Regulation (EU) 2025/40 on Packaging and Packaging Waste (PPWR) entered into force on February 11, 2025. It is directly applicable EU law, so no national transposition is required. Every business that places packaged goods on the EU market, including importers and online marketplaces, must comply from August 12, 2026. It covers all packaging: primary, secondary, and tertiary.

When does the PPWR apply?

The PPWR is directly applicable from August 12, 2026 across all 27 EU member states. On that date the Declaration of Conformity obligation, PFAS limits, and EPR registration and fee obligations apply.

What is the PPWR PFAS threshold for food-contact packaging?

PFAS are banned from food-contact packaging from August 12, 2026 at concentrations exceeding three limits set in Article 5(5): 25 ppb for any individual PFAS by targeted analysis, 250 ppb for the sum of PFAS, both excluding polymeric PFAS, and 50 ppm for total PFAS including polymeric PFAS. Above 50 mg/kg total fluorine, suppliers must evidence on request how much of that fluorine is PFAS.

Which EU countries have deposit return systems?

Germany and the Netherlands operate active deposit return systems. France and Italy are developing them. Spain's own deposit return mandate (RD 1055/2022) carries a November 2026 statutory deadline, but operator authorization has stalled and launch is widely expected to slip; the binding EU backstop is the PPWR Article 50 mandate of January 1, 2029. Deposit amounts and scope vary by country.

How much are packaging EPR fees in the EU by country?

Packaging EPR fees are set nationally and vary widely by material. PPWR Atlas carries published 2025/2026 base rates for 14 EU countries from national PRO schedules such as Verpact (Netherlands), CITEO (France), CONAI (Italy), ARA (Austria), Repak (Ireland), Fost Plus (Belgium), and Ecoembes/Envalora (Spain). Germany is quote-based with no published table. These are planning figures, not compliance reporting numbers; verify current tariffs with each national PRO.

What is the PPWR empty space limit for e-commerce and transport packaging?

From January 1, 2030, or 3 years after the Article 24(2) implementing acts enter into force, whichever is the latest, grouped, transport, and e-commerce packaging may not exceed a 50 percent empty-space ratio under Article 24. The methodology act is due by February 12, 2028 and has not been adopted, so the 2030 date is a floor, not a fixed date. The figure is 50 percent, not the 40 percent that circulated in earlier drafts. A general packaging minimization duty applies from August 12, 2026.

What are the PPWR recycled content targets for plastic packaging?

From January 1, 2030, or 3 years after the Article 7(8) implementing act enters into force, whichever is the latest, under Article 7(1): 30 percent for contact-sensitive PET, 10 percent for other contact-sensitive plastic, 30 percent for single-use plastic beverage bottles, and 35 percent for other plastic packaging. A second tier applies from January 1, 2040 at 50, 25, 65, and 65 percent. Only post-consumer recycled content counts; the calculation methodology is pending a delegated act.

⚠️

PPWR is directly applicable from August 12, 2026. No national transposition required. The Declaration of Conformity obligation, PFAS limits, and EPR registration and fee obligations apply on that date across all 27 EU member states. Grade-based eco-modulation of EPR fees is mandatory under Art. 6(4)/45(1) but binds later, about mid-2029 (18 months after the design-for-recycling act, due Jan 1, 2028). 9 delegated acts remain pending; key technical thresholds are still being finalized.

EU Member States

Aug 12

2026 Enforcement Date

Delegated Acts Pending

Art. 6(4)

Eco-Modulation Mandatory

📰 Latest developments

All updates →

Jul 29, 2026

Three August 12 points that are easy to miss. Recyclability under Article 6(1) applies from August 12, not 2030. Packaging already placed on the market may stay there and does not need withdrawal. And Directive 94/62/EC is only partly repealed, with parts running to 2028 and 2029. Detail and citations on the Prepare for PPWR tab.

Jul 21, 2026

A fourth corrigendum to the PPWR, and again it is language only. The Official Journal published a Spanish-language correction to Regulation (EU) 2025/40 on July 21, 2026, aligning recitals 130 and 131, Article 3(1)(66) and Article 47(1) with the other language versions. The English operative text is unchanged. Every corrigendum issued so far corrects a single language version, not the substance.

Jul 17, 2026

Germany's VerpackDG is law. Germany published its Packaging Law Implementation Act (VerpackDG) in the Federal Law Gazette (BGBl I 2026 Nr. 207), adapting national law to Regulation (EU) 2025/40 and replacing the old VerpackG; it takes effect August 12, 2026 alongside the PPWR.

Jun 30, 2026

France sets a 2029 deposit deadline. France's ecology minister told the plastics plan consultation that a deposit for recycling will be mandatory from January 1, 2029. Local authority associations and NGOs walked out of the session, and the Senate committee opposed the measure on May 19.

What is the PPWR?

Q: What are recyclability grades A, B, and C?

PPWR Annex II grades packaging recyclability by weight. Grade A means 95 percent or more recyclable, Grade B means 80 percent or more, and Grade C means 70 percent or more. Below 70 percent is non-recyclable and cannot be placed on the EU market from January 1, 2030. Exact per-material criteria are pending the design-for-recycling delegated act (ACT-02).

A plain-language primer on Regulation (EU) 2025/40

Regulation (EU) 2025/40 on Packaging and Packaging Waste (PPWR) entered into force on February 11, 2025. It is directly applicable EU law, no national transposition law is needed. The Commission's official interpretive guidance was published in the Official Journal on June 10, 2026 as Commission Notice C/2026/3084. Every business that places packaged goods on the EU market, including importers and online marketplaces, must comply from August 12, 2026. The regulation covers all packaging: primary (consumer-facing), secondary (transit), and tertiary (industrial/transport).

🎯 Core Goals

Reduce packaging weight and complexity (minimization rules)
Make all packaging recyclable or reusable by 2030
Mandate post-consumer recycled (PCR) content targets by 2030
Harmonize EPR fees across all 27 member states via eco-modulation
Mandate DRS for beverage containers by 2029
Eliminate PFAS from food-contact packaging (from Aug 12, 2026)

📋 Who Must Comply

Brand owners / manufacturers, primary obligation holders
Importers, treated as producers if no EU manufacturer
Online marketplaces, backstop registrant for non-EU sellers
Packaging suppliers / converters, technical information duties
Distributors, labeling compliance and pass-through obligations

🧭 Where to Start

Prepare for PPWR, the step-by-step actions by role and packaging type
Format Risk Screener, flag formats likely to miss the recyclability grade
Fee Estimator, size your EU EPR fee exposure
Delegated Acts Tracker, what is still pending and when it lands

The changes are coming in waves

Milestone that reshapes the market Phased obligation or Commission deadline

12 Aug 2026Now

General applicationEnforcement

PFAS banned in food-contact packaging; EU Declaration of Conformity required; producer identification and marking; EPR registration in every market; suppliers must provide accurate material data (Art. 16). No grace period for packaging placed after this date.

12 Feb 20272027

Refill in hospitality

HORECA must let consumers bring their own container and must offer a refill option.

1 Jan 20282028

Recyclability rules get defined

Deadline for the Commission to set the design-for-recyclability grades (A, B, C). The criteria you must design against become concrete. This is the critical path for the 2030 wall.

12 Feb 20282028

Compostability mandates

Tea and coffee bags, single-serve pods, produce stickers, and ultra-light carrier bags must be industrially compostable.

12 Aug 20282028

Labeling reset

A harmonized EU sorting label replaces national marks, the Digital Product Passport begins for in-scope packaging, and standalone marks such as the Green Dot are restricted. Expect a pan-EU artwork change.

1 Jan 20292029

Deposit return systems live

Every member state must operate a deposit return system for single-use plastic beverage bottles and metal beverage containers up to three litres, and hit 90% separate collection (Art. 50).

12 Feb 20292029

Reuse marking

Reusable packaging carries the QR marking that identifies it as part of a re-use system.

~ mid 20292029

Fees start to follow grade

Eco-modulated EPR fees keyed to recyclability grade begin to bite (about 18 months after the design-for-recyclability act). A low-grade format now costs more every year.

1 Jan 20302030

The design wallRedesign by here

Grades A, B, or C become mandatory (below C is off the EU market); minimum recycled content in plastic; a 50% empty-space cap; single-use format bans; and reuse targets all take effect together.

1 Jan 20352035

Recyclable at scale

The tougher "recyclable at scale" test replaces the 2030 design test.

1 Jan 20382038

Top grades only

Only grades A and B may be placed on the market; grade C is phased out.

1 Jan 20402040

Higher targets

Recycled-content minimums and reuse targets step up again.

Key terms, including Producer, Declaration of Conformity, eco-modulation, recyclability grades, PCR content, and PFAS, are defined on the Glossary tab.

ℹ️ About This Hub

This hub is provided for informational purposes only and does not constitute legal, regulatory, or compliance advice. The EU Packaging and Packaging Waste Regulation is still being operationalized: deadlines, thresholds, fee rates, and exemptions change as the delegated and implementing acts are finalized. Verify all information against the primary sources, including Regulation (EU) 2025/40 on EUR-Lex, the European Commission's official PPWR guidance, the delegated and implementing acts as they are adopted, and the national EPR scheme (PRO) in each market where you sell, or with qualified legal counsel before taking compliance action.

PPWR Atlas is built and maintained by Dave Hartter, a packaging and product sustainability advisor with more than 20 years at global manufacturers, most recently as Director of Sustainability at Huber Engineered Materials and Newell Brands. He combines technical rigor with commercial logic, connecting regulation and customer requirements to real product and packaging decisions.

He now advises CPG brands and packaging suppliers on EU packaging compliance under the PPWR: where the fees land, how design and material choices change them, and how to turn early compliance into risk mitigation and a product advantage that future-proofs the portfolio. PPWR Atlas is the public version of that work, updated weekly from primary sources.

For advisory engagements or corrections, reach Dave at info@hartteradvisory.com. More about the author and advisory services →

Prepare for PPWR

PPWR at a glance

If your company puts packaging or packaged products on the EU market, PPWR applies wherever the company is based. The regulation is already in force and phases in through 2040, and the most expensive decisions are the design choices being made now, because product cycles run 18 to 36 months and the formats you sell in 2030 are being chosen today.

Deadline

The first hard date is 12 August 2026, when PFAS is banned in food-contact packaging and a Declaration of Conformity, producer marking, and EPR registration become mandatory in every market you sell into, with no grace period for new packaging.

The wall

The design wall arrives on 1 January 2030, when recyclability grades, recycled-content minimums, a 50% empty-space cap, and reuse targets all take effect together. Grade C and the empty-space cap each carry a "whichever is later" clause tied to their delegated acts, so 2030 is the earliest date, not a guaranteed one.

Cost

From about mid-2029, EPR fees begin to follow recyclability grade, so a low-grade format carries a cost your company pays every year rather than once.

Scope

Non-EU sellers are included and usually need an EU representative, and the design, substance, and labeling rules apply regardless of volume.

Before August 12

Three important points about August 12 that are easy to miss

These three points sit in the detail of the regulation and the Commission guidance rather than in the headline dates, and each one changes what you actually have to do. Sources are cited so you can check them.

1. The recyclability obligation starts on August 12, 2026. The grades start in 2030.

These are two different things and they have two different dates. The Commission guidance is explicit: "Article 6(1) requires that all packaging placed on the market is recyclable without providing a specific deadline for the application of this provision, which means that it applies from 12 August 2026." Until the Article 6(4) design-for-recycling act applies, you comply against the old Packaging and Packaging Waste Directive requirements and the related harmonized standard, EN 13430:2004, and your Declaration of Conformity attests to that. You do not run the Article 38 conformity assessment for recyclability until the Article 6(4) act is in force. [LOCKED, Commission Notice C/2026/3084, June 10, 2026]

2. Packaging already placed on the market does not have to be withdrawn

There is no transitional period for exhausting stocks. The guidance also says, though, that packaging "placed on the market before 12 August 2026 may remain on the market and does not need to be withdrawn." What matters is when placing on the market happens, and that is the transfer of ownership or possession, not the sale to a consumer. For imported packaging or packaged products, the relevant timestamp is release for free circulation at the end of the customs procedure. Stock that clears customs on August 11 is placed on the market. Note also that sales and grouped food-contact packaging are placed on the market when they are filled, while transport and service packaging are placed on the market empty. [LOCKED, Commission Notice C/2026/3084, section on PFAS enforcement and exhaustion of stocks]

3. Directive 94/62/EC is only partly repealed on August 12

Article 70 repeals Directive 94/62/EC with effect from August 12, 2026, but keeps several provisions running. Article 8(2) on marking continues until 30 months after the Article 12(6) implementing act enters into force. Article 9(1) and (2) continue for the first-indent essential requirements until December 31, 2029. Articles 5(2) and (3), 6(1)(d) and (e), and 6a continue until December 31, 2028, and Article 12(3a) to (4) until December 31, 2028, or 2029 for data transmission to the Commission. Decision 97/129/EC on the material identification system is not repealed until August 12, 2028. [LOCKED, Reg (EU) 2025/40 Art. 70]

Four moves, in order

Map the whole portfolio first, every SKU and component, including secondary, transport, e-commerce, and imported packaging, because everything downstream keys off a complete map.
Stand up the compliance file, meaning the Declaration of Conformity, producer marking, EPR registration, and removal of PFAS from food-contact formats, all due by 12 August 2026.
Design to Grade A or B rather than the 2030 floor, since Grade C is legal in 2030 but banned in 2038, and designing once to the tougher bar avoids a second redesign.
Name one owner and brief leadership early, because PPWR is cross-functional and stalls without a clear owner and an executive mandate.

Requirements attach to packaging formats, not individual SKUs. PPWR obligations (the Declaration of Conformity, the recyclability grade, and the recycled-content and design rules) apply per packaging type: a stable combination of format, structure, and materials. Every SKU that shares the same packaging is covered by one assessment and one Declaration of Conformity. You map SKUs to find your distinct formats, then comply format by format.

Expand any area below for the detail. The full milestone timeline, every date from 2026 to 2040, lives on the Overview tab.

Does PPWR apply to your company, and in what role?

The core test: if you place packaging or packaged products on the EU market, PPWR applies to your company, wherever it is based. Non-EU businesses selling into the EU are included and usually need to appoint an EU authorized representative. National EPR schemes may set small-quantity reporting thresholds, but the design, substance, and labeling rules apply to your packaging regardless of size.

Brand owner or filler

Producer

You sell products in EU packaging under your brand, whether you fill it yourself or a co-packer does it for you.

Importer or online seller

Producer / importer

You bring packaged goods into the EU, or sell into the EU from outside it.

Retailer or distributor

Verify + own label

You sell or move other brands' packaged goods within the EU. Private label lines make you the producer for those SKUs.

Packaging maker or supplier

Data duty

You make or supply empty packaging or components that end up on goods sold in the EU.

Marketplace or fulfillment

Facilitation duty

You list, store, or dispatch other sellers' packaged goods bound for EU buyers.

Your company is likely in scope if any of these is true: you sell packaged products in the EU; you import packaging or packaged goods into the EU; you ship to EU consumers online; or you make or supply packaging used on goods sold in the EU.

See your duty list, by role and packaging type

Pick your role and the packaging types you use to see which PPWR obligations apply to you, and when. Every date is taken from the EUR-Lex text of Regulation (EU) 2025/40 (fact base locked July 2, 2026); evidence labels show how settled each item is.

Your role

Packaging types (pick all that apply)

Plastic packaging Food-contact packaging Beverage containers E-commerce / grouped / transport Paper & board Glass & metal

Role-wide duties (like EPR registration) always show; type-specific rows appear only for the types you pick.

⚠️ Planning aid only, not legal advice. Dates marked LOCKED were read in the EUR-Lex text of Regulation (EU) 2025/40; SIGNALED items rest on official sources not yet final or not yet re-read; SPECULATIVE items are proposals. Several 2030+ dates shift if their delegated or implementing acts are adopted late (the row notes say so). Verify against primary sources before compliance decisions.

Where to put your effort, phase by phase

Now

Get the day-one basics locked

Before 12 Aug 2026

Map the whole portfolio first, including secondary, transport, e-commerce, and imported packaging.

Everything downstream (fees, the Declaration of Conformity, redesign priorities) keys off a complete SKU and component map. Gaps here show up late as compliance holes.

Stand up the compliance file: Declaration of Conformity, producer marking, and EPR registration in every market you sell into.

These are legal obligations on 12 August 2026 with no grace period for new packaging. Registration in each member state takes lead time.

Get PFAS out of food-contact formats and document it with third-party certificates.

The PFAS limit is one of the few hard bans that bites on day one. Supplier assurances are not enough; you need test certificates for your file.

Start collecting supplier data in a structured format (Article 16).

You cannot complete a Declaration of Conformity without accurate composition, recycled-content, and substance data from suppliers. Build the data spine now.

Set up for the 2028 acts

2026 to 2028

Pre-assess recyclability against proxies (RecyClass, APR, JRC) before the 2028 grades are final.

Waiting for final criteria wastes the two-year runway to 2030. Product cycles run 18 to 36 months, so the formats sold in 2030 are being chosen now.

Get ready for the labeling change.

The 2028 harmonized label and Digital Product Passport mean a pan-EU artwork update. Pre-build templates and data fields so it becomes a switch, not a scramble.

Attack minimization and empty space early.

The 50% empty-space cap and minimization rules land in 2030, but the redesigns and tooling changes take time. Overpackaging is the easiest early win.

Forward

Design for 2030 and the grades beyond

2028 onward

Design to Grade A or B, not the 2030 floor.

Grade C is legal in 2030 but banned in 2038. Designing once to the tougher bar avoids a second redesign a few years later.

Build certified recycled content into sourcing.

The 2030 recycled-content targets need certified chain-of-custody, and certified PCR capacity is constrained. Qualify supply ahead of demand.

Treat the EPR fee as total cost of ownership.

From about 2029 fees follow grade, so a low-grade format carries a recurring annual cost. Model that fee into format decisions, not just unit price.

Add reuse and refill where the format fits.

The 2030 reuse targets and refill obligations pull demand toward reusable formats, and a refill line also lowers the volume you place on the market.

Mobilize your team and brief leadership

Get your organization moving

Name one owner and pull in design, procurement, logistics, legal, and sustainability. PPWR is cross-functional and it stalls without a clear owner.
Find your at-risk SKUs and size the cost. Run the portfolio map, then use the Format Risk Screener to flag formats likely to miss the grade and the Fee Estimator to put a number on your EU exposure.
Turn it into a 90-day plan. PFAS and documentation first, then the redesign candidates the screener surfaces, sequenced against the phases above.

Brief your executives

The deadline is real and phased. It starts 12 August 2026 and tightens through 2030, 2038, and 2040.
The costly decisions are being made now, not in 2030. Product cycles run 18 to 36 months, so today's format choices lock in 2030 compliance and years of EPR fees.
It touches the whole business and the budget. Design, procurement, legal, and sustainability all have a part, and low-grade formats carry a fee we pay every year.

The 30-second version: PPWR is an EU packaging law that affects our market access and margins from 2026. If we act now on our top SKUs, we avoid a redesign scramble and lower our ongoing fees.

Frequently asked questions

The questions companies ask first when PPWR lands on their desk. Click any question to open the answer. Planning context, not legal advice.

Do I need a Declaration of Conformity for every SKU?

No. PPWR requirements attach to packaging formats, not individual SKUs. The Declaration of Conformity is drawn up per packaging type, a stable combination of format, component structure, material composition, and compliance-relevant features, so every SKU that uses the identical packaging shares one declaration. A change of material, supplier, weight, or format triggers a new version.

What does PPWR require on August 12, 2026, versus later?

From August 12, 2026 the substantive obligations are the Declaration of Conformity, EPR registration and fees in every market, the PFAS limits for food-contact packaging, and the general packaging minimization duty. The recyclability grade, recycled-content minimums, the 50 percent empty-space cap, and reuse targets apply from January 1, 2030, and harmonized labeling from August 12, 2028, or 24 months after the Art. 12(6) or 12(7) implementing acts enter into force, whichever is the latest. So the Declaration of Conformity is required day one, but mainly attests identity, substances, and minimization, with the design attestations added as their delegated acts arrive.

Where do I submit the Declaration of Conformity?

Nowhere. There is no EU portal or central authority for it. You hold it on file and produce it to a national market surveillance authority on request. That is different from EPR registration, which does go into national registers such as Germany's LUCID. The declaration follows the Annex VIII structure and travels through the supply chain with the packaging.

Who must comply: the brand owner, the importer, or the supplier?

Brand owners and manufacturers hold the primary obligation. Importers are treated as producers when there is no EU manufacturer. Online marketplaces are the backstop registrant for non-EU sellers. Packaging suppliers and converters have technical information duties, and distributors handle labeling compliance and pass-through obligations.

Do non-EU sellers have to comply, and do I need an EU representative?

Yes. PPWR applies to any company placing packaging or packaged goods on the EU market, wherever it is based. A non-EU seller typically complies through its EU importer, who becomes the producer, through an online marketplace acting as backstop registrant, or by appointing an EU authorized representative where national law requires one. Austria requires one at any volume. EPR registration remains country-by-country.

What are recyclability grades A, B, and C?

PPWR Annex II grades packaging recyclability by weight: Grade A is 95 percent or more recyclable, Grade B is 80 percent or more, and Grade C is 70 percent or more. Below 70 percent is non-recyclable and cannot be placed on the EU market from January 1, 2030. From January 1, 2038 only Grade A or B is allowed. Exact per-material criteria are pending the design-for-recycling delegated act (ACT-02, due January 1, 2028).

What is the empty-space limit for e-commerce and transport packaging?

From January 1, 2030, grouped, transport, and e-commerce packaging may not exceed a 50 percent empty-space ratio under Article 24. The figure is 50 percent, not the 40 percent that circulated in earlier drafts. A general packaging minimization duty applies from August 12, 2026, and the calculation-method act is due February 12, 2028.

What is the PFAS threshold for food-contact packaging?

PFAS are banned from food-contact packaging from August 12, 2026 at three limits under Art. 5(5): 25 ppb for an individual PFAS, 250 ppb for the sum of PFAS, both excluding polymeric PFAS, and 50 ppm for total PFAS including polymeric. The Commission's June 2026 guidance recommends a stepwise test: total fluorine first, and under 50 mg/kg the sample can be treated as compliant. Test grease-resistant paper and board formats now, since reformulation lead times run 12 to 18 months.

When does eco-modulation of EPR fees become mandatory?

Grade-based eco-modulation of EPR fees is mandatory under Articles 6(4) and 45(1) but binds later, about mid-2029, roughly 18 months after the design-for-recycling act (due January 1, 2028). National PROs already modulate fees by design today, so a low-grade format carries a recurring annual cost.

Need help preparing, or an exec-ready brief?

Get hands-on support to map your portfolio, size your exposure, build the compliance file, and brief your leadership.

Get in touch

Country Navigator

Click any country on the map to see EPR system details, fee thresholds, eco-modulation notes, and DRS status. All 27 member states are subject to PPWR direct application from August 12, 2026.

DRS Active

DRS In Development

DRS Deferred / Limited

DRS Not Yet Operational

🗺️

Select a Country

Select any country to see EPR program details, thresholds, and DRS status.

All 27 Member States, EPR & DRS Summary

PPWR Art. 50 DRS mandate: All 27 EU member states must operate a deposit return system for single-use plastic and metal beverage containers from 0.1L to 3L by January 1, 2029. Member states already achieving a 90 percent or higher separate collection rate for a container type may apply for exemption. The mandate does NOT cover glass bottles unless a member state chooses to include them. Click any country on the map for its DRS status, launch date, deposit amount, scope, and operator.

Fee data note: Base EPR fee rates are indicative figures from 2025/early 2026 schedules. Eco-modulation adjustments can shift final liability significantly. Verify current tariffs directly with each national PRO.

Country	PRO / Registry	SME Threshold	DRS Status	Key Note
🇩🇪 Germany	LUCID / Multiple PROs	≤80,000 units AND ≤200 kg	DRS Active, €0.25	Competitive multi-PRO market. Declaration of Completeness required above tonnage threshold.
🇫🇷 France	CITEO / Léko	~≤200 units or ≤5 kg (~€80/yr flat)	DRS Developing	Triman label still required. ICP B2B rate from Jan 1, 2026. CITEO bonus/malus up to ±100%.
🇮🇹 Italy	CONAI (7 consortia)	Varies by consortium	DRS Developing	Alphanumeric codes required. TRIS notification 2026/0167/IT in EC review.
🇪🇸 Spain	Ecoembes / Envalora	<15 tonnes/year	DRS Stalled	SDDR statutory deadline Nov 2026 (RD 1055/2022) but operator authorization stalled; PPWR Art. 50 backstop is Jan 1, 2029. No PPWR national implementing measures enacted.
🇳🇱 Netherlands	Verpact	<50 tonnes/year	DRS Active, €0.15/€0.25	Most generous SME threshold. Statiegeld fully operational. DRS-eligible formats require deposit marking.
🇵🇱 Poland	NFOŚiGW / BDO	PLN 150/quarter waiver	DRS Not Yet	All private PROs liquidated. AR required for non-EU e-commerce sellers. BDO portal in Polish.
🇦🇹 Austria	ARA	Kleinstzeichner ~€150/yr flat rate	DRS Limited / Voluntary	Strictest AR requirement in EU, zero de minimis. Omnibus AR suspension dropped from the Council negotiating mandate June 24, 2026; stalled, not adopted.
🇧🇪 Belgium	Fost Plus / Bruxelles-Propreté	Varies by region	DRS Developing	Three separate regional EPR schemes (Flanders, Wallonia, Brussels).
🇸🇪 Sweden	FTI (Förpacknings- och Tidningsinsamlingen)	~2 tonnes/year	DRS Active, SEK 1–2	Mature EPR system since 1994. Pantamera DRS operational.
🇩🇰 Denmark	Dansk Retursystem	~1 tonne/year	DRS Active, DKK 1–3	One of oldest DRS systems globally (1989). High return rates.
🇫🇮 Finland	Rinki / Palpa	~1 tonne/year	DRS Active, €0.10–€0.40	World-leading return rates (>93%). DRS since 1996.
🇨🇿 Czech Republic	EKO-KOM	300 kg or 600 units	DRS Developing	DRS legislation under development. EKO-KOM well-established.
🇭🇺 Hungary	OHÜ	~200 kg	DRS Active, HUF 50	Centralized state system. DRS launched 2024 via MOHU.
🇷🇴 Romania	ANPM / RetuRO	To confirm	DRS Active, RON 0.50	DRS launched Nov 2023 via RetuRO.
🇧🇬 Bulgaria	ECOBULPACK	To confirm	DRS Not Yet	EPR system transitioning. PPWR application may outpace national readiness.
🇬🇷 Greece	EOAN	To confirm	DRS Not Yet	EPR system in place. Limited DRS development. PPWR mandate by 2029.
🇵🇹 Portugal	SPV (Sociedade Ponto Verde)	~1 tonne/year	DRS Not Yet	DRS in planning. SPV EPR system well-established.
🇮🇪 Ireland	Repak / Re-Turn	~1 tonne or €1M turnover	DRS Active, €0.15/€0.25	Re-Turn DRS launched 2024. Repak established EPR operator.
🇸🇰 Slovakia	NATUR-PACK / ENVI-PAK	To confirm	DRS Active, €0.15	DRS operational since 2022.
🇭🇷 Croatia	FZOEU	To confirm	DRS Active	DRS operational since 2006 via FZOEU.
🇸🇮 Slovenia	SLOPAK	To confirm	DRS Developing	DRS in development. SLOPAK EPR system established.
🇪🇪 Estonia	Eesti Pandipakend	To confirm	DRS Active, €0.10	DRS operational since 2005.
🇱🇻 Latvia	Latvijas Zaļais Punkts	To confirm	DRS Active, €0.10	DRS operational since 2011.
🇱🇹 Lithuania	Green Dot Lithuania	To confirm	DRS Active, €0.10	DRS operational since 2016.
🇱🇺 Luxembourg	Valorlux	~300 kg	DRS Not Yet	Small market. Valorlux EPR established. PPWR DRS mandate by 2029.
🇨🇾 Cyprus	GreenDotCyprus	To confirm	DRS Not Yet	EPR system present. PPWR DRS mandate by 2029.
🇲🇹 Malta	GreenPak / WasteServ	To confirm	DRS Not Yet	Very small market. GreenPak EPR operational. PPWR DRS mandate by 2029.

Glossary

Precise definitions for PPWR terminology. Legal definitions often differ from common usage.

ProducerArt. 3(27) PPWR

Any natural or legal person that makes packaging or packaged products available on the EU market for the first time on a professional basis. Includes manufacturers, importers, and online marketplaces acting as backstop registrants for non-EU sellers.

Common misuse: "producer" is often assumed to mean manufacturer only. PPWR's definition is explicitly broader and captures importers and marketplaces.

Packaging Types (Primary / Secondary / Tertiary / Service)Art. 3(1) PPWR

Primary: packaging constituting a sales unit to the final consumer. Secondary: grouping packaging for a number of sales units. Tertiary: transport/industrial packaging. Service packaging: provided to consumer at point of sale (e.g., carrier bags, takeaway cups).

Recyclability Grade A/B/CArt. 6 + ACT-02 (pending)

A classification of packaging recyclability by weight. Grade A = 95 percent or more (enabling the largest EPR fee discounts), Grade B = 80 percent or more, Grade C = 70 percent or more. Below 70 percent is non-recyclable and cannot be placed on the EU market from January 1, 2030.

Exact criteria are pending ACT-02 (Delegated Act on Design for Recycling). No final technical thresholds published as of July 2026.

Post-Consumer Recycled (PCR) ContentArt. 7 PPWR

Material recovered from waste generated by households or commercial/institutional facilities after use by end consumers. PPWR sets mandatory minimum PCR content targets by polymer type from January 1, 2030.

Distinct from post-industrial / pre-consumer recycled content. Only PCR content counts toward PPWR targets. Methodology for verification: pending ACT-03.

Mass Balance AccountingArt. 7 + ACT-03 (pending)

A chain-of-custody methodology that allows recycled feedstock inputs to be allocated to specific outputs without requiring physical separation throughout production. Relevant to chemical recycling credits for PCR content claims.

Heavily contested. NGOs argue mass balance overstates actual recycled content. Industry argues it is essential for chemical recycling viability. ACT-03 will define the permissible methodology.

Declaration of Conformity (DoC)Arts. 5–12 PPWR

A formal written document attesting that a packaging format meets applicable PPWR requirements. Required for all packaging placed on the EU market from August 12, 2026. Must cover minimization, recyclability, PCR content, PFAS/SoC compliance, and reuse classification.

No direct US equivalent. Some DoC fields (recyclability grade) require data not yet finalizable pending ACT-02.

Authorized Representative (AR)Art. 3(29) + national requirements

A natural or legal person established in the EU, mandated by a non-EU producer to fulfill EPR registration and compliance obligations on the producer's behalf in a specific member state.

Austria requires an AR for all non-resident producers regardless of volume. The Environmental Omnibus proposal would suspend the AR requirement for EU-established producers until Jan 1, 2035; the EPR provisions were dropped from the Council negotiating mandate on June 24, 2026, so the suspension is stalled and not adopted.

Eco-ModulationArt. 6(4)/45(1) PPWR

Mandatory adjustment of EPR fees based on the environmental performance of packaging. Member states must ensure PROs apply higher fees to less recyclable, lower-recycled-content packaging and lower fees to more sustainable formats.

France's CITEO bonus/malus is the most developed example: up to –50% bonus for best-practice design, up to +100% malus for worst-performing formats.

EPR / PROArt. 44–49 PPWR

Extended Producer Responsibility: policy requiring producers to bear financial responsibility for end-of-life management of their packaging. A PRO (Producer Responsibility Organization) is the collective scheme through which producers fulfill EPR obligations (e.g., CITEO, CONAI, Verpact, ARA).

Deposit Return System (DRS)Art. 50 PPWR

A system where consumers pay a deposit on beverage containers at point of sale, refunded when the container is returned to a collection point. PPWR mandates DRS in all 27 member states by January 1, 2029 for single-use plastic and metal beverage containers between 0.1L and 3L.

Digital Product Passport (DPP)Art. 13 + ACT-09 (pending)

A data carrier (e.g., QR code) on packaging linking to a digital record of the packaging's material composition, recyclability grade, PCR content, and compliance documentation. Required from August 12, 2028. Technical format pending ACT-09.

Substances of Concern (SoC)Art. 3(12) + Annex I PPWR

Hazardous substances present in packaging that may impair human health or hinder recycling. Includes PFAS, certain heavy metals, phthalates, and others listed in Annex I. PFAS in food-contact packaging banned from Aug 12, 2026 (>25 ppb individual, >250 ppb sum, >50 ppm total including polymeric, Art. 5(5)).

Design for Recycling (DfR)Art. 6 + ACT-02 (pending)

Technical design criteria that packaging must meet to qualify for specific recyclability grades. Covers material composition, colorants, labels, adhesives, closures, barrier coatings, and separability. Exact criteria pending ACT-02 adoption.

PFAS (Per- and Polyfluoroalkyl Substances)Annex I PPWR

A class of approximately 4,700 synthetic fluorinated compounds. PPWR bans PFAS in food-contact packaging from August 12, 2026 at three limits under Art. 5(5): 25 ppb for any individual PFAS and 250 ppb for the sum of PFAS, both by targeted analysis excluding polymeric PFAS, and 50 ppm for total PFAS including polymeric PFAS. Where total fluorine exceeds 50 mg/kg, suppliers must on request evidence the split between PFAS and non-PFAS fluorine. Common in grease-resistant coatings on paper cups, fast-food wrappers, and microwave packaging.

PFAS testing and reformulation lead times are typically 12–18 months. Brands that have not started this process are now operating very close to the deadline.

Green Dot (Der Grüne Punkt)Art. 12(8) PPWR

The interlocking green arrows symbol historically used to indicate EPR fee payment to a national scheme. PPWR Article 12(8) restricts marks, symbols or inscriptions (including a standalone Green Dot) that could mislead or confuse consumers about packaging waste management, applying once the harmonized label takes effect from August 12, 2028. It may not be used as a recycling instruction symbol.

Harmonized Sorting PictogramArt. 13 + ACT-04 (pending)

A standardized EU-wide graphical symbol indicating how a packaging component should be sorted. Replaces national sorting labels (e.g., France's Triman, Italy's alphanumeric codes). Required on consumer packaging from August 12, 2028. Visual format pending ACT-04.

Compostable PackagingArt. 3(34) + Art. 9 + ACT-05 (pending)

Packaging that can be organically recovered through composting. PPWR distinguishes industrial compostable from home compostable. Permitted only for specific applications (e.g., tea bags, coffee capsules, some fresh food wrapping). Technical criteria pending ACT-05.

Italy filed TRIS notification 2026/0167/IT seeking exemption for compostable single-use food-service packaging. EC response pending ~July 2026.

Void Space / Minimization RuleArt. 24 PPWR

PPWR requires that packaging volume be minimized relative to product volume. For e-commerce, grouped, and transport packaging, the empty (void) space ratio may not exceed 50% from January 1, 2030 (Art. 24); the calculation methodology comes in an implementing act due February 12, 2028, and the general minimization duty starts August 2026. Retail packaging must use the minimum material weight and volume necessary for protective function and labeling.

Life Cycle Assessment (LCA)Not directly applicable under PPWR

A methodology for quantifying environmental impacts across a product's full life cycle. PPWR does not currently permit LCA-based arguments to override its specific format bans or reuse exemptions.

Common misconception: brands sometimes assume an LCA showing single-use outperforms reusable will earn an exemption. PPWR is prescriptive, LCA is not currently a permitted compliance pathway.

PPWR article finder

The articles compliance teams are most often handed by a customer, a lawyer or a supplier. Each links to a full page with the compliance date, who it binds, and the EUR-Lex text.

Delegated Acts Tracker

Live status tracker for PPWR secondary legislation, where the technical details are actually defined. Each act shows its status, due date, evidence label, last-verified date, and what it does to your fees or formats.

🕐 Tracker last verified: July 16, 2026 (statuses checked against EUR-Lex and the Commission implementation page in the July 16 scan)

Why this matters: PPWR's broad requirements are in force from Aug 12, 2026, but many specific technical thresholds (recyclability grades, PCR methodology, DfR criteria) are defined in delegated and implementing acts, most of which are still pending. Of the 9 tracked acts below, none is marked Adopted; none has a EUR-Lex OJ publication as of the last verification. Separately, the first PPWR delegated act was adopted by the Commission on February 25, 2026: Commission Delegated Decision (EU) 2026/429, exempting certain operators using pallet wrappings and straps from the 100 percent transport-packaging reuse targets, now published in the Official Journal (OJ L, 2026/429). The Commission has also published its official interpretive guidance in the Official Journal (Commission Notice C/2026/3084, June 10, 2026). Compliance planning should account for the risk that these acts may be published on short notice. Four corrigenda to Regulation (EU) 2025/40 have appeared in the Official Journal to date (May 22, 2025; September 9, 2025; November 25, 2025; and July 21, 2026). Each corrects a single language version, French, Czech, Swedish and Spanish respectively, and none changes the English operative text [LOCKED, verified against the EN text of Arts. 3(1)(66), 24(2), 29(6) and 47(1)].

ACT-01

Reuse Targets, Calculation Methodology (Art. 30(3))

The reuse targets themselves are self-executing in Article 29 (transport and e-commerce packaging 40% from 2030; beverages 10% from 2030; endeavour targets 70% and 40% from 2040). What is pending is the Article 30(3) implementing act defining how the targets are calculated and measured.

Consequence: Determines how the Art. 29 percentages are counted (qualifying systems, trip counting, exemptions), which drives reuse-system planning for beverage and e-commerce brands ahead of the 2030 deadline. No direct fee effect.

Due: June 30, 2027 Status: Pending, not adopted Evidence: LOCKED deadline (Art. 30(3), EUR-Lex read); SIGNALED status Last verified: 2026-07-16 Source: Art. 30(3) in Reg 2025/40

Pending

ACT-02

Design for Recycling (DfR) Criteria + Recyclability Grade A/B/C Methodology (Art. 6(4))

Defines the technical criteria for each recyclability grade (A, B, C) across all packaging material categories. Determines which formats fall below Grade C (and cannot be placed on the market from 2030) and which earn Grade A fee discounts. JRC methodology work in development; not yet published for public consultation. The technical basis for these criteria is EN 18120:2026, the CEN design-for-recycling standard for plastic packaging (mandate M/584). It is voluntary until ACT-02 makes the method binding. See the Format Risk Screener for per-format traffic-light reads.

⚠️ Blocks: EPR fee grade calculation, DoC recyclability field, packaging design investment decisions, non-recyclable (below Grade C) market-access planning

Consequence: The single most fee-relevant pending act. It delivers the Art. 6(4)(d) eco-modulation framework keyed to the Art. 45(1) EPR obligation: harmonized grade-based fee modulation becomes mandatory in all 27 member states about 18 months after it enters into force (roughly mid-2029), and grade assignments decide 2030 market access for every format in the Format Risk Screener.

Due: January 1, 2028 Status: In preparation Evidence: LOCKED deadline (Art. 6(4), EUR-Lex read); SIGNALED status Last verified: 2026-07-16 Source: Art. 6(4) in Reg 2025/40

In Preparation

ACT-03

PCR Content Calculation Methodology (Art. 7)

Defines how post-consumer recycled content must be calculated, verified, and certified. Determines whether mass balance accounting is permissible for chemical recycling inputs. Contested by NGOs and chemical recycling industry.

⚠️ Blocks: PCR target compliance claims, chemical recycling credit eligibility, PCR supply contract structuring

Consequence: Decides which recycled inputs count toward the Art. 7(1) 2030 minimums (30/10/30/35 by category), so it directly sets the compliance cost of PCR sourcing, whether chemical-recycling credits are usable, and eligibility for national PCR fee bonuses (Verpact 200 EUR/t discount, CITEO PCR prime, Ecoembes 20%+ PCR bonus).

Due: 2026 (statutory) Status: Not published Evidence: SIGNALED Last verified: 2026-07-16 Source: Art. 7 in Reg 2025/40

Not Published

ACT-04

Harmonized Labeling Implementing Act, Sorting Pictograms (Art. 12(6)/(7))

Defines the visual format, sizing, placement, and color specifications for EU-wide harmonized sorting pictograms replacing national labeling schemes from August 12, 2028.

⚠️ Blocks: Artwork planning for the 2028 label transition; national labels (Triman, IT alphanumeric) remain in force until adopted

Consequence: Starts the 24-month clock to the harmonized label (applies Aug 12, 2028, or 24 months after this act if later), which also triggers the Art. 12(8) restriction on standalone marks such as the Green Dot. Late adoption pushes the whole labeling timeline. Artwork and inventory cost effect, no fee-rate effect.

Due: August 12, 2026 Status: Pending, due in weeks Evidence: LOCKED deadline (Art. 12, EUR-Lex read); SIGNALED status Last verified: 2026-07-16 Source: Art. 12 in Reg 2025/40

Pending

ACT-05

Compostable Packaging Technical Criteria (Art. 9)

Defines the specific application categories where compostable packaging is permitted, and technical standards for industrial vs. home compostable certification. Related to Italy TRIS notification 2026/0167/IT (EC standstill response expected ~July 2026).

⚠️ Blocks: Compostable packaging investment decisions; Italy TRIS outcome interacts with this act

Consequence: Decides which formats (coffee capsules, tea bags, fruit stickers, light carrier bags) may or must be compostable, which determines whether bioplastic SKUs stay marketable and how they are priced under schemes like Italy's Biorepack (246 EUR/t from July 2026).

Due: 2026 (statutory) Status: In consultation Evidence: SIGNALED Last verified: 2026-07-16 Source: Art. 9 in Reg 2025/40

Consultation

ACT-06

Reusable Packaging Technical Design Criteria (Art. 11)

Defines technical requirements that packaging must meet to qualify as "reusable." Covers minimum trip counts, durability, hygiene standards, and collection system requirements.

Consequence: Sets the bar for what counts as reusable, which gates both the Art. 29 reuse targets and the large national reuse fee incentives (for example CITEO's reuse bonus, up to a full contribution discount for proven reuse systems).

Due: 2026 (statutory) Status: Not published Evidence: SIGNALED Last verified: 2026-07-16 Source: Art. 11 in Reg 2025/40

Not Published

ACT-07

Deposit Return System Technical Requirements (Art. 50)

Defines minimum technical standards for DRS infrastructure, interoperability between national systems, and cross-border recognition of deposit markings.

Consequence: Shapes deposit-marking and interoperability requirements for beverage formats ahead of the January 1, 2029 all-27 DRS mandate; affects label artwork and cross-border SKU planning in the 9 member states without an operating DRS. No EPR fee effect.

Due: 2027 (statutory) Status: Not yet started Evidence: SIGNALED Last verified: 2026-07-16 Source: Art. 50 in Reg 2025/40

Not Yet Started

ACT-08

Harmonized EPR Registration Format (Art. 44(14))

Required to establish a standardized registration format enabling producers to register across all 27 member states using a single data structure. Intended to reduce administrative burden of multi-country EPR compliance.

⚠️ Statutory deadline of February 12, 2026 was MISSED. Not published as of July 2026. Producers must continue registering individually in each member state using national PRO formats.

Consequence: Until adopted, every producer registers separately in each member state on national PRO formats, the biggest recurring admin cost for multi-country and non-EU sellers (27 registrations, 27 data structures). No fee-rate effect, pure compliance burden.

Due: February 12, 2026 (missed) Status: Overdue Evidence: LOCKED deadline (Art. 44(14)); SIGNALED status Last verified: 2026-07-16 Source: Art. 44(14) in Reg 2025/40

Overdue

ACT-09

Digital Product Passport Format & Minimum Data Fields (Art. 13)

Defines the technical specification for the Digital Product Passport (DPP) data carrier, minimum data requirements, and interoperability standards. Required on packaging from August 12, 2028.

Consequence: Determines the QR/data-carrier spec that must sit alongside (or carry) the 2028 harmonized label, including where a fee-paid symbol like the Green Dot may still appear (inside the QR only). Artwork and data-systems cost, no fee-rate effect.

Due: 2028 (statutory) Status: Not yet started Evidence: SIGNALED Last verified: 2026-07-16 Source: Art. 13 in Reg 2025/40

Not Yet Started

Format Risk Screener

Quick recyclability and compliance risk lookup by packaging format, now with an EN 18120 design-for-recycling score per format.

Design for Recycling: Grade Ladder (preview)

PPWR Annex II grades packaging recyclability by weight (Grades A, B, C only; below 70 percent is non-recyclable). The per-category technical criteria are pending the design-for-recycling delegated act (ACT-02, due Jan 1, 2028), so the assignments below are provisional, for orientation only.

Market-access ladder: from Jan 1, 2030 packaging must reach at least Grade C to be placed on the EU market; from Jan 1, 2035 the recyclable-at-scale test applies; from Jan 1, 2038 only Grade A or B is permitted.

Grade A: 95%+

Largest EPR fee discounts. Clear PET bottles, natural HDPE, aluminum cans, glass, uncoated kraft board.

Grade B: 80%+

Moderate discount. PP tubs, mono-material PE flexibles where collection exists.

Grade C: 70%+

Minimum to stay on the market from 2030. Beverage cartons, some flexibles, coated fiber.

Below Grade C

Non-recyclable. Off the market from 2030. Multilayer laminates, PVC, carbon-black plastic, EPS.

Risk ratings reflect current best assessment based on PPWR text and JRC draft guidance. ACT-02 (DfR criteria) has not been finalized, so exact Grade A/B/C assignments are pending. PPWR Annex II defines only Grades A, B, and C; packaging below 70 percent recyclability is non-recyclable. Use for planning; verify against ACT-02 once adopted.

Format risk ratings, with EN 18120 design read

Each format card shows two reads: a PPWR recyclability risk rating (the badge on the right, based on the PPWR text and JRC draft guidance), and an EN 18120:2026 design-for-recycling traffic-light for plastic formats. EN 18120 (CEN/TC 261/SC 4/WG 10) is the new European Design for Recycling standard for plastic packaging; it classifies design features by compatibility with real recycling infrastructure: Green compatible, Yellow limited, Red incompatible. Developed under Commission mandate M/584 to feed the PPWR method, it is voluntary for now and covers plastics only, so non-plastic formats show Out of scope. The traffic-light is an indicative design screen, not the binding PPWR grade; the legal method is the pending Article 6(4) delegated act (ACT-02, due Jan 1, 2028).

What drives a format risk rating

These are the design factors the screener scores against. They are public recycling-infrastructure principles, not the per-format ratings, and they are worth knowing before you unlock the screener. Full detail at ppwratlas.com/format-risk-screener/.

🔓

See the full screener

You are previewing the risk screener. Add your details to unlock every format, the search, and the full risk detail.

Clear PET Bottle (beverage)

Mono-material clear or light-blue PET, separable closure. Standard beverage bottle format.

EPR: Lower rate under eco-modulation. DRS: In scope in DE, NL, FI, SE, DK, EE, LV, LT, HR, RO, SK, HU, IE and others.

EN 18120: Green Parts 4/10 (PET bottles). Mono-material clear PET with a separable closure, the reference recyclable design.

Grade A Likely

HDPE Rigid Container (natural/white)

Milk bottles, detergent bottles, shampoo containers in natural HDPE. Mono-material, sortable.

EPR: Lower eco-modulation rate. Favored format for DfR compliance.

EN 18120: Green Parts 6/12 (PE/PP rigid). Mono-material natural HDPE, NIR-sortable.

Grade A/B Likely

Aluminum Beverage Can

Standard aluminum can. Highly recyclable, established collection infrastructure across EU.

EPR: Lower rate. DRS: In scope across most active DRS markets. PCR content achievable via closed-loop recycling.

EN 18120: Out of scope Plastic packaging only. Metal recyclability sits under EN 13430; well-established stream.

Grade A Likely

Glass Bottle / Jar

Standard soda-lime glass packaging. Well-established recycling stream across EU.

EPR: Lowest fee rates in most markets. DRS scope varies, excluded from some DRS systems.

EN 18120: Out of scope Plastic packaging only. Glass recyclability sits under EN 13430.

Grade A Likely

PP Rigid Container / Tub

Yogurt pots, margarine tubs, food containers in polypropylene.

EPR: Moderate eco-modulation rate. Clear/natural PP preferred. Label/sleeve compatibility important for grade.

EN 18120: Green Parts 6/12 (PE/PP rigid). Clear or natural PP is design-aligned; full-body sleeves or dark pigment move it to Yellow.

Grade B Likely

Mono-Material PE Flexible Pouch / Film

Stand-up or lay-flat pouch in a single polyethylene family, no barrier layers or foil laminate.

EPR: Medium rate. Grade B in markets with flexible PE infrastructure; Grade C where collection is limited. Market-dependent.

EN 18120: Yellow Parts 7/13 (PE/PP flexible). The mono-PE structure is design-aligned, but flexible-PE collection and sorting are immature in many markets.

Grade B/C, Market Dependent

Opaque / Dark-Pigmented PET Bottle or Container

PET packaging colored with dark or opaque pigments, including most black-pigmented containers.

FR: CITEO malus up to +100%. DE: Higher dual-system fee for non-recyclable formats under the VerpackDG design-incentive structure. IT: High Corepla band. Carbon black prevents NIR sorting, high risk across EU.

EN 18120: Red Parts 4/5/10/11 plus Part 3 (sortability). Carbon black or dark pigment blocks NIR detection, so the pack fails sorting.

Grade C / Non-Recyclable Risk

Multi-Layer Flexible Laminate / Foil Pouch

Stand-up or flat pouches combining PE/PP/PET layers with aluminum foil or EVOH barrier. Non-separable composite.

Highest risk format. Non-separable composite is effectively unrecyclable. ACT-02 expected to classify it as non-recyclable (below Grade C). Malus in FR, high band in IT. 2030 market-access risk is high.

EN 18120: Red Parts 7/13 (PE/PP flexible). Non-separable multi-material and barrier layers are incompatible with mechanical recycling.

Non-Recyclable Risk, 2030 Market Ban

Expanded Polystyrene (EPS), Food Contact

EPS foam trays, cups, boxes for food service or perishable packaging.

SUP Directive restrictions apply to some food-service EPS formats. Non-recyclable (below Grade C) risk under ACT-02. Limited collection infrastructure. High malus in eco-modulation systems.

EN 18120: Red Parts 9/15 (EPS). Sparse collection and sorting plus food-contact contamination make it incompatible in practice.

Non-Recyclable Risk

PVC Packaging (clamshell, blister)

Rigid PVC clamshells and blister packs for retail consumer electronics, hardware, food.

PVC is incompatible with most plastic recycling streams. Below Grade C in draft JRC guidance. Design substitution to PET clamshell strongly recommended.

EN 18120: Red No dedicated EN 18120 part; the protocols treat PVC as a cross-stream disruptor. Substitute to PET.

Below Grade C, Substitution Needed

PFAS-Coated Paper / Board (cups, wrappers, trays)

Paper cups, fast-food wrappers, bakery trays, microwave packaging with fluorinated grease-resistant coatings.

⛔ BANNED from Aug 12, 2026 if PFAS content exceeds 25 ppb individual, 250 ppb sum, or 50 ppm total including polymeric PFAS. Test all grease-resistant paper and board formats immediately. Reformulation lead time: 12–18 months.

EN 18120: Out of scope Plastic packaging only; this is fiber-based. Also banned from Aug 12, 2026 above the PFAS limits regardless of recyclability.

BANNED Aug 2026

Composite Beverage Carton (aseptic / chilled)

Carton formats combining paperboard, PE layers, and aluminum foil (e.g., Tetra Pak, Elopak).

Recyclable in dedicated carton streams only. Grade C anticipated, composite structure impairs recyclability. Some markets lack dedicated carton collection.

EN 18120: Out of scope Fiber-based composite, outside EN 18120 (plastic only). Assess under fiber schemes (4evergreen) and dedicated carton streams.

Grade C Anticipated

Recycled Paperboard / Kraft Board Carton

Secondary and tertiary packaging in recycled paperboard. Widely collected. High PCR content often already present.

EPR: Lowest rates across all markets. Grade A likely. Barrier coatings (PE, wax) may reduce grade, specify barrier-free where possible.

EN 18120: Out of scope Plastic packaging only; this is fiber-based. Strong recyclability under EN 13430 and fiber schemes (4evergreen).

Grade A Likely

Compostable PLA / Bio-Based Plastic

Packaging from polylactic acid or other bio-based compostable materials. Often used for cups, trays, cutlery.

Bio-based origin does not determine PPWR recyclability grade. PLA not recyclable in standard plastic streams. Permitted only for specific applications (ACT-05 pending). Italy TRIS notification may affect scope.

EN 18120: Out of scope EN 18120 covers PET, PE, PP, PS and EPS, not PLA. PLA is a composting route, not recyclable in mainstream plastic streams.

Pending ACT-05

Carbon-Black Pigmented Plastic

Any plastic packaging colored with carbon black pigment (black trays, containers, lids).

Carbon black absorbs NIR light, invisible to NIR sorting equipment. CITEO malus applies. ACT-02 expected to classify it as non-recyclable (below Grade C). Substitute with carbon-black-free alternatives.

EN 18120: Red Part 3 (sortability). Carbon black absorbs NIR, so the pack is invisible to standard sorting. Use detectable pigments.

Non-Recyclable Risk

Full-Body Shrink Sleeve on PET/HDPE

PVC or PET shrink sleeve applied to a PET bottle for decoration/branding.

PVC sleeves on PET bottles: contamination risk, downcycles bottle. PET sleeves: better compatibility. Specify PET sleeve with perforation for easy removal.

EN 18120: Red Parts 4/5 (PET) plus label and sleeve criteria. A PVC or full-coverage sleeve is a disruptor (Red); a perforated PET sleeve is Yellow.

Grade C Risk (PVC sleeve)

Labeling Requirements

Consolidated view of PPWR packaging labeling: harmonized pictograms, deposit and reuse marks, the Green Dot transition, and surviving national marks. Evidence labels show how settled each item is.

Article 12 harmonized labeling. PPWR replaces the national label patchwork with a single EU label using pictograms for material composition and consumer sorting. The Commission implementing act that specifies the pictograms is due by August 12, 2026 [SIGNALED, not yet adopted as of July 2026]. The harmonized label then applies from August 12, 2028, or 24 months after the act enters into force, whichever is later [LOCKED date].

Key Labeling Dates

Date	Requirement	Evidence

What Changes

Pictogram artwork and minimum sizes are not final until the Art. 12 implementing act publishes. Treat label redesign specifications as provisional until then. This section is updated when the act is adopted. Full detail at ppwratlas.com/labeling/.

About PPWR Atlas

Who builds and maintains this hub, the advisory work behind it, and how the data is kept current and trustworthy.

About the Author

I'm Dave Hartter, a packaging and product sustainability advisor based in Charlotte, NC, with more than 20 years of sustainability, R&D and quality experience inside global manufacturers. I view sustainability as a driver of business performance, not just a reporting requirement: understand the market and regulatory environment, identify the risks and opportunities, and build programs that go beyond compliance to drive business value.

As Director of Sustainability, I led product sustainability at Huber Engineered Materials, a division of J.M. Huber. There, I applied tools such as Life Cycle Assessment and Portfolio Sustainability Assessment to understand the regulatory environment, market trends, and customer requirements to drive sustainability into business decisions and customer messaging. At Newell Brands, I led the development of the packaging sustainability program from the ground up, from developing 2025 goals aligned to internal and external stakeholders to building out the tools, systems and training that delivered measurable results. Sustainability programs are only successful when cross-functional teams are engaged and empowered with the tools and training necessary to deliver on the goals.

Today, I advise manufacturers and packaging suppliers directly. The Atlas hubs are the public side of that work. I built them so teams spend less time getting up to speed and more time delivering results. Connect with me on LinkedIn.

Advisory Services

The Atlas provides the information necessary to understand what the PPWR requires and what it costs. Companies throughout the packaging supply chain can then understand the near and long-term risks and opportunities to their business. Whether your company is just starting to scope its PPWR obligations or already understands the financial impact of EU EPR fees and needs a customized strategy to reduce them, I can help.

Engagements I can help you with:

PPWR strategy and fee-reduction roadmaps: where your fees will land across EU markets, and which design, material, and data moves reduce them.
Design for recyclability: assessing a portfolio against the PPWR recyclability grades and eco-modulation criteria, and prioritizing the changes that pay back.
LCA and packaging sustainability programs: building the measurement and design capability in-house, from a first LCA to portfolio coverage.
Regulatory readiness: registration, Authorized Representative appointment, reporting, and data requirements, and getting a company through its first compliance cycle without surprises.

If you are working to future-proof your product and packaging portfolio, let's talk: info@hartteradvisory.com

About the Site

The EU Packaging and Packaging Waste Regulation is moving fast and is difficult to keep up with. Regulation (EU) 2025/40 applies from August 12, 2026, its recyclability, recycled-content, labeling, reuse, and deposit return rules phase in through a series of delegated and implementing acts, and national EPR schemes each modulate fees their own way. Most coverage assumes you already know what you're doing, or sits behind a consulting paywall. Sustainability, packaging, and regulatory leaders needed one trusted place that tracks all of it, stays current, and is free to use.

That is what PPWR Atlas is: a live intelligence hub covering deadlines, recyclability grades, eco-modulation, EPR fees, labeling, and the pending delegated acts across the EU and its key national markets, updated weekly from primary and trusted sources.

How the data is maintained

Regulatory data is only useful if you can trust it and if it's current, so PPWR Atlas runs on a few standing rules.

Every date, threshold, grade, and fee is tied to a primary source: the regulation text on EUR-Lex, an adopted delegated or implementing act, official Commission guidance, or a national PRO's published schedule. Each figure carries a visible evidence label, LOCKED for a settled rule, SIGNALED for one that is expected but not yet adopted, and SPECULATIVE for a projection, so you can see the difference between a rule that is fixed and one that is still forming. A national scheme's rule is never presented as a harmonized PPWR requirement.

The site is not to be viewed as legal advice. Rules change, and your obligations depend on the specifics of your company. Verify anything consequential against the primary sources or with qualified legal counsel before acting on it.

The other Atlases

PPWR Atlas is one of three regulatory intelligence sites:

PPWRAtlas.com: the EU Packaging and Packaging Waste Regulation (this site)
EPRAtlas.com: U.S. packaging Extended Producer Responsibility
ESPRAtlas.com: the EU Ecodesign for Sustainable Products Regulation and Digital Product Passports

What's New

Recent PPWR developments from the last 60 days, split into regulatory and policy movement and site updates. Updated July 29, 2026.

Latest Regulatory & Policy

Regulatory & Policy July 29, 2026

Three August 12 Points That Are Easy to Miss

With two weeks to go, three points sit in the detail rather than the headline dates. First, recyclability. The A, B, C grades are a 2030 obligation, but the recyclability requirement itself is not: the Commission guidance states that Article 6(1) "applies from 12 August 2026," with compliance measured against the old Directive and EN 13430:2004 until the Article 6(4) act lands. Second, stock. There is no transitional period for exhausting stocks, but packaging already placed on the market "may remain on the market and does not need to be withdrawn," and placing on the market is the transfer of ownership or possession, with imports timestamped at release for free circulation. Third, the previous Directive. Article 70 repeals Directive 94/62/EC from August 12 but keeps parts of it running to 2028 and 2029, and Decision 97/129/EC on material identification codes survives to August 2028. The full detail, with citations, is on the Prepare for PPWR tab. Sources: Reg (EU) 2025/40 Arts. 6, 70; Commission Notice C/2026/3084, June 10, 2026 [LOCKED].

Regulatory & Policy July 27, 2026

Deposit Systems Post First Hard Numbers

Two live deposit return systems published performance data this month. Romania's RetuRO reported more than 2.4 billion containers returned in the first half of 2026, an 82 percent return rate, up three points year on year, with coverage now reaching 92 percent of localities above 1,500 inhabitants. Portugal's Volta, live since April 10, 2026, passed 100 million containers returned and an estimated 38 percent collection rate by the end of July, running more than 2,500 automated collection points. Both figures matter as benchmarks for the member states that must stand up a system by January 1, 2029 under Article 50. Source: RetuRO H1 2026 barometer, July 27, 2026; SDR Portugal, July 21, 2026 [SIGNALED].

Regulatory & Policy July 21, 2026

Fourth PPWR Corrigendum, and Still No Change to the English Text

The Official Journal published a corrigendum to Regulation (EU) 2025/40 on July 21, 2026 correcting the Spanish language version of recitals 130 and 131, Article 3(1)(66) and Article 47(1), replacing "sistema de responsabilidad ampliada del productor" with "organizacion competente en materia de responsabilidad del productor." This is the fourth corrigendum to the PPWR, following French on May 22, 2025, Czech on September 9, 2025 and Swedish on November 25, 2025. All four correct a single language version. The English text of Article 3(1)(66) already reads "producer responsibility organisation" and the English Articles 24(2) and 29(6) already carry the corrected wording, so nothing in the English operative text has moved. If you work from a Spanish or French text, re-check your quotations against the consolidated version. Read it at EUR-Lex, OJ L of July 21, 2026. Source: OJ L, 2026/90604, July 21, 2026 [LOCKED].

Regulatory & Policy July 8, 2026

Spain's Deposit Authorization Stalls at Regional Level

Spain's own deposit mandate under Real Decreto 1055/2022 carries a November 2026 statutory deadline, and the process to authorize an operator has stopped. MITECO reports that between June 29 and July 8, 2026 the Madrid regional coordination commission issued three requests for supplementary documentation without transmitting them to the four applicant deposit operators, leaving the authorizations unresolved. More than 130 organizations have written to the regional government about the blockage. Spanish producers should plan on the November 2026 date slipping, with the PPWR Article 50 mandate of January 1, 2029 as the binding EU backstop. Source: MITECO procedural record and Spanish reporting, June to July 2026 [SIGNALED].

Fees July 7, 2026

Verpact Publishes 2027 Rate Bandwidths for the Netherlands

Verpact set indicative bandwidths for its 2027 Dutch packaging EPR tariffs. Glass, paper and board, wood, other metals and the system contribution are stable; beverage cartons and aluminium rise; plastic is held flat despite cost increases. Final 2027 rates follow in September 2026. The notable change is a new eco-modulation deduction rewarding recyclate sourced from European countries and customs zones, scaling with recyclate share, on top of the existing 20 cent per kg recycled-content discount. Deposit producer contributions rise for both plastic bottles and cans. Current rates: verpact.nl/nl/tarieven. Source: Verpact, July 7, 2026 [LOCKED].

Fees July 2026

Ecoembes Publishes Its 2027 Spanish Schedule Early

Ecoembes has published full 2027 Punto Verde prices and its rate page now leads with 2027 rather than 2026, unusually early in the year. Headline 2027 domestic lines: PET beverage bottles up to 3L at 0.278 EUR/kg, other PET bottles 0.267, PET trays and other rigid items 0.682, HDPE rigid 0.282, other rigid plastics 0.773, flexible film 1.269, paper and cardboard 0.117, beverage cartons 0.544, steel 0.197, aluminium 0.040. Spanish household producers can model 2027 exposure now. Note that Ecoembes covers household packaging only; glass sits with Ecovidrio and industrial and commercial packaging with Envalora and the other industrial schemes. Rates: ecoembesempresas.com/precios. Source: Ecoembes 2027 price sheet [LOCKED].

Regulatory & Policy June 30, 2026

France Sets a January 1, 2029 Deposit Deadline

At the June 30, 2026 plenary session of the Plan plastique consultation, France's ecology minister stated that a deposit for recycling will be mandatory from January 1, 2029, framing it as "anticipate or endure" and citing a 58.4 percent beverage container collection rate in 2024 against a 90 percent goal. Local authority associations and NGOs walked out of the session, and the Senate committee had formally opposed the measure on May 19, 2026, so the delivery route is contested even though the date is now on the record. The date is corroborated in a Senate written question of May 28, 2026. France moves from "developing a DRS" to a dated national commitment. Source: French Ministry for Ecological Transition consultation, June 30, 2026 [SIGNALED].

Regulatory & Policy July 17, 2026

Germany's VerpackDG Enters the Statute Book

Germany promulgated its Packaging Law Implementation Act (Verpackungsdurchführungsgesetz, VerpackDG) in the Federal Law Gazette on July 17, 2026 (Bundesgesetzblatt Teil I 2026 Nr. 207). The act adapts national packaging law to Regulation (EU) 2025/40 and replaces the old Verpackungsgesetz (VerpackG); its core provisions take effect August 12, 2026, in parallel with the PPWR. The Bundestag adopted it June 11, 2026 and the Bundesrat approved it July 10, 2026, after the European Commission withdrew its notification objections on May 29, 2026. Notable national changes include an expanded system-participation obligation (now reaching certain primary-production and transport packaging), a new authorization requirement for producers of non-system-participation packaging, and a transition rule keeping existing system participations valid until December 31, 2026; the LUCID register continues, to be aligned once the PPWR Article 44(14) registration-format act is adopted. Source: Bundesgesetzblatt I 2026 Nr. 207, July 17, 2026 LOCKED.

Regulatory & Policy June 24, 2026

Council Drops EPR Provisions from Environmental Omnibus Mandate

On June 24, 2026 the Council agreed a partial negotiating mandate on the Environmental Omnibus covering industrial emissions, circular economy, and geospatial data. The extended producer responsibility provisions, including the proposed suspension of the Article 45(3) Authorized Representative requirement for EU-established producers until 2035 (COM/2025/982), did not secure agreement and were removed from the mandate. The suspension cannot proceed to trilogue as drafted; the Presidency continues work. Non-EU producers were never covered and must still appoint an AR by August 12, 2026. Source: Council of the EU press release, June 24, 2026.

Regulatory & Policy June 10, 2026

PPWR Guidance Document Published in the Official Journal

The European Commission's guidance document for Regulation (EU) 2025/40 was published in the Official Journal on June 10, 2026 as Commission Notice C/2026/3084 (adopted June 5, 2026 as C(2026) 3702 final). It formalizes the guidance first released March 30, 2026 and covers definitions, the PFAS food-contact restriction, recyclability, recycled content, labeling, reuse, DRS, and compostable packaging. It is now the authoritative interpretive reference ahead of the August 12, 2026 application date. Read it at EUR-Lex, C/2026/3084. Source: EUR-Lex, C/2026/3084, June 10, 2026.

Site Updates

Site Update July 16, 2026

New "Prepare for PPWR" tab

Added a "Prepare for PPWR" tab, an action-oriented walkthrough of what producers should do ahead of the August 12, 2026 application date.

Site Update July 2, 2026

Interactive Fee Estimator and EU map

Expanded the Fee Estimator with per-SKU and country-specific fee structures for France, Italy, and the Netherlands, added a clickable SVG map of the EU to the Country Navigator, and built a status tracker for the nine pending delegated acts.

Site Update June 30, 2026

Format Risk Screener and Labeling tab

Added the Format Risk Screener with the A/B/C recyclability grade ladder and market-access dates, plus a consolidated Labeling requirements tab.

ℹ️ About This Tab

This tab shows PPWR developments from the last 60 days, organized into two sections. Regulatory & Policy covers new EU delegated and implementing acts, official guidance, national scheme changes, enforcement, comment periods, and legislative movement. Site Updates covers new hub features and enhancements.

The primary sources monitored each week (EUR-Lex, the European Commission, national PRO portals, the JRC, and trade and legal press) are listed in the footer.

💶 EU Packaging Fee Estimator

Estimate annual EPR compliance fees across EU member states. Two modes: portfolio-level (enter annual tonnage by material) or per-SKU (enter each packaging component). Rates from verified 2025/2026 PRO schedules. Eco-modulation is excluded from the portfolio estimate and offered as an illustrative layer in the per-SKU estimator; design attributes can move fees by 10 to 100 percent.

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Enter annual tonnage by material for a given market. 12 categories reflecting how major EU PROs actually price packaging, plastic is split by format (rigid/flexible) and recyclability grade. Formula: Tonnes × PRO base rate (€/tonne) = annual fee. Eco-modulation adjustments (±10–100%), SME flat rates, and SUP per-unit fees not applied.

⚖️ Annual Tonnage by Material

🇪🇺 Countries to Compare

💰 Estimated Annual EPR Fees

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Select countries and enter annual tonnes by material

⚠️ Planning estimates only, not for compliance reporting. Rates are verified base fees from PRO schedules; eco-modulation (±10–100%) excluded. Netherlands: Rigid Recyclable and Rigid Hard-to-Recycle show the same base rate, Verpact differentiates recyclability through eco-mod, not the base fee. Italy plastic rates from CONAI 9-band Corepla system. Germany: compliance rates not public. Spain uses Ecoembes household rates; industrial and commercial packaging goes to Envalora and is materially cheaper. Spanish glass is managed by Ecovidrio and carries a weight factor plus a unit factor; only the weight factor is shown here. France: CITEO 2026 official weight-based rates (the per-unit component is excluded here; use the Per-SKU Estimator to include it). CZ rates converted at 25.3 CZK/EUR; SE at 10.9 SEK/EUR. Sweden rates are among the EU's highest; NPA cut 2026 fees as the property-near (kerbside) collection rollout ran slower than planned, with increases due again Jan 2027.

Add each packaging component for this SKU (e.g. a PET bottle body + PP cap + paper label). Enter weight per unit in grams and annual units sold per market. The calculator estimates the EPR fee per unit and per year in each country.

📦 SKU Packaging Components

Component

Material

Weight (g)

Units/Year

IT CONAI Band

♻️ Eco-Modulation & Penalties (illustrative)

Applies an illustrative bonus or malus to the plastic portion of the SKU, reflecting how national PROs (CITEO, CONAI, Ecoembes, Verpact) already adjust fees by design. Harmonized PPWR grade-based modulation under Art. 6(4)/45(1) is mandatory only about mid-2029.

Post-consumer recycled (PCR) content Carbon black or NIR-undetectable colorant (malus) Full-body shrink sleeve over 50% coverage (malus) PVC or non-recyclable multilayer structure (malus)

🎯 Country-Specific Structures (Tier 2)

France, Italy, and the Netherlands charge along axes a weight-only model misses. Each input below affects only that country's column in the results.

🇫🇷 France: CITEO per-unit (UVC) contribution SIGNALED

Add the per-UVC charge on top of the weight base Business sector (CITEO 2026 barème)

Packaging units (UEs) per UVC are counted from the components above (capped at 20; CITEO adds 5% per unit beyond that). Includes the flat 0.0140 ct reuse contribution per UVC. Source: official CITEO 2026 rate guide (the 4-UE row was read directly in the official guide); full six-sector grid via THOT EXPERTISE's reproduction of the official schedule, cross-checked against that row.

🇮🇹 Italy: CONAI diversified contribution LOCKED

Pick each component's CONAI band in the component rows above ("IT CONAI Band"). The band replaces the generic material rate in the Italy column, and the illustrative eco-modulation layer is not applied on top (the band is Italy's eco-modulation). Plastic bands A1.1 to C run 40 to 790 EUR/tonne (schedule in force to Sep 30, 2026; CONAI has announced increases from Oct 1, 2026, e.g. Fascia C to 922 EUR/tonne [SIGNALED]). Paper fascie 1 to 6 run 45 to 285 EUR/tonne by non-paper content [SIGNALED].

🇳🇱 Netherlands: SUP per-unit surcharge LOCKED

This SKU is a single-use-plastic format (cups, drinks packaging, molded or flexible SUP food packaging, carrier bags under 50 micron): adds 2.10 EUR per 1,000 units (Verpact 2026). Applies from the first unit, outside the 50-tonne exemption.

🇪🇺 Countries to Compare

💰 Per-Unit & Annual Cost by Country

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Add components to see results

⚠️ Per-unit fee = component weight (kg) × material rate (€/kg), plus any country-specific structures you enable: the France CITEO per-UVC contribution (six sector barèmes, packaging units counted from your components, annualized using the highest units/year among components), the Italy CONAI band override (per component), and the Netherlands SUP per-unit surcharge. The eco-modulation panel applies an illustrative bonus or malus to the plastic portion only; it is skipped for components with an explicit IT CONAI band in the Italy column. DRS deposit amounts and SME minimum fees not applied. Planning estimates only, not for compliance reporting.

📋 Rate Data Sources & Coverage

14 countries with confirmed or indicative primary-source rates. 1 country (Germany) does not publish compliance rates publicly. Italy (CONAI), Netherlands (Verpact), and Belgium (Fost Plus): plastic sub-categories from primary per-format rates. Other countries: rigid/flex sub-split estimated from published recyclable/non-recyclable rates.

Country	PRO / Source	Year	Confidence	Notes

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ℹ️ About This Hub

PPWR at a glance

Three important points about August 12 that are easy to miss

1. The recyclability obligation starts on August 12, 2026. The grades start in 2030.

2. Packaging already placed on the market does not have to be withdrawn

3. Directive 94/62/EC is only partly repealed on August 12

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Retailer or distributor

Packaging maker or supplier

Marketplace or fulfillment

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Set up for the 2028 acts

Design for 2030 and the grades beyond

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All 27 Member States, EPR & DRS Summary

PPWR article finder

Design for Recycling: Grade Ladder (preview)

Grade A: 95%+

Grade B: 80%+

Grade C: 70%+

Below Grade C

Format risk ratings, with EN 18120 design read

What drives a format risk rating

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Key Labeling Dates

What Changes

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About the Site

Latest Regulatory & Policy

Three August 12 Points That Are Easy to Miss

Deposit Systems Post First Hard Numbers

Fourth PPWR Corrigendum, and Still No Change to the English Text

Spain's Deposit Authorization Stalls at Regional Level

Verpact Publishes 2027 Rate Bandwidths for the Netherlands

Ecoembes Publishes Its 2027 Spanish Schedule Early

France Sets a January 1, 2029 Deposit Deadline

Germany's VerpackDG Enters the Statute Book

Council Drops EPR Provisions from Environmental Omnibus Mandate

PPWR Guidance Document Published in the Official Journal

Site Updates

New "Prepare for PPWR" tab

Interactive Fee Estimator and EU map

Format Risk Screener and Labeling tab

ℹ️ About This Tab

💶 EU Packaging Fee Estimator

See the full estimator

📋 Rate Data Sources & Coverage

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