Your PPWR brief · 13 August 2026
11 duties apply to you today
You hold four roles under PPWR. Roles stack, so each one carries its own duties. In all, your brief holds 25 duties: 11 apply now, 12 apply later, and 2 are set nationally.
- Your role
- Own-brand manufacturerEPR producerDistance sellerFiller or packer
- Your packaging
- Sales packagingE-commerce packagingBeverage container in a deposit and return system
- Your material
- PlasticPaper and board
Your brief at a glance
- 11
- Apply now
- 12
- Apply later
- 2
- Set nationally
Next date
Not before 12 August 2028
Harmonised packaging labelling
Guidance, not legal advice. Read back against the Official Journal on 13 August 2026.
Take it with you
The whole brief in your inbox, with a link back to this page.
01
Role by role, starting with today
Each duty shows what to do, what to keep and the article it comes from, and every article opens the words behind it.
Own-brand manufacturer
7 duties · 3 apply now · 4 apply later
Somebody else may make the packaging, but it carries your name or trademark, so the Regulation treats you as the manufacturer.
Defined atArticle 3(1), point (13)Article 15(1)Article 15(12)
Today
Applies nowAccept that the brand on the pack carries the manufacturer dutiesDetail
Where packaging or a packaged product is designed or manufactured under your name or trademark, you are the manufacturer, even when another trademark also appears on the pack. Contract the Annex VII assessment from your converter if you wish, but hold the responsibility and the file yourself and draw up the EU declaration of conformity yourself or through an authorised representative under a written mandate. The one carve-out is where you are a micro-enterprise and the supplier of your packaging is in the same member state: that supplier is then the manufacturer.
Evidence to keep
Supply agreements that name who runs the conformity assessment, plus your own copy of the technical documentation and the EU declaration of conformity.
CitedArticle 3(1), point (13)Article 15(1)Article 15(2)Article 17
Applies nowPlace only recyclable packaging on the marketDetail
All packaging you place on the market must be recyclable, and that duty applies from 12 August 2026. Recyclable means designed for material recycling and, when it becomes waste, separately collectable, sortable without harming other streams, and recycled at scale. Until the design-for-recycling criteria apply, the Commission reads the duty against the Directive 94/62/EC requirements and standard EN 13430:2004. Article 6(2), point (a), then applies from 1 January 2030 or 24 months after the delegated acts enter into force, and point (b), including recycled at scale, from 1 January 2035.
Evidence to keep
A recyclability position per packaging unit against EN 13430:2004 for now, and the collection and sorting streams it is designed for. You do not need the Article 38 and Annex VII conformity assessment for recyclability until the Article 6(4) delegated acts enter into force.
Applies nowOnly claim what beats the legal minimumDetail
Make environmental claims about packaging properties this Regulation already governs only where the property exceeds the applicable minimum requirement, measured by the Regulation's own criteria and calculation rules. Say whether the claim covers the unit, part of the unit, or all your packaging. Do not use labels or symbols likely to mislead about sustainability or waste management.
Evidence to keep
The calculation behind each claim, the minimum it is measured against, the stated scope of the claim, and the demonstration in the Annex VII documentation.
Ahead of you
Waits on an EU actNot before 12 August 2028Carry the harmonised material-composition labelDetail
Mark packaging with the harmonised pictogram label showing material composition so consumers can sort it. Transport packaging is out of scope, but e-commerce packaging is not, and packaging in a deposit and return system needs a clear deposit label instead. Reusable packaging additionally needs a reuse label and a digital data carrier from 12 February 2029, or 30 months after the Article 12(6) implementing act enters into force, whichever is later.
Evidence to keep
Artwork per format against the harmonised specification, the language versions required by each destination market, and any digital data-carrier content.
What still moves this date
Harmonised label implementing acts under Article 12(6) and Article 12(7), due by 12 August 2026. The duty starts 24 months after they enter into force if that is later.
Applies laterFrom 1 January 2030Do not use features that only make the pack look biggerDetail
From 1 January 2030, do not place packaging with double walls, false bottoms or unnecessary layers whose purpose is to increase the perceived volume of the product, or packaging that fails the Annex IV performance criteria. Until 31 December 2029 the Directive 94/62/EC minimisation requirements and standard EN 13428:2004 continue to govern. Narrow exceptions exist for designs and shape trademarks protected before 11 February 2025 and for products under a protected geographical indication or quality scheme.
Evidence to keep
A technical justification for each wall, layer and void, and registration evidence where you rely on a protected design, trademark or geographical indication.
CitedArticle 10(2)Article 10(4)Article 70(1), point (b)Annex IVAnnex VII
Applies laterFrom 1 January 2030Reduce weight and volume to the minimum the pack needsDetail
By 1 January 2030, design packaging so its weight and volume are the minimum needed for functionality, allowing for its shape and material. For reusable packaging, weigh this against the Article 11 reuse requirements first.
Evidence to keep
The Annex IV performance-criteria assessment, the design constraints that stop further reduction, and any tests, studies, modelling or simulation behind the minimum.
Waits on an EU actNot before 1 January 2030Build recycled content into every plastic partDetail
Plan for the minimum recycled content in each plastic part of your packaging, averaged per manufacturing plant and year: 30% for contact-sensitive PET, 10% for other contact-sensitive plastics, 30% for single-use plastic beverage bottles, and 35% for other plastic packaging. Content must be post-consumer waste collected and recycled under the Article 7(3) conditions.
Evidence to keep
Mass-balance or equivalent records per plant and year, supplier certificates for post-consumer feedstock, and the demonstration in the Annex VII technical information.
What still moves this date
Calculation and verification methodology implementing act under Article 7(8), due by 31 December 2026. The duty starts three years after that act enters into force if that is later.
CitedArticle 7(1)Article 7(3)Article 7(6)Article 7(11)Annex VII
EPR producer
9 duties · 6 apply now · 1 apply later · 2 set nationally
You are the first to make packaging or a packaged product available on the territory of a member state, so extended producer responsibility sits with you.
Today
Applies nowRegister before you first supply in a member stateDetail
Register in the national producer register of every member state where you first make packaging or packaged products available, or where you unpack packaged products without being an end user. Do not make packaging available before that registration exists. The application carries the Part A of Annex IX information, and the competent authority grants the registration and a registration number within a maximum of twelve weeks from the moment all the required information is provided. Where you have entrusted a producer responsibility organisation with your extended producer responsibility obligations, that organisation meets this duty for you unless the member state says otherwise. Each member state has 18 months from the entry into force of the first Article 44(14) implementing act to establish its register, so check the state of the national register in each market you supply.
Evidence to keep
Registration numbers per member state, the Part A of Annex IX submissions behind them, and the notification route for changes.
CitedArticle 3(1), point (15)Article 44(1)Article 44(2)Article 44(4)Article 44(5)Article 44(11)Annex IX
Applies nowReport packaging volumes by 1 June each yearDetail
Submit the Part B, point 1, of Annex IX information to the competent authority responsible for the register by 1 June for each full preceding calendar year. Producers who made available less than 10 tonnes in a calendar year, and producers under Article 3(1), point (15)(e) who unpack less than 10 tonnes, submit the reduced Part B, point 2, set instead, though a member state may set a lower threshold for a given year. A member state may require the data to be audited and certified by independent auditors. Notify the authority without undue delay of any change to the registered information or of permanent cessation.
Evidence to keep
Tonnage by packaging type and material category, the reconciliation behind it, and audit or certification where the member state requires it. The first full calendar year under the Regulation is 2027, so the first return falls due on 1 June 2028.
CitedArticle 3(1), point (15)(e)Article 44(7)Article 44(8)Article 44(12)Annex IX
Applies nowAppoint an EPR representative where you sell across a borderDetail
Where you supply end users directly in a member state other than the one you are established in, appoint an authorised representative for extended producer responsibility there by written mandate. Member states may also require this of producers established in third countries.
Evidence to keep
A written mandate per member state, the representative's registration entry, and the list of producers they represent.
CitedArticle 45(3)Article 3(1), point (20)Article 44(3)Article 44(6)
Applies nowPay the extended producer responsibility contributionsDetail
Pay the extended producer responsibility contributions for the packaging you first make available on the territory of a member state, and for packaging you unpack without being the end user. Beyond the waste-management costs in Article 8a(4), point (a), of Directive 2008/98/EC, your contributions also cover the cost of labelling waste receptacles under Article 13 and the cost of compositional surveys of collected mixed municipal waste. The costs covered are set in a transparent, proportional, non-discriminatory and efficient way.
Evidence to keep
Fee statements per member state mapped to the packaging you first made available, and the tonnage reconciliation behind each declaration.
Applies nowHand your registration evidence to platforms and fulfilment providersDetail
Providers of online platforms must obtain two things from you before they let you use their services: your Article 44 registration details and registration number or numbers for the member state where the consumer is, and a self-certification that you only offer packaging meeting the extended producer responsibility requirements in that member state. The duty to obtain sits on the platform, so hold both items ready for every market you sell into. Your own direct duty runs to fulfilment service providers: give them the same two items at the moment you conclude the contract. You are responsible for the accuracy of that information, and a fulfilment service provider must suspend its service to you if you do not correct information it finds inaccurate, incomplete or out of date.
Evidence to keep
The self-certification text, registration numbers per member state, and a record of what was supplied to each platform and fulfilment partner.
Applies nowTell end users how to prevent and sort packaging wasteDetail
Make information available to end users about waste prevention, the re-use arrangements available for your packaging, their part in separate collection including packaging that held hazardous products, the effect of littering and improper disposal, and the composting properties of compostable packaging together with the warning that it is not suitable for home composting. Keep it current and deliver it through a website or other electronic means, public information, education programmes and campaigns, or signposting in a language end users understand. The duty to explain what the labels and symbols mean applies later: from 12 August 2028 or from the date of application of the relevant provision of Article 12, whichever is the latest. Where a producer responsibility organisation carries your extended producer responsibility obligations, it does this for you.
Evidence to keep
The published information set, the channel it is published on, and the review date that keeps it current.
CitedArticle 55(1)Article 55(1), point (d)Article 55(2)Article 46(1)Article 12
Waiting on your member state
Set nationallyFrom 1 January 2029Plan for deposit and return on beverage containersDetail
Article 50 addresses member states, not you. By 1 January 2029 each member state must ensure separate collection of at least 90% by weight of single-use plastic beverage bottles and single-use metal beverage containers up to three litres made available on its territory, and must ensure deposit and return systems are set up for those formats with a deposit charged at the point of sale. Your operator-facing duties follow from the national scheme: participate in it, and mark packaging subject to a deposit and return system with a clear and unambiguous label under Article 12(1). Packaging for wine and aromatised wine products, similar fermented beverages, spirits and milk products is outside the mandatory deposit and return requirement in Article 50(2), but still counts toward the Article 50(1) collection target. A member state that separately collected 80% or more of the format in calendar year 2026 can seek an exemption from setting up a system if it notifies the Commission and submits an implementation plan by 1 January 2028.
Evidence to keep
Per-market deposit scheme registration, barcode and deposit-label artwork, and the volumes reported into each scheme.
What still moves this date
National deposit and return system design, exemptions under Article 50(5), and any national extension under Article 50(9).
CitedArticle 50(1)Article 50(2)Article 50(4)Article 50(5)Article 50(11)Article 12(1)Annex X
Set nationallyTreat registration and fees as a separate check in each marketDetail
The Regulation sets the frame, but each member state runs its own register, authorisation and fee mechanics, and may add information requirements, quarterly reporting, lower reporting thresholds or mandatory membership of a producer responsibility organisation. Run a country-by-country check for every market you supply. This tool does not compute national EPR outcomes.
Evidence to keep
A market-by-market register of scheme operator, registration status, fee basis, reporting frequency and national deadlines.
What still moves this date
National register, authorisation and fee rules in each member state where you place packaging.
CitedArticle 44(1)Article 44(9)Article 44(11)Article 46(1)Article 47(1)
Ahead of you
Waits on an EU actExpect fees to move with recyclability performanceDetail
Contributions become modulated by recyclability performance grade 18 months after both the Article 6(4) delegated acts and the Article 6(5) implementing acts enter into force. Member states may also modulate by the share of recycled content, but they are not obliged to. Neither modulation changes what you owe today; it changes how the bill is split between well-designed and poorly designed packaging.
Evidence to keep
Fee statements mapped to packaging categories and grades, and the recyclability assessment that determines the modulation band.
What still moves this date
Modulation starts 18 months after both the Article 6(4) delegated acts and the Article 6(5) implementing acts enter into force. Modulation by recycled content under Article 7(7) is optional for member states.
Distance seller
5 duties · 2 apply now · 3 apply later
You sell online or through other distance contracts, which changes where you register and how information must reach the buyer.
Defined atArticle 3(1), point (14)Article 3(1), point (15)Article 12(5)
Today
Applies nowRegister where your customers are, not only where you areDetail
Selling directly to end users in another member state makes you a producer there. Register in that member state's producer register before you supply, whether you are established in the Union or in a third country.
Evidence to keep
A market list showing every member state you ship to, with registration status and registration number for each.
CitedArticle 3(1), point (15)(c)Article 3(1), point (15)(d)Article 44(2)Article 44(4)
Applies nowAppoint an EPR representative in each destination marketDetail
Appoint an authorised representative for extended producer responsibility, by written mandate, in each member state where you first make packaging or packaged products available and where you are not established. If you are established in a third country, this appointment applies where the destination member state requires it, so check each market. Entrusting a producer responsibility organisation with your extended producer responsibility obligations under Article 46(1) is a separate arrangement and does not replace this appointment.
Evidence to keep
Signed mandates per member state and the representative's confirmation of registration on your behalf.
Ahead of you
Waits on an EU actNot before 12 August 2028Show the label information online, before the customer buysDetail
The information carried by the harmonised sorting label, the reusable-packaging label and any digital data carrier must also be available to end users before purchase in online sales, in one or more languages easily understood by end users as determined by the destination member state. Where the information is given electronically, collect only the personal data needed to give access, and do not mix it with sales or marketing content.
Evidence to keep
Product page templates showing the label information, the language mapping per market, and the data-minimisation position for any digital carrier.
What still moves this date
Harmonised label implementing acts under Article 12(6) and the material-composition methodology act under Article 12(7), both due by 12 August 2026. The Article 12(1) and 12(4) labels start 24 months after the latest of those acts enters into force if that is later; the reusable-packaging label under Article 12(2) starts 12 February 2029 or 30 months after the Article 12(6) act.
Waits on an EU actNot before 1 January 2030Keep the shipping box no more than half emptyDetail
Where you fill e-commerce, transport or grouped packaging, keep the empty space ratio at or below 50%. Filling materials such as paper cuttings, air cushions, bubble wrap, foam or loose fill count as empty space. Using the sales packaging itself as the shipping pack, or reusable packaging inside a re-use system, exempts you from the ratio but not from the Article 10 minimisation duty.
Evidence to keep
Per-carton volume calculations against the packed sales units, the box-size selection rule, and the fill-material policy behind it.
What still moves this date
Empty-space calculation methodology implementing act under Article 24(2), due by 12 February 2028. The duty starts three years after that act enters into force if that is later.
CitedArticle 24(1)Article 24(2)Article 24(3)Article 24(5)Article 10
Filler or packer
4 duties · 4 apply later
You put product into packaging, so the empty-space, re-use and format-restriction duties land on you.
Defined atArticle 24Article 26Article 29
Ahead of you
Applies laterFrom 12 February 2028Cut empty space in sales packaging to what the product needsDetail
By 12 February 2028, keep empty space in sales packaging to the minimum needed for functionality and product protection. Filling materials count as empty space. Where the product settles in transit, or a food product needs headspace, compliance is judged at the pack-fill level at the time of filling, and air or protective gases between or within the food do not count as empty space.
Evidence to keep
Fill-level records at the time of filling, internal pack volume against product volume, and the technical justification for necessary headspace.
Applies laterFrom 1 January 2030Meet the reusable transport and grouped packaging sharesDetail
From 1 January 2030, at least 40% of the listed transport formats you use inside the Union must be reusable within a re-use system, and at least 10% of grouped packaging in the form of boxes other than cardboard. Transport packaging moved between your own sites, or between you and a linked or partner enterprise, and transport packaging delivered to another operator inside the same member state, must be reusable outright.
Evidence to keep
The Article 30 calculation of equivalent units per target, kept for each calendar year.
CitedArticle 29(1)Article 29(2)Article 29(3)Article 29(5)Article 30(1)
Applies laterFrom 1 January 2030Drop the packaging formats that become prohibitedDetail
From 1 January 2030, do not place packaging in the formats and for the uses listed in Annex V. Check your range against Annex V now, because reformulating a format takes longer than the notice period suggests. The bans in points 1 to 4 are not limited to all-plastic items: Commission guidance treats composite packaging, including paper-based packaging containing 5% or more plastic, as caught, while packaging with no more than 5% plastic is not. Member states may allow micro-enterprises a narrow derogation for point 3 of Annex V where it is not technically feasible to avoid the packaging or to access the infrastructure a re-use system needs.
Evidence to keep
A format-by-format screen against Annex V, with a replacement plan and date for each affected line.
Waits on an EU actNot before 1 January 2030Hold the 50% empty-space ratio in outer packagingDetail
Where you fill grouped, transport or e-commerce packaging, keep the empty space ratio at or below 50%. Empty space is the difference between the total volume of the outer packaging and the volume of the sales packaging inside it; the ratio is that empty space divided by the total outer volume. Filling materials count as empty space. Reusable packaging inside a re-use system, and sales packaging used as the shipping pack, are exempt from the ratio.
Evidence to keep
Volume calculations per outer format, the pack-size decision rule, and the exemption basis where you rely on one.
What still moves this date
Empty-space calculation methodology implementing act under Article 24(2), due by 12 February 2028. The duty starts three years after that act enters into force if that is later.
02Your timeline
The dates behind these duties
Every date below is one your brief cites. Where a deadline still waits on a Commission act or a national scheme, the entry says what moves it.
12 August 2026Applies now
PPWR applies
Regulation (EU) 2025/40 applies across the Union. Conformity assessment, technical documentation, the substance limits, economic operator duties and extended producer responsibility all start here, along with the standing duty that packaging placed on the market is recyclable.
The measurable recyclability criteria behind Article 6(1) arrive later: design for recycling from 1 January 2030 and recycled at scale from 1 January 2035. Producer registration under Article 44(2) also waits on national registers, which member states establish within 18 months of the first Article 44(14) implementing act.
12 August 2028Applies later
Harmonised packaging labelling
Packaging placed on the market carries the harmonised material-composition label so consumers can sort it. Waste receptacles carry the matching harmonised labels. Transport packaging is out of scope, but e-commerce packaging is not.
Starts 24 months after the Article 12(6) and 12(7) implementing acts enter into force if that is later than 12 August 2028. Receptacle labelling under Article 13(1) is a member state duty and starts 30 months after the separate Article 13(2) implementing acts are adopted if that is later. Non-compliant stock made or imported before the deadline can be made available for three years from the entry into force of the labelling requirements.
1 January 2029Applies later
Beverage deposit and return systems
Member states must separately collect at least 90% by weight of single-use plastic beverage bottles and single-use metal beverage containers up to three litres, and must run deposit and return systems charging a deposit at the point of sale.
Article 50 addresses member states, not producers directly. Wine, aromatised wine, spirits and milk products are excluded from the deposit duty in Article 50(2) but not from the 90% separate-collection target in Article 50(1). HORECA on-premises consumption can be exempted from charging a deposit, and a member state already separately collecting 80% or more in 2026 can request exemption by 1 January 2028.
12 February 2029Applies later
Reusable packaging labelling
Reusable packaging carries a label telling users it is reusable, plus a QR code or other standardised open data carrier that supports tracking of trips and rotations.
Starts 30 months after the Article 12(6) implementing act enters into force if that is later. Open-loop systems with no system operator are exempt from the label and carrier.
1 January 2030Applies later
Recyclability grades and the 50% empty-space limit
Packaging must reach recyclability performance grade A, B or C, minimum recycled content applies to plastic parts, packaging must be minimised in weight and volume, grouped, transport and e-commerce packaging must stay at or below a 50% empty space ratio, the Annex V format restrictions bite, and the reusable transport packaging shares start.
Recyclability grades start 24 months after the Article 6(4) delegated acts if that is later. Recycled content starts three years after the Article 7(8) implementing act if that is later. The empty-space ratio starts three years after the Article 24(2) implementing act if that is later. Packaging minimisation, the Annex V restrictions and the reuse shares carry no act dependency.
03Where this brief stops
What this brief cannot tell you
The Regulation sets the frame. Each member state then sets its own mechanics, and those keep moving, so four things in your brief have a national answer this tool cannot compute: the producer register you sign up to, and what it asks for; the fees you pay and how they are modulated; the deposit and return scheme your beverage containers join; and the authorisation route for an authorised representative in a market you do not sit in.
Two duties in your brief wait on a national scheme:
21 areas this brief does not coverDetail
National registration mechanics, fee schedules and producer responsibility organisation contracts vary by member state and are flagged rather than computed.
The compostability rules for beverage bags, single-serve units and fruit stickers need their own material model and are out of scope for the first ruleset.
Labelling waste receptacles is a member state duty; producers meet it through extended producer responsibility costs, not through their own artwork.
Take-away refill and re-use offer duties apply to the HORECA sector specifically and need a sector question the flow does not yet ask.
Re-use targets for beverage formats and their reporting sit outside the transport and grouped packaging shares this ruleset covers.
Lightweight plastic carrier bag reduction is set as a member state consumption target, not as an operator obligation.
Biobased plastic feedstock carries a Commission review and a possible future proposal, not a current duty.
The five-year derogation for innovative packaging needs a notification workflow and a competent-authority decision the tool cannot model.
Optional national symbols for extended producer responsibility schemes and for non-Article 50 deposit systems are permissive and member-state specific.
Per-capita waste prevention targets are member state obligations, reached through national measures rather than through operator duties.
Collection systems, mandatory collection objectives and recycling targets are addressed to member states.
Annual reporting by packaging waste management operators is a separate duty for a role the Navigator does not qualify.
Risk procedures, safeguard procedures and controls on packaging entering the Union describe what authorities do, not what an operator must prepare.
Green public procurement requirements depend on future criteria and apply to contracting authorities.
Penalties are laid down by each member state, so the exposure is national and not computable at Union level.
Whole product classes drop out of specific duties: medicinal products, medical devices, in vitro diagnostics, infant formula and food for special medical purposes, and dangerous goods. The flow does not ask what is inside the pack, so it applies the general rule and leaves the carve-out to you.
Article 6(11)Article 7(4)Article 7(5)Article 12(11)Article 15(11)
Open loop re-use systems with no system operator are exempt from the reusable-packaging label and the digital data carrier, which needs a system-shape question the flow does not ask.
Producer registration applies from 12 August 2026, but member states have 18 months from the first Article 44(14) implementing act to establish their register, so a register may not exist until around mid-2027. The duty applies regardless, and the Navigator does not track which registers are open.
No provision of the Regulation imposes a duty on end users, so the end-user role carries orientation and the two ways out of end-user status rather than a duty set. That is the honest answer, not a missing section.
The duty to demonstrate achievement of the re-use targets applies from 1 January 2030 or 18 months after the Article 30(3) methodology act, whichever is later, so the evidence date can move even though the target date cannot.
Transitional handling of packaging placed under Directive 94/62/EC needs a placed-on-market date the flow does not collect.
Keep it current
This brief is true today. PPWR will not stay still.
Implementing acts, delegated acts and twenty-seven national schemes all move the dates above. Foresight tracks them against your products and your markets, and tells you when something you rely on changes.