PPWR deadlines: separating company obligations from Commission milestones

Four dates describe the Regulation itself. It was adopted on 19 December 2024 and published in the Official Journal on 22 January 2025. It entered into force on 11 February 2025, which starts the clock for some deadlines. It has applied since 12 August 2026 (Article 71). The one exception in Article 71 is Article 67(5), which adds products to the bans in the Single-Use Plastics Directive from 12 February 2029, including plastic chips used to protect goods in transport.

Implementation dates are separate again. They are the deadlines for the Commission's implementing and delegated acts, standardisation requests and guidelines, and for Member State measures such as penalties, due by 12 February 2027 (Article 68). An implementation date says when someone else must act. It becomes a company date only where an article ties a company obligation to it.

The Commission milestones, as they stood on 14 October 2026, run as follows. Some had already passed without an adopted act.

The implementing act on the format of producer registers was due by 12 February 2026 (Article 44(14)). A draft was published for feedback from 6 August to 10 September 2026, and it hasn't been adopted. Member States then have 18 months from its entry into force to set up the new registers.

The implementing acts on harmonised labels were due by 12 August 2026 (Article 12(6)). The Commission published a planning notice on 14 September 2026, with a draft still to come and adoption planned for the fourth quarter of 2026.

The implementing acts on calculating and verifying recycled content, and on the equivalence of recycled content from outside the EU, and the delegated act on sustainability criteria for recycling technologies, are all due by 31 December 2026 (Article 7(8) to (10)). Calls for evidence ran from 14 August to 16 September 2026, the drafts are still to come, and adoption is planned for the fourth quarter of 2026.

Later deadlines include 12 February 2027 for the minimum rotations of reusable packaging (Article 11(2)) and the guidelines on the Annex V bans (Article 25(6)). They also include 30 June 2027 for the reuse target calculation method (Article 30(3)), 1 January 2028 for the design for recycling criteria (Article 6(4)), and 12 February 2028 for the empty space calculation method (Article 24(2)).

Some Commission work has been adopted. Delegated Decision (EU) 2026/429 exempts users of pallet wrapping and straps from the 100% reuse requirements in Article 29(2) and (3), though not from the 40% target in Article 29(1). The Commission's guidance notice C/2026/3084 was published on 10 June 2026, and the second edition of its FAQ in August 2026.

Fixed company dates don't move if the Commission is late. From 12 August 2026, these include the substance requirements in Article 5, including the 100 mg/kg limit for lead, cadmium, mercury and hexavalent chromium and the PFAS limits for food contact packaging. The same date covers the conformity assessment, technical documentation and EU declaration of conformity (Article 15), and the duties of importers and distributors (Articles 18 and 19). From 12 February 2028, fillers of sales packaging must cut empty space to the minimum necessary (Article 24(4)). From 1 January 2030, packaging must be minimised (Article 10), the Annex V formats are banned for their listed uses (Article 25), and the reuse targets in Article 29 apply. From 1 January 2038, only recyclability grades A and B are allowed (Article 6(3)).

Other dates move with an act, taking the later of a fixed date and a period after the act enters into force. Designed for recycling and grades A to C apply from 1 January 2030 or 24 months after the design for recycling acts (Article 6(2) and (3)). Recycled content targets apply from 1 January 2030 or three years after the Article 7(8) act (Article 7(1)). The harmonised sorting label applies from 12 August 2028 or 24 months after the label acts (Article 12(1)). The 50% empty space limit for grouped, transport and e-commerce packaging applies from 1 January 2030 or three years after the method (Article 24(1)). Proof of the reuse targets applies from 1 January 2030 or 18 months after the calculation method (Article 30(4)).

Some fixed obligations still depend on missing detail in practice. All packaging must be recyclable from 12 August 2026 (Article 6(1)), but the Commission's guidance notice says manufacturers don't need to run the recyclability conformity assessment until the design for recycling acts enter into force. No harmonised standards under the Regulation had references published at the check date. The Commission's FAQ says the standards under the old Packaging Directive no longer give a presumption of conformity, except the minimisation standard, which keeps it until the end of 2029.

EPR registration also sits on a dependency. Producers keep registering under each country's existing rules until the new Article 44 registers are in place, as the Commission's guidance for small businesses confirms.

Take a fictional manufacturer, Tarnwick, which ships its products on pallets wrapped in bought-in stretch film. Its timeline row for that wrap reads as follows. The requirement is recycled content of 35% for other plastic packaging (Article 7(1)(d)), owed by the film's manufacturer. It applies from 1 January 2030, or three years after the Article 7(8) act enters into force if that is later. The act was still at call for evidence stage on 14 October 2026. The calculated date stays 1 January 2030 only if the act enters into force by 1 January 2027. The owner is procurement, and the action is to ask the film supplier for its recycled content evidence once the method is adopted.

Give each company obligation one row. Record the article, the fixed date, the Commission act it depends on, that act's status and the date it was checked, the calculated date, the owner and the next review date. Keep Commission milestones in a separate list that feeds the trigger column, so a change in one updates the other.

Check the act statuses at least quarterly, and when the Commission publishes a draft, adopts an act or updates its implementation page. When an act enters into force, replace the formula with a date. Keep proposals out of the obligation rows until they are adopted. Two were pending on 14 October 2026. Proposal COM(2025) 982 would suspend the duty in Article 45(3) to appoint an EPR authorised representative until 1 January 2035. Proposal COM(2026) 590 would delete the green public procurement article, Article 63.