex., or in a document that comes with the packaged product (Art. 15(6)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 15, paragraph 6Click opens the article on EUR-Lex.). It must not replace or hide information that other EU law requires on the product (Art. 15(7)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 15, paragraph 7Click opens the article on EUR-Lex.). Having packaging made under your own name or trademark makes you the manufacturer (Art. 3(13)(a)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 13, point (a)Click opens the article on EUR-Lex.). A micro-enterprise with a supplier in the Union passes the duties of Art. 15Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 15Click opens the article on EUR-Lex. to that supplier (Art. 15(12)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 15, paragraph 12Click opens the article on EUR-Lex.).

An importer must put its own name and its registered trade name or trademark on the packaging, with a postal address. Where that is not possible, it goes in the digital data carrier of Art. 12Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12Click opens the article on EUR-Lex. or in a document that comes with the packaged product (Art. 18(3)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 18, paragraph 3Click opens the article on EUR-Lex.). The importer must also check that the packaging is labelled as Art. 12Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12Click opens the article on EUR-Lex. requires (Art. 18(2)(b)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 18, paragraph 2, point (b)Click opens the article on EUR-Lex.).

National sorting marks until the EU label applies

The harmonised label is not in force, so the national marks on your packaging are not replaced by it yet. The Commission reads Art. 12Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12Click opens the article on EUR-Lex. as fully harmonised, so no new national sorting-instruction marks should be added, and existing ones may not stand next to the EU label once it applies (Commission Notice C/2026/3084, section 13; guidance, not law). The Notice asks countries to repeal or adapt them before that date. No binding text sets a date, so the packaging recycling symbols a country already requires stay until it acts or the EU label applies. The marks each country requires today are on packaging recycling symbols. One limit already holds in the text: a label must not mislead buyers about packaging waste options for which a harmonised label has been laid down (Art. 12(8)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12, paragraph 8Click opens the article on EUR-Lex.). A second limit is coming. By 12 February 2027, packaging in an EPR scheme may be identified “only by means of a corresponding symbol in a QR code or other standardised, open, digital-marking technology” (Art. 12(9)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12, paragraph 9Click opens the article on EUR-Lex.). The Commission reads this as a ban on physical EPR labels (section 13 of the Notice; guidance, not law). No labelling rule changes who must register: that is the producer register above.

When expanded polystyrene foam was banned: 2021

Food containers for immediate consumption, beverage containers with their caps and lids, and cups with their covers and lids made of expanded polystyrene (EPS) have been banned since 3 July 2021. The ban comes from Directive (EU) 2019/904Directive (EU) 2019/904, Single-Use Plastics DirectiveThe whole regulationClick opens the law on the EU Publications Office., which made each EU country ban them in its own law (Art. 5Directive (EU) 2019/904, Single-Use Plastics DirectiveArticle 5Click opens the article on EUR-Lex. and Art. 17(1)Directive (EU) 2019/904, Single-Use Plastics DirectiveArticle 17, paragraph 1Click opens the article on EUR-Lex. of Directive (EU) 2019/904, Annex Part B points 7-9). What PPWR adds to that list applies from 12 February 2029. The Directive’s other duties are on the single-use plastics directive.

When the one near-term date lands: HORECA refill, 12 February 2027

One dated duty is close, and it is narrow. By 12 February 2027 a final distributor making hot or cold beverages available in take-away packaging must “provide a system for consumers to bring their own container to be filled”, and the same duty runs separately for ready-prepared food in take-away packaging (Art. 32(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 32, paragraph 1Click opens the article on EUR-Lex.). It is written for final distributors of prepared food and drink. A business that ships packaged goods is outside it.

What you can set aside for now

How penalties work: a Union deadline, national figures

Each EU country must lay down penalties for infringing the Regulation and notify the Commission of them “by 12 February 2027”, and those penalties must be “effective, proportionate and dissuasive” (Art. 68(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 68, paragraph 1Click opens the article on EUR-Lex., Art. 68(3)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 68, paragraph 3Click opens the article on EUR-Lex.). For infringements of Articles 24Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 24Click opens the article on EUR-Lex. to 29Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 29Click opens the article on EUR-Lex. the penalties “shall include administrative fines” (Art. 68(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 68, paragraph 2Click opens the article on EUR-Lex.). The Regulation fixes the deadline and the standard, never the figures. Each country sets the figures in its own national law, and each sets its own EPR fees.

What the law leaves open

• Whether the Art. 3(13)(b)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 13, point (b)Click opens the article on EUR-Lex. carve-out moves producer status, not just the manufacturer label. Art. 3(13)(b)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 13, point (b)Click opens the article on EUR-Lex. says only that in that case “‘manufacturer’ means the natural or legal person that supplies the packaging”. It says nothing about “producer”. Art. 3(15)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 15Click opens the article on EUR-Lex. defines a producer as “any manufacturer, importer or distributor” meeting one of its five cases, so it reads the word the other definition has just moved. Two readings survive on the text alone: the micro-enterprise brand owner stops being a producer because it is no longer the manufacturer, or it remains one as a “distributor”, which Art. 3(18)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 18Click opens the article on EUR-Lex. defines as any person in the supply chain “other than the manufacturer or importer, that makes packaging available on the market”. Neither article chooses between them, and no binding text does. Meanwhile, if you are a micro-enterprise brand owner supplied from your own country, do not treat the carve-out as removing your Art. 44(4)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44, paragraph 4Click opens the article on EUR-Lex. registration duty.
• How the Art. 44(4)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44, paragraph 4Click opens the article on EUR-Lex. duty works in a country whose register under Art. 44(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44, paragraph 1Click opens the article on EUR-Lex. has not opened. Art. 44(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44, paragraph 1Click opens the article on EUR-Lex. ties the register to “18 months of the date of entry into force” of the format act, so a fixed month for “when the register opens” is an estimate, not the text, and the text is silent on the gap between a live duty and a register that is not there yet. How registrations are taken until then depends on the country. Meanwhile, apply to the competent authority of each country before you first sell there (Art. 44(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44, paragraph 2Click opens the article on EUR-Lex.); the duty does not wait for the register.
• Who is the manufacturer outside Art. 15Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 15Click opens the article on EUR-Lex. when a micro-enterprise brand owner’s packaging supplier is in another EU country. For the paperwork the text is clear: Art. 15(12)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 15, paragraph 12Click opens the article on EUR-Lex. is the specific rule, and makes the supplier the manufacturer “for the purposes of this Article” wherever in the Union it is located; Art. 21Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 21Click opens the article on EUR-Lex. uses the same “located in the Union” test. The gap is the general label. Art. 3(13)(b)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 13, point (b)Click opens the article on EUR-Lex. moves it to the supplier only where the supplier is in the same EU country as the brand owner, so with a supplier in another EU country the brand owner stays the manufacturer under Art. 3(13)(a)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 13, point (a)Click opens the article on EUR-Lex. for every article outside Art. 15Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 15Click opens the article on EUR-Lex., while its conformity assessment and declaration are the supplier’s. No binding text says how the two halves fit together. Meanwhile, have the supplier carry out the assessment, draw up the technical documentation and sign the declaration, as Art. 15(12)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 15, paragraph 12Click opens the article on EUR-Lex. requires, and treat yourself as the manufacturer for everything else, including your Art. 44(4)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44, paragraph 4Click opens the article on EUR-Lex. registration.