PPWR in the 27 Member States: National Packaging Laws, Registers, Deposit Systems and Authorities

The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, applies directly in all 27 member states since 12 August 2026, but each member state keeps its own producer register, competent authority, penalty rules and deposit system, so packaging EPR still runs country by country. Published in OJ L, 2025/40, 22.1.2025, it entered into force on 11 February 2025 (Art. 71).

The obligations of the Packaging and Packaging Waste Regulation (PPWR) are the same in every member state, because the Regulation is binding in its entirety and directly applicable. The procedures are not: a producer registers in each member state where it first makes packaging available (Art. 44(2)) and may not make packaging available there without that registration (Art. 44(4)).

This page lists each state's packaging act and register, the four verified adaptation acts, the three pending bills, the deposit systems and the deadlines for authorities and penalties.

Compiled by the PackagingRegulation.org Editorial Team from the Regulation's text on EUR-Lex and the cited official sources. Every national act and date is checked against the national gazette or authority; see our methodology and fact-checking. As of 24 October 2026.

Why Do National Packaging Rules Still Apply under the PPWR?

National packaging rules still apply because the PPWR itself assigns four tasks to the member states: keeping the producer register, designating competent authorities, laying down penalties and setting up deposit return systems. The four national tasks are listed below.

• Producer register: one register in each member state, where the producer registers before it first makes packaging available there (Art. 44(2) and (4) PPWR).
• Competent authorities: designated and notified to the Commission by 12 July 2025 (Art. 40(3) PPWR).
• Penalties: laid down and notified by 12 February 2027; the Regulation sets no fine amount (Art. 68 PPWR).
• Deposit return systems: in place by 1 January 2029 for single-use plastic bottles and metal beverage containers up to 3 litres (Art. 50(1) PPWR).

Does every member state need its own PPWR law?

No: Regulation (EU) 2025/40 is binding in its entirety and directly applicable in all member states (Art. 71), so its obligations apply since 12 August 2026 whether or not a national act exists. Czechia shows how this works: its packaging act, Act No. 477/2001 Sb., in force since 1 January 2002, still applies cumulatively with the PPWR, and the Czech adaptation amendment is not adopted as of 24 October 2026.

Packaging EPR by Country: National Acts and Producer Registers in the 27 Member States

A producer meets a different register and national act in each member state where it first makes packaging available, because Article 44 of the PPWR sets one register per member state. The table gives, for each state, the national packaging act in force and the body that keeps the producer register, as of 24 October 2026. Germany and France have full country pages: PPWR in Germany covers the VerpackDG and the LUCID packaging register, and PPWR in France covers the French AGEC law, the SYDEREP register and Triman, the French sorting label. Each other row leads to its country page, from PPWR in Austria to PPWR in Sweden. The annual report under Art. 44(7) is due by 1 June for the preceding calendar year in each member state.

Which Member States Have Adopted a National Implementing or Adaptation Act?

As of 24 October 2026 four member states have a verified national act in force that adapts their law to the PPWR: Germany (VerpackDG, since 12 August 2026), Finland (Decree 534/2026 and Act 648/2026, since 12 August 2026), Denmark (BEK nr 851 af 28/09/2026, since 15 October 2026) and Ireland (S.I. No. 541/2025, competent authorities only). In Germany the VerpackG expired at the end of 11 August 2026. Denmark's order repealed BEK nr 1146 af 29/09/2025, and the Irish regulations, in force since 6 November 2025, designate the EPA, the Minister and local authorities without creating penalties.

Austria, Cyprus, Hungary, Malta, the Netherlands, Slovenia and Spain have no implementing act identified as of 24 October 2026. In Hungary, Decree 80/2023 in its version of 12 August 2026 contains no reference to the PPWR. In Spain the Cortes were dissolved on 6 October 2026, so no adaptation law can pass before the new Cortes sit.

For the other member states, the national packaging acts in force are listed in the table above.

What is still pending in the member states on 24 October 2026?

Three national adaptation bills are pending as of 24 October 2026: the Czech adaptation amendment of Act No. 477/2001 Sb., Luxembourg bill n° 8482 and the Polish draft act UC100. Their stages are listed below.

• Czechia: the adaptation amendment of the packaging act is not adopted; Act No. 477/2001 Sb. applies cumulatively with the PPWR until then.
• Luxembourg: bill n° 8482 is in committee, after a second complementary opinion of the Conseil d'État on 14 October 2026.
• Poland: UC100 is at the government stage, discussed by the Committee for European Affairs on 9 September 2026; it is not adopted by the Council of Ministers and not in the Sejm.

Changes to these national bills are tracked in PPWR news.

Deposit Return Systems in the Member States

Article 50(1) of the PPWR requires every member state to run a deposit return system for single-use plastic bottles and metal beverage containers up to 3 litres by 1 January 2029, aiming at 90 % separate collection, unless it qualifies for the Art. 50(5) exemption. Seventeen member states run a system as of 24 October 2026, as the table shows.

The exemption under Art. 50(5) needs at least 80 % separate collection in calendar year 2026, plus a request and an implementation plan submitted by 1 January 2028. A state without a system, such as Czechia, stays outside the deposit duty only on that route. Case T-197/25, brought on 21 March 2025 by five Czech waste-sector applicants, not by the Czech Republic, seeks the annulment of Art. 50(1) to (7) and (9) to (12) and is pending. The scope, the 90 % target and the exemption are explained in deposit return systems under the PPWR.

Competent Authorities and National Penalty Rules

Each member state had to notify its PPWR competent authorities to the Commission by 12 July 2025 (Art. 40(3)), and must lay down and notify its penalty rules by 12 February 2027 (Art. 68). The authorities cover Chapter VIII of the Regulation plus Art. 6(10), Art. 29(1) to (7) and (9) and Art. 30 to 34 (Art. 40(1)). National sources name them: in France the DGPR of the Ministère de la Transition écologique, in Ireland the EPA, the Minister and local authorities, in Finland Lupa- ja valvontavirasto for producer responsibility and Tukes for market surveillance, and in Belgium EPRiBEL for the EPR part and the register.

The PPWR sets no fine amount, so every penalty comes from national law. In Germany the VerpackDG has been in force since 12 August 2026, while its fines for PPWR breaches under § 66(2) apply only from 12 February 2027 (§ 68(17)). The Art. 68 deadline and the enforcement side are explained in PPWR penalties and market surveillance.

Selling Packaging in Several Member States

A producer that first makes packaging available in several member states registers and reports in each of them, and since 12 August 2026 a producer selling directly to end users in a member state where it is not established appoints an authorised representative for EPR there (Art. 44, Art. 45(3) PPWR). It covers producers under Art. 3(1)(15)(c) and (d), by written mandate; member states may extend it to third-country producers (Art. 45(3), second sentence).

Three national rules sit beside Art. 45(3). Germany requires a representative for producers without a German establishment under VerpackDG § 5(2), since 12 August 2026. Spain requires one for producers established in another member state or a third country under Art. 17(2) of RD 1055/2022. Malta requires distance sellers to consumers established elsewhere to appoint a Malta-established representative under reg. 21(8) of S.L. 549.43. The Commission proposal COM(2025) 982 of 10 December 2025 would suspend Art. 45(3); the European Parliament adopted amendments on 20 October 2026 and referred the file back to the ENVI committee, according to the Legislative Observatory. Nothing is suspended as of 24 October 2026, and the mandate rules are set out under authorised representative for EPR.

Is there one EU-wide producer register?

No: the PPWR keeps national registers, and the Art. 44(14) implementing act on a harmonised register format was due 12 February 2026 and is not adopted as of 24 October 2026; a draft has been published for feedback. Until it applies, each national register keeps its own format.

Register data and the 1 June report are covered in PPWR producer registration and reporting.

The registers move to the harmonised format within 18 months of the entry into force of the first Art. 44(14) act (Art. 44(1)), so no fixed date can be given.

The register-format act is one of the overdue PPWR delegated acts and implementing acts.

How Do the National Rules Connect to the Rest of the PPWR?

The national layer sits on top of the PPWR legal text and timeline, packaging EPR, EU packaging waste and PPWR compliance, and the PPWR labelling requirements that will replace national sorting labels. National labels may not be kept beside the EU labels after 12 August 2028 or 24 months after the Art. 12 implementing act, whichever is later, according to Commission Notice C/2026/3084 (OJ C, 10.6.2026).

This page covers the 27 EU member states only; rules for UK and other third-country sellers are in PPWR for non-EU exporters.

PPWR member state questions answered

Is PRO membership mandatory in any member state?

Yes, in some: the PPWR leaves PRO membership optional but lets a member state make it mandatory (Art. 46(1)). Malta requires membership under S.L. 549.43, except for transport packaging and refillable gas cylinders (reg. 16(2)). In Hungary, MOHU fulfils packaging EPR collectively by law under the Waste Act (Act CLXXXV of 2012, § 53/A(4)). Latvia requires PRO membership from 300 kg of used packaging per year, a national rule.

How early must a producer register in a member state?

Before the first sale: the PPWR forbids making packaging available without registration (Art. 44(4)), and a register issues the number within 12 weeks of a complete application (Art. 44(11)(b)). National rules add their own timing. Denmark requires registration at the latest 14 days before first making packaging available (BEK 851/2026 § 15), Hungary before starting the activity (Decree 80/2023 § 23(1)), and Slovenia within 30 days of starting activity.

Does every member state already run a public producer register?

No: Belgium's EPRiBEL register is under development, Ireland has no PPWR register yet and the Netherlands has no public register, as of 24 October 2026. Italian packaging producers join CONAI under D.Lgs. 152/2006 Art. 221, and RENAP covers electrical equipment, batteries and tyres only. In Poland the BDO registration covers Poland only.