How to build a packaging EPR reporting programme across countries

Two roles in the EU's Packaging and Packaging Waste Regulation (PPWR) decide who owes what, and they are often different companies. The producer has EPR in each Member State. That is the company that first makes packaging available there, or a company elsewhere that supplies end users there directly (Article 3(1), point (15)). The manufacturer makes the packaging, or has it made, and markets it under its own name or trademark (Article 3(1), point (13)). It draws up the EU declaration of conformity and technical documentation and keeps them for 5 years after single-use packaging is placed on the market, or 10 years for reusable packaging. The Commission's guidance notice C/2026/3084 says the two are defined for different purposes. There is one manufacturer for the whole EU, while the producer pays for waste management where the packaging becomes waste.

So run two tracks. The conformity track holds one file per packaging unit, wherever it is sold. The EPR track holds one record per country, per producer and per stream.

Take a fictional manufacturer, Tarnwick, with an EU company in Ireland and a UK company in England. It ships 200 L drums straight to factories in Germany and the Netherlands, sells 20 L jerrycans directly to workshops in France and Spain, and sells pallets of 1 L laundry liquid bottles to a distributor in Italy. Its English company supplies UK customers. Tarnwick is the producer in France, Germany, the Netherlands and Spain, because it supplies the end users there directly. The Italian distributor is the producer in Italy, so Tarnwick's job there is to give it accurate packaging data. In the UK, Tarnwick's English company is assessed under UK law.

Check the EU layer first. Each producer must register in each Member State where it first makes packaging available (Article 44(2)), and may not supply there unless registered (Article 44(4)). The new national registers are due 18 months after the Commission's implementing act on the register format (Article 44(1)). That act was due by 12 February 2026. A draft was open for feedback from 6 August to 10 September 2026, and it hadn't been adopted on 14 October 2026. Until then, producers register under each country's existing rules.

A producer that supplies end users in another Member State directly must appoint an authorised representative for EPR there by written mandate (Article 45(3)). That has applied since 12 August 2026. A Commission proposal of 10 December 2025, COM(2025) 982, would suspend the duty until 1 January 2035 for producers established in the EU. On 14 October 2026 it was awaiting Parliament's first-reading position. Meanwhile, the Commission's page for small businesses says it has asked Member States to enforce the duty pragmatically and not to sanction operators. Record the duty as it stands, and the proposal and the Commission's request separately.

Then write one record per country. Tarnwick's records, on 14 October 2026, read as follows.

France splits packaging into household and professional streams (Environment Code, Article L. 541-10-1). A ministerial order allocates products between them by volume, mass, quantity or use. For example, cleaning products up to 5 L count as household, and larger packs as professional. Professional packaging has had its own scheme since 1 January 2026, and three eco-organismes were approved for it in June 2026. Since 1 July 2026, a producer joins one before first supplying, or runs an approved individual system. Every producer registers with ADEME, which issues a unique identifier (IDU) (Article L. 541-10-13).

In Germany, the VerpackDG has applied since 12 August 2026. Every producer registers with the Zentrale Stelle Verpackungsregister (ZSVR) in LUCID before supplying (§ 6). Only packaging that typically ends up with households or comparable places joins a dual system (§ 7). Industrial drums carry take-back and recovery duties instead (§ 39).

In Italy, Legislative Decree 152/2006 covers all packaging, from households to industry (Article 217). Producers and users of packaging join CONAI unless they run their own system (Articles 221 and 224). A law in force since 9 April 2026 gives the government eight months to adapt national law to the PPWR. No decree had been adopted by 14 October 2026.

In the Netherlands, a generally binding agreement, in force from 1 January 2023 to 31 December 2027, sets a fee on all packaging, whether it ends up in household or business waste. Producers below 50,000 kg a year pay no fee and file no declaration, but keep their calculation. That threshold doesn't apply to deposit or single-use plastic packaging.

In Spain, Real Decreto 1055/2022 covers all packaging, including commercial and industrial packaging. Producers register in the packaging section of the Registro de Productores de Productos (Article 15). The environment ministry says the decree applies where it is compatible with the PPWR until a new one replaces it.

In the UK, the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 apply to producers established in the UK. A large producer has turnover above £2 million and supplies more than 50 tonnes of packaging. A small producer has turnover above £1 million and supplies more than 25 tonnes (regulation 24).

Collect data at component level, so it can be grouped the way each scheme asks. For each component, record the material, weight, packaging type, where it was sold and whether it went to households or businesses. Then link it to units sold in each country for each period.

Schemes differ on what they count. Germany, Italy and the PPWR's register information in Annex IX count weight by material. France, Spain and the Netherlands count units as well as weight. France's data rules count sales units and tonnes by material for household packaging from 2026 data. For professional packaging, they count the number of packs and tonnes by material from the second half of 2026. The UK counts weight in kilograms by material, packaging type and whether it is household packaging, with units only for drink containers (Schedule 4). The PPWR allows simpler reports below 10 tonnes a year in a Member State (Article 44(8)).

Some data comes from markings. Italy has required material identification on all packaging, including secondary and transport packaging, since 1 January 2023 (Article 219(5)).

Put every date in one calendar, with its source. In Germany, Tarnwick updates LUCID by 12 November 2026 (§ 68(2)), and keeps the take-back and recovery record for non-system packaging by 15 May each year (§ 39(3)). In Spain, it reports 2026 data before 31 March 2027 (Article 16). In the Netherlands, if it supplies over 50,000 kg, it declares 2026 weight and number before 1 April 2027. In France, 2026 data reaches ADEME by 31 May 2027, sent by the eco-organisme for its members. For professional packaging, that first report covers only the second half of 2026.

In the UK, a large producer reports July to December 2026 by 1 April 2027, and January to June 2027 by 1 October 2027 (regulation 35). A small producer reports once a year, by 1 April (regulation 36).

Scheme participation and take-back follow the same records. In Germany, any system contract made under the old law ends by 31 December 2026, and from 1 January 2028 producers of industrial packaging need ZSVR approval for their take-back, unless an approved organisation takes it on (§§ 19 and 68(9)). Spain's producers of commercial and industrial packaging had to set up EPR systems by 31 December 2024. In the UK, disposal fees apply only to household packaging supplied by large producers (regulation 60), so Tarnwick's drums are reported but carry no disposal fee.

Before each filing, reconcile reported weights against sales and specifications, and have one person check each figure against its source and approve it. Keep the evidence the law asks for. Germany requires a verifiable record for non-system packaging, shown to the authority on request (§ 39(3)). The Netherlands asks producers below the threshold to keep their calculation. Spain's registration number goes on invoices and commercial documents (Article 15(3)). France's IDU goes in the general terms of sale, or another contractual document given to the buyer, and on the producer's website (Article R. 541-173). Keep the conformity file on its own track, for 5 or 10 years.

Then watch for changes that move the calendar. These include the Commission's register act, the vote on Article 45(3), Italy's adapting decree, the end of the Dutch agreement in 2027 and Germany's approval regime from 2028. When one moves, recheck the countries it affects and record what changed.