EU-wide shake-up for packaging: new producer definition & expanded registration duties under the PPWR
The Packaging and Packaging Waste Regulation (PPWR) (EU) 2025/40 is directly applicable across the EU and will largely replace the former EU Packaging Directive as it applies from 12 August 2026 onwards. The PPWR aims to increase recycling and reuse rates, tighten evidentiary requirements and harmonise data reporting across Member States. Key changes include, among others:
Producer definition: The concept of “producer” is broadened and will be assessed by reference to an actor’s function in the market — for example, any party placing packaging or filled products on the market under its own name or brand.
Registration obligations & national registers: The Regulation creates harmonised, EU-wide requirements for registration and reporting. In several Member States, registration will become mandatory for producers for the first time. Producers without establishment in a given Member State will be required to appoint an authorised representative.
How Member States are responding
Germany — PPWR implemented alongside the national Packaging Act
Germany will implement the PPWR within the framework that has been set by the Packaging Act (VerpackG). The (draft) new Packaging Act (VerpackDG) that is to replace the VerpackG by 12 August 2026 is expected to set out implementing details such as sanctions and scheme authorisations.
Core impact: Companies that place packaging or packaged products on the German market “under their own name/brand” will typically be treated as producers and therefore subject to registration and reporting duties.
Netherlands — de-minimis threshold likely to be removed
Until now, operators placing less than 50 tonnes of packaging per year on the Dutch market were exempt from registration. Under the PPWR that de-minimis threshold is expected to disappear, bringing many additional businesses within the scope of producer obligations.
Similar removals of de-minimis thresholds are anticipated in Belgium and the Czech Republic.
France — commercial packaging registration from 1 July 2026
Exemptions for commercial (B2B) packaging will lapse before 12 August 2026. From 1 July 2026 commercial packaging will, in many cases, become subject to registration.
Practical implications for businesses — quick checklist
Clarify roles: Verify whether your organisation qualifies as a producer, manufacturer or importer and identify the obligations that follow.
Register early: Complete registrations well before 12 August 2026 to ensure compliance and avoid last-minute capacity constraints.
Set up reporting processes: Adapt internal reporting to produce reliable submission data.
Watch national specifics: Check for additional national requirements (e.g., labelling or reporting) in jurisdictions such as France, Italy and Spain.
How we can help
With experience supporting more than 3,000 clients, Bitkom Compliance Solutions will guide you through registration processes in EU Member States, Norway, Switzerland and the United Kingdom. As your full-service partner we handle communications with national registers, producer responsibility organisations (PROs) and authorised representatives — taking the administrative burden off your team.
Workshops & training
We also run targeted support formats to help you and your team prepare for the PPWR:
