PPWR compliance.
Everything that applies since 12 August 2026, and what comes after.

What is PPWR, and when did it start to apply?

PPWR is Regulation (EU) 2025/40 on packaging and packaging waste, and it has applied since 12 August 2026 in every Member State, with no national transposition. It repeals Directive 94/62/EC and runs to 2040.

Formally the Regulation of the European Parliament and of the Council on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC, it is the EU’s overhaul of packaging law for the next two decades. It was adopted on 19 December 2024, published in the Official Journal of the European Union on 22 January 2025 and entered into force on 11 February 2025.

The choice of instrument matters. The old Packaging and Packaging Waste Directive (PPWD, in force since 1994) required Member State transposition and produced 27 differently transposed national regimes. PPWR is a regulation: it has direct effect and applies uniformly across all 27 Member States from the same date. National laws (France AGEC, Germany VerpackG, Italy decreto legislativo 152/2006, Spain Real Decreto 1055/2022) continue to apply alongside PPWR, but they cannot derogate from its harmonised rules.

PPWR covers four broad areas: (a) packaging design and composition (recycled content, recyclability classes, reuse, hazardous substances); (b) extended producer responsibility (Article 45, the authorised representative regime); (c) labelling and consumer information; (d) end-of-life targets and waste reduction. This guide focuses on (b) and its operational implications, with reference to (a) and (c) where they affect cross-border producers.

PPWR timeline 2024 to 2040

The regulation phases in over 15 years from adoption. The first four dates are behind us; from here, producers need a concrete plan for 2027, 2028 and 2030.

Who has to appoint an authorised representative under Article 45?

Since 12 August 2026, Article 45 of Regulation (EU) 2025/40 requires a producer that makes packaging available in a member state where it is not established, including from another EU country, to appoint an authorised representative for extended producer responsibility in that member state. One representative per Member State: a producer shipping to four Member States where it is not established needs four.

The article is short and operationally decisive. Its four paragraphs, as read in the Commission's guidance:

• Article 45(1): the producer of packaging not established in the Member State where it makes packaging available must appoint, in that Member State, an authorised representative for extended producer responsibility.
• Article 45(2): the appointment is made by written mandate, and the representative must be established in that Member State.
• Article 45(3): the representative fulfils the EPR obligations in that Member State (registration, declarations, contributions, information to the authorities); the producer remains responsible.
• Article 45(4): one representative per Member State. There is no single-window mechanism for the EPR representative role, unlike VAT OSS.

In France, the PPWR rule sits next to a national one that is broader: since 10 July 2026, Article L. 541-10-9-1 of the French Environmental Code requires every producer not established in France and subject to EPR to appoint a France-established representative, for every stream, not only packaging. For the paragraph-by-paragraph analysis see the PPWR Article 45 guide; for the French role itself, the EPR authorized representative page.

And the Omnibus? The European Commission's environmental Omnibus proposal is still in the legislative procedure and has no legal effect. The French obligation of Article L. 541-10-9-1 applies today. Latest state of play: EU Omnibus and the EPR authorised representative, what changes and what does not.

Who is in scope of PPWR?

Everyone who makes packaging available on the EU market, whatever their origin. The producer is whoever first makes the packaging available on the market of a given Member State, which matches the national EPR definition.

In practice, for sellers based outside the destination country, that covers direct-to-consumer brands shipping from abroad (Shopify stores, dropshippers, TikTok Shop sellers), Amazon FBA sellers whose seller of record is not established in the country of sale, wholesalers placing packaged goods for resale, and brand owners selling through a fulfilment partner. Four producer profiles behave differently:

• Non-EU producer shipping directly to EU consumers. US LLC, UK Ltd, Hong Kong or Chinese exporter. Article 45 applies: appoint a representative in every Member State you ship packaging to. France: mandataire REP, compulsory under Article L. 541-10-9-1. Germany: Bevollmächtigter under VerpackG.
• EU producer shipping cross-border between Member States. German GmbH shipping to France, Spanish SL shipping to Italy. Article 45 applies in every Member State where the producer is not established. EU establishment elsewhere does not exempt.
• EU producer placing on its home market only. No separate representative for the home Member State: the producer registers directly with its national schemes.
• Non-EU producer shipping to an EU importer who takes title. If the importer is the producer for EPR purposes (title passes to it before the goods reach the end user), the importer registers; the exporter does not. Incoterms and contract structure decide.

Online marketplaces do not take on your EPR automatically: they must verify that third-party sellers are registered, which is why a missing registration gets listings blocked. Where a producer is not established or registered, some Member States can treat the platform or fulfilment provider as the producer, but that does not relieve you of the obligation to appoint a representative.

What applied on 12 August 2026?

The representative obligation and the product-conformity pillar. Recycled content, recyclability classes and format bans did not start that day: they start on 1 January 2030.

• Article 45 representative obligation, EU-wide. Enforcement goes through marketplaces and each Member State's administrative framework.
• Conformity assessment and EU declaration of conformity (Article 38 and Annex VII, Article 39 and Annex VIII), with technical documentation kept 5 years, or 10 years for reusable packaging. See our conformity guide.
• Identification and contact details of the manufacturer or importer on the packaging (Article 15), and importer verification (Article 18).
• Substances of concern (Article 5), including the PFAS limits in food-contact packaging and the heavy-metal limits inherited from the PPWD.
• Reusable packaging requirements (Article 11), minus the minimum number of rotations, which awaits a delegated act due by 12 February 2027.

France's existing Info-tri and Triman marking continues to apply alongside, until the harmonised EU label replaces it: see the label harmonisation state of play.

What changes from 2030?

Packaging design. From 1 January 2030, recyclability classes, recycled-content minimums for plastic packaging, Annex V format bans and the first reuse targets apply, and redesign has 18 to 36 month lead times, so planning starts now.

Article 6, recyclability classes. All packaging placed on the EU market must be designed for recycling. Three grades:

• Grade A: optimally recyclable.
• Grade B: recyclable with limitations.
• Grade C: barely recyclable; banned from 2035.

The grading methodology is specified by Commission implementing acts (Article 6(4) and (5)). France's eco-modulation grids (Citeo, Refashion, Ecosystem) will adjust as the methodology lands.

Article 7, minimum recycled content. Mandatory minimum post-consumer recycled content in plastic packaging, by application. The first thresholds land on 1 January 2030 (30% for contact-sensitive PET, 35% for other plastic packaging among them) and rise again on 1 January 2040. For producers using virgin plastic, this is the biggest cost driver in the regulation.

Reuse targets. Mandatory reuse rates for specified packaging applications, shown in the targets table below. The biggest commercial impact is on B2B logistics (transport packaging, pallets, crates) and HORECA.

Targets summary table

Indicative thresholds; exact numbers depend on Commission implementing acts and may be refined. Always cross-check the EUR-Lex text and Commission communications.

How do you become PPWR-ready, step by step?

For a producer selling into Member States where it is not established, the path runs through seven steps. Steps 1 to 5 are due now, since the obligation has applied since 12 August 2026; steps 6 and 7 are continuous.

1. Step 1, Map your packaging footprint by Member State. List every EU Member State where you currently place packaging on the market. Quantify the annual packaging tonnage per material per Member State. This is the data foundation for everything that follows.
2. Step 2, Appoint an authorised representative per Member State. Where you are not established locally, appoint a representative in each Member State. France: a France-established mandataire REP appointed by written mandate, compulsory since 10 July 2026 under Article L. 541-10-9-1 of the French Environmental Code. Germany: Bevollmächtigter under VerpackG. Italy: representative under decreto legislativo 152/2006.
3. Step 3, Join the national schemes. In each Member State, the representative files your membership with the relevant accredited organisations: in France, Citeo or Léko for household packaging; in Germany, a dual system; in Italy, CONAI; in Spain, Ecoembes; in the Netherlands, Verpact.
4. Step 4, Obtain the national producer identifiers. Each national register issues a producer number: the IDU in France (SYDEREP), the LUCID number in Germany, and so on. In France, Citeo issues the identifier about seven business days after the membership is validated; Léko about five business days after its initial invoice is paid (payable within five business days, otherwise the membership is cancelled). Marketplaces check these numbers before listings stay live.
5. Step 5, Upload the identifiers to your sales channels. For each Member State you ship to, enter the local producer number in the marketplace compliance settings (Amazon Seller Central, Cdiscount, ManoMano) and in your terms of sale where required.
6. Step 6, Audit packaging for the 2030 recyclability classes. Begin redesigning packaging artwork and material composition for PPWR recyclability grading (Article 6). Target Grade A or B by 2030; Grade C is banned from 2035.
7. Step 7, Declare and stay compliant. Declarations run per Member State. In France, most streams are declared once a year; household packaging placed on the market in 2027 is declared to Citeo from January to the end of February 2028.

What does PPWR compliance cost?

It scales with the number of Member States: each one adds a representative fee, a scheme membership and the eco-contribution on your tonnage. The same producer pays roughly the same per-country cost in each Member State of shipment.

For France specifically, our fee is a fixed annual fee per stream, from €190/year excl. VAT, confirmed in a written quote within one business day. Your annual fee is a fixed amount per stream and per calendar year, independent of your eco-contributions. It depends on the declaration regime and frequency, the number of references and, above EUR 1,000 of eco-contribution per stream, its size. It is fixed in writing for the year and can only change for the following year, notified in writing by 15 September, or during the year if your scope changes, for example a new stream or a change of declaration regime.

We act as your authorized representative in France only; for other EU Member States, a separate representative established in each country is required, which is outside our scope. Expect roughly €2,000 to €5,000/year per stream from local providers there. We are building a partner program (in development) for those markets: Germany, Italy, Spain, Netherlands, United Kingdom (post-Brexit).

Eco-organism or dual-system membership adds €80 to €500/year per Member State per stream. The eco-contribution scales with declared tonnage: in France €0.02 to €2.80 per kilogram of household packaging depending on material, modulated by recyclability.

For a typical non-EU consumer brand shipping packaged goods to four EU Member States (FR, DE, IT, ES): total all-in PPWR packaging compliance is about €15,000 to €25,000 per year. Adding electrical equipment (which remains national, not under PPWR) doubles or triples this for electronics brands.

Which PPWR mistakes cost producers the most?

Assuming one representative covers the EU, assuming PPWD compliance carries over, and leaving the 2030 redesign too late. The five we see most often:

Frequently asked questions

Sources & references

Every legal claim on this page traces to one of the primary sources below.

• Regulation (EU) 2025/40 (PPWR), EUR-Lex (English text) · Adopted 19 December 2024, OJEU 22 January 2025, applicable since 12 August 2026.
• Packaging waste, European Commission topic page · Official Commission overview with the implementing acts roadmap.
• Directive 94/62/EC (PPWD), EUR-Lex · The directive repealed by PPWR.
• Article L. 541-10 du Code de l’environnement, Légifrance · French producer definition.
• Loi n° 2026-602 du 8 juillet 2026, creating Article L. 541-10-9-1 du Code de l’environnement (JO of 9 July 2026) · Applicable since 10 July 2026: a producer not established in France and subject to EPR must appoint a representative established in France, for every stream.
• Loi n° 2020-105 du 10 février 2020 (AGEC), Légifrance · French national EPR framework that continues to apply alongside PPWR.
• LUCID, German central packaging register (ZSVR) · German operational reference.
• CONAI, Consorzio Nazionale Imballaggi (Italy) · Italian packaging EPR scheme.
• Real Decreto 1055/2022 (España), BOE · Spanish packaging EPR.
• SYDEREP, French producer register (ADEME)

Updated 12 October 2026.