EU Packaging Regulation (PPWR): Registration and Data Reporting
Part 1: What needs to be done now
The new EU Packaging Regulation (PPWR) introduces uniform obligations from August 2026 for all companies placing packaging on the EU market. Key innovations include mandatory registration in national packaging registers and annual data reporting of packaging quantities. Companies must assess early in which countries they are subject to registration, clearly define responsibilities, and adapt internal processes and IT systems to meet the new requirements on time and correctly. Careful preparation minimizes risks and ensures compliance with the new EU-wide regulations.
Registration Obligation
Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) introduces EU-wide uniform obligations from 12 August 2026 for all companies placing packaging on the market. One of the key innovations is the registration obligation in official producer registers of each EU Member State. In future, every company (“producer” within the meaning of the regulation) that places packaging or packaged products on the market for the first time in a country must register in the respective national packaging register. This applies uniformly to all packaging materials and industries. Companies without their own establishment in the country concerned must appoint an authorized representative there to fulfill Extended Producer Responsibility (EPR). Without registration, no packaging may be placed on the market – the regulation prohibits placing on the market as long as there is no valid registration (or representative appointment) in the respective national register. Companies should therefore assess in good time in which countries they are subject to registration and prepare for initial registration as soon as the national registers are established (by 2027 at the latest).
Annual Data Reporting Obligation
In parallel, the PPWR introduces an annual data reporting obligation. In future, producers must report annually by 1 June the quantities of all packaging they placed on the market for the first time in each EU country in the previous year. This quantity reporting is submitted to the competent authority or producer register and records weight data by packaging type and material per country. The plan is for data to be transmitted electronically and uniformly wherever possible. Small placers on the market with very low packaging quantities (below 10 tonnes/year per country) benefit from simplifications: Member States may allow them to submit simplified reporting by overarching packaging types instead of detailed material categories. Regardless of such exemptions, however, all affected parties are well advised to establish a system for recording their packaging quantities early on, in order to report on time and correctly. Incorrect or missed quantity reports can – as already known from existing national systems – lead to sanctions, so care is required.
Establish Clear Responsibilities
In conclusion: Companies in the packaging industry and food packers should prepare in an organized manner for the new obligations starting now. Most requirements only come into force in 2026, but the groundwork must be laid now. Clear responsibilities within the company must be defined – who takes care of registration in which countries and annual data collection? – and existing processes must be adapted. Be aware of what role your company plays under the PPWR (e.g. manufacturer/producer, importer or distributor) and what responsibility is associated with it. Organize internal processes and IT systems so that all required information is available in time (e.g. packaging weights by material, sales country, registration numbers). Early preparation ensures that you are compliant when the PPWR comes into application on 12 August 2026 and can fulfill registration and data reporting smoothly. This minimizes risks and gives you planning certainty during the transition period to the new EU-wide packaging regulations.
