Question 1

We already have a national packaging registration. Is that enough?

Accepted Answer

It may still be the register you use, but the position needs checking per country. The Article 44(14) act defining the EU register format was due 12 February 2026 and has not been adopted, so the clock for Member States to build PPWR registers has not started. Several countries continue to run registers inherited from the directive era. The platform records, per Member State, whether a register exists, on what legal basis, and what format applies.

Question 2

Does PPWR apply to us if we manufacture outside the EU?

Accepted Answer

If packaging is placed on the EU market under your name or trademark, Article 3(1)(13)(a) makes you a manufacturer, with the technical file and the declaration of conformity as your responsibility. It does not make you a producer: that role belongs to whoever first makes the packaging available inside a Member State, so registration and extended producer responsibility usually fall to your EU importer. You may appoint an authorised representative under Article 17, but drawing up the technical file cannot be delegated.

PPWR producer registration

FAQs

Keep reading