# The regulation that arrives today: PPWR and the 27 registrations behind it

Source: https://euornot.eu/ppwr-eu-2025-40-applies-today/
Published: 2026-08-12
Updated: 2026-08-14
Section: Packaging & EPR
Tags: ppwr, epr, packaging, cross-border, compliance
Licence: CC BY 4.0 — attribute euornot.eu

Summary: Regulation (EU) 2025/40 applies from 12 August 2026. It harmonises packaging design and documentation across the EU — and leaves registration and fees national, which is where the cost lands for cross-border sellers.

Key dates:
- 22 Jan 2025: Published in the Official Journal
- 11 Feb 2025: Entry into force
- 12 Aug 2026: General date of application (Article 71)

**Update, 14 August 2026.** The Commission has pointed small sellers to its December 2025
proposal to suspend the authorised representative obligation until 2035. The proposal is
pending, and covers producers established in the EU only — Article 45(3) below applies
unchanged in the meantime.
[What the proposal does and does not do](/commission-authorised-representative-suspension/).

The Packaging and Packaging Waste Regulation, formally Regulation (EU) 2025/40,
replaces Directive 94/62/EC and begins to apply today, 12 August 2026. The
substitution of a regulation for a directive is the operative legal fact. A
directive requires transposition into national statutes and produces 27 variants.
A regulation applies directly, in identical text, with no national step in between.

The instrument was published in the Official Journal on 22 January 2025 and entered
into force on 11 February 2025. Article 71 set the general date of application
eighteen months later. It also amends Regulation (EU) 2019/1020 on market
surveillance and Directive (EU) 2019/904 on single-use plastics.

## Harmonised text, national money

Harmonisation covers design, substance limits and documentation. It does not cover
the money. Registration and fees stay national, administered by national registers
and national producer responsibility organisations. That split produces the
arithmetic in the merchant's notice.

Article 44 requires a producer to register in every member state where it first
makes packaging or packaged products available. The same article bars a producer
from making covered packaging available in a member state where it, or its relevant
representative, is not registered. There is no single European licence. A Spanish
registration covers Spain and confers nothing in Germany, France or Italy. For a
direct-to-consumer seller shipping parcels across borders, the destination market
is where the packaging is first made available, which places the obligation in each
country a parcel reaches.

Article 45 assigns the second layer. Under Article 45(1), the producer carries the
cost of collection and recovery in the member state where the packaging is expected
to become waste. Article 45(3) requires a producer not established in the
destination state to appoint, by written mandate, an authorised representative for
extended producer responsibility there. One representative per member state. No
single window, and no equivalent of the value added tax one-stop shop. A seller
shipping to France, Germany and Italy needs three mandates, three sets of national
filings and three fee relationships.

## What the split costs

The fixed cost of compliance therefore scales with the number of destination
markets, not with volume. A seller with modest revenue spread across ten member
states carries ten registrations, ten mandates and ten reporting cycles; a seller
with the same revenue concentrated in one carries one. Small cross-border sellers
pay the highest per-parcel compliance cost in the system, which is the opposite of
the outcome a single market is meant to produce.

Two things follow for anyone shipping into the EU today:

- **Registration precedes sale, not follows it.** Article 44 makes an unregistered
  making-available unlawful. Backfilling registration after the first shipment does
  not cure the breach.
- **Marketplaces are now a checkpoint.** Online platform providers must obtain and
  assess producer registration and EPR information before listing. Missing
  registrations surface as delisting long before they surface as enforcement.

## What is still open

Enforcement capacity is national and uneven, and several implementing and delegated
acts under the Regulation — including harmonised labelling specifications and
recyclability performance grades — arrive after today's date of application. The
obligations that bite immediately are the registration, representation and
fee obligations above, because they exist in the base text and need no further act.

The direction of travel is consistent with everything else moving through Brussels
right now: harmonise the rulebook at EU level, keep the collection machinery
national, and place liability on the seller rather than the buyer. The same pattern
governs the [customs reform that removed the €150 duty relief](/eu-de-minimis-ends-3-euro-flat-duty/)
and the [EU Customs Data Hub arriving in 2028](/eu-customs-data-hub-2028/).

## Sources

- Regulation (EU) 2025/40 on packaging and packaging waste, OJ L, 22.1.2025: https://eur-lex.europa.eu/eli/reg/2025/40/oj — legal text, Articles 44, 45 and 71
- European Commission — packaging waste policy: https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste_en