On August 6, 2026, the European Commission initiated a public consultation on a draft implementing regulation of the Packaging and Packaging Waste Regulation (EU) 2025/40, with the core objective of establishing harmonized registration formats and reporting requirements for producer registers.
I. Registration Requirements (Annex I)
When registering, producers (or their producer responsibility organizations, authorized representatives) must submit the following information:
|
Section |
Content |
|
Part A |
Basic producer information: Name, legal form, address, tax/VAT number, brand names, contact details, etc. |
|
Part B |
How the producer fulfills Extended Producer Responsibility (EPR): Self-compliance or delegation to a Producer Responsibility Organization (PRO), with relevant authorization documents attached |
|
Part C |
Certificate of compliance issued by the Producer Responsibility Organization |
|
Part D |
Authorized representative information (for non-EU producers): Name, address, tax number, represented producer(s), etc. |
Key Requirements: Information must be submitted electronically, supporting fully automated processing and batch verification. If multiple packaging waste management systems exist within a Member State, separate registration is required for each.
II. Reporting Requirements (Annex II)
Producers must annually report packaging placement and waste treatment data, using different forms based on production volume:
|
Section |
Applicability |
Reporting Content |
|
Part A |
Producers placing ≥10 tonnes/year |
Detailed reporting by weight of packaging placed on the market, categorized by primary material (glass, paper/cardboard, iron, aluminum, various plastics, wood, textiles, ceramics, and 23 other categories) |
|
Part B |
Producers placing <10 tonnes/year |
Simplified reporting with broader material categories |
|
Part C |
All relevant parties |
Quantity of separately collected single-use plastic beverage bottles and metal beverage containers (capacity ≤3 liters), distinguishing whether included in a deposit-return system |
|
Part D |
All relevant parties |
Quantity of various packaging waste collected within the Member State |
|
Part E |
All relevant parties |
Quantity of packaging waste disposed of, recovered, and recycled within the EU |
|
Part F |
All relevant parties |
Quantity of packaging waste disposed of, recovered, and recycled outside the EU |
Key Rules:
- Composite materials shall be classified according to their main component (the material with the highest weight percentage), but the weight of each constituent material must also be reported.
- Data must be based on the product's technical documentation or an equivalent complete description (linked to EU conformity assessment requirements).
- If the product already has a Digital Product Passport (e.g., compliant with (EU) 2024/1781), it may be used directly to provide registration information.
ChemRadar Insights
The consultation period for this draft ends on September 10, 2026. Although the draft has not yet been formally adopted, given that the (EU) 2025/40 PPWR is already in effect, companies should immediately begin the following preparations:
- Inventory current packaging placement volumes in each EU Member State to determine whether the 10-tonne threshold is triggered.
- Evaluate authorized representative establishment options (for non-EU enterprises, consider establishing a unified representative in a key market country).
