The European Commission has proposed new harmonised registration and reporting formats for packaging producers under the Packaging and Packaging Waste Regulation (PPWR – Regulation (EU) 2025/40).
The draft implementing rules aim to standardise producer registration, Extended Producer Responsibility (EPR) information and packaging data reporting across the European Union, making compliance information more consistent, digital and comparable.
The PPWR entered into force on 11 February 2025, and most of its provisions became applicable from 12 August 2026.
PPWR Producer Registration Requirements
Annex I of the draft establishes a harmonized structure for information to be submitted to national producer registers.
Producers, Producer Responsibility Organisations (PROs) and, where applicable, authorized representatives would be required to provide the following information:
| Section | Content |
| Part A | Basic producer information, including name, legal form, address, tax/VAT number, brand names and contact details. |
| Part B | Description of how Extended Producer Responsibility (EPR) obligations are fulfilled, either individually or through a PRO, supported by authorisation documents. |
| Part C | Certificate of compliance issued by the relevant PRO. |
| Part D | Authorised representative information for non-EU producers |
Digital Producer Registration Under PPWR
Digitalisation is a key element of the proposed registration system.
Under the draft framework:
- Information would be submitted electronically.
- Registration systems would support automated data processing and batch verification.
- Separate registration may be required where more than one packaging waste management system operates within a Member State.
The harmonised approach is intended to reduce differences between national producer registers and improve the comparability and verification of packaging compliance data across the EU.
PPWR Reporting Requirements
Annex II establishes annual reporting requirements covering packaging placed on the market and packaging waste management.
The level of reporting detail would depend partly on the amount of packaging a producer places on the market each year.
| Section | Applicability | Reporting Content |
| Part A | Producers placing ≥10 tonnes/year | Detailed weight reporting by packaging material categories such as glass, paper/cardboard, metals, plastics, wood, textiles and others. |
| Part B | Producers placing <10 tonnes/year | Simplified reporting using broader material categories. |
| Part C | All relevant parties | Quantity of separately collected single-use plastic beverage bottles and metal beverage containers. |
| Part D | All relevant parties | Quantity of 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. |
How Will Composite Packaging Be Reported?
The proposed rules also address the reporting of composite packaging made from multiple materials.
Composite packaging would generally be classified according to its predominant material by weight. However, the weight of each constituent material would also need to be reported.
Companies may therefore need more granular packaging composition data rather than relying solely on total packaging weight.
Technical Documentation and Digital Product Passports
Packaging data used for reporting would need to be supported by technical documentation or an equivalent detailed product description.
Where a Digital Product Passport (DPP) is available, relevant information contained in the passport may also be used for producer registration purposes.
This could support greater interoperability between PPWR compliance information and other digital product information systems.
What Does This Mean for Non-EU Producers?
The proposed registration framework is particularly relevant for companies established outside the European Union that place packaged products on the EU market.
Where applicable, non-EU producers will need to review their authorised representative arrangements, EPR responsibilities and producer registration obligations in each Member State where they operate.
Companies selling into several EU markets should therefore assess packaging volumes and compliance obligations on a country-by-country basis.
How Should Companies Prepare for PPWR Registration and Reporting?
With the PPWR now in its application phase, businesses should begin reviewing whether their packaging data and compliance systems can support the more harmonised registration and reporting framework. The European Commission is continuing to develop implementing measures and guidance to support PPWR implementation.
Key preparation steps include:
- Mapping packaging volumes by EU Member State,
- Classifying packaging by material category,
- Reviewing EPR and PRO arrangements,
- Verifying producer registration information,
- Assessing authorised representative requirements for non-EU businesses,
- Reviewing technical documentation supporting packaging data, and
- Establishing processes for annual PPWR reporting.
The harmonised system is expected to make PPWR producer registration, EPR compliance and packaging reporting more structured across the EU. Companies placing packaged products on the European market should therefore ensure that their packaging data and compliance processes are ready for the evolving PPWR framework.