The Big Picture

The Packaging and Packaging Waste Regulation (PPWR) takes effect on August 12, 2026 across all 27 EU member states. Unlike a Directive, which each country must transpose into national law, the PPWR is a Regulation — it applies directly and uniformly in every member state with no room for national variation.

The European Commission categorically rejected the industry's "Stop the Clock" petition, signed by more than 500 companies asking for a 24-month delay. There will be no grace period and no national exceptions.

Key obligations from August 12, 2026:
  • Producer registration in national packaging registers
  • Declaration of Conformity for all packaging
  • PFAS ban on food-contact packaging

What Amazon Requires

Warning: Amazon enforces August 12, 2026 as a hard deadline — no indication they will move it.

Country-by-Country Status

Below is the current EPR registration status in key European markets. Status colors: green = normal processing, orange = slow or restricted, red = delayed or severe backlog.

Germany

Normal

Registration via LUCID within standard timeframes. However, VerpackG is being replaced by VerpackDG from August 12. B2B packaging now also falls under EPR. Existing systems must prove compliance by January 1, 2027.

France

Normal

Registrations proceeding normally. Separate development: Professional/commercial packaging EPR postponed to January 1, 2027. Consumer EPR via Citeo/Léko unchanged.

Italy

Delayed

National packaging EPR registry has NOT yet opened. Amazon confirmed sellers cannot register yet and absence of a number does NOT affect selling ability currently. No timeline announced.

Spain

Slow

Extended apostille timelines combined with summer holidays. Lead time: 1–2 months (with existing VAT + apostille), 2–3 months (VAT but no apostille), 3–5 months (neither). DRS (deposit return system) postponed from November 2026 to 2029.

Netherlands

Restricted

Dutch PRO (Verpact) currently completing registrations for EU-established companies ONLY. Non-EU company registrations suspended pending procedure harmonization with platforms.

Belgium

Backlog

Over 11,000 applications received. System upgrades underway. Most clients receiving temporary membership numbers first, formal numbers to follow.

Poland

Severe Delays

BDO authority on rotating summer leave (mid-June to late August). Backlog exceeds 15,000 applications. Priority order: Polish companies, then EU companies, then non-EU companies. Timelines up to 5–6 months possible.

Sweden

Summer Closure

Applications before June 20 processed normally. Authority closed July 13 – August 17. Expect 1–2 month additional delay after reopening.

Ireland

Slow

Authority currently processing applications from early March. Significant backlog expected through summer.

Denmark

Normal

EPR entered into force October 1, 2025 (one of the last EU countries). First compliance year runs through December 31, 2026.

Austria

Normal

Simplified flat-fee option available for very small volumes. Standard registration processing without significant delays.

Czech Republic

Normal

EKO-KOM system unchanged. PPWR will run in parallel with the existing national system.

United Kingdom

Delayed

Not EU, separate system. Data resubmission deadline moved to September 2026. Fee notices delayed. New RAG-based recyclability fee modulation from 2026–2027.

Other Major EPR Changes

EU Battery Regulation

Due diligence obligations for battery supply chains have been postponed from August 2025 to August 2027 under the Omnibus IV package. However, EPR obligations (registration, take-back, and reporting) remain unchanged on their original timeline.

Textile EPR

The revised Waste Framework Directive entered into force in October 2025. Member states must transpose it by June 2027 and have operational EPR schemes for textiles by April 2028. This is a completely new obligation — no EU-wide textile EPR existed before.

Germany: VerpackG to VerpackDG

From August 12, 2026, the new Packaging Implementation Act (VerpackDG) replaces the existing VerpackG. B2B packaging is brought under EPR for the first time. The LUCID register will be adapted to the new requirements. Existing authorized dual systems must demonstrate compliance by January 1, 2027. New B2B PROs must be authorized by November 1, 2027.

What You Should Do Now

Action items — do not wait:
  1. Check your EPR registration status in every country where you sell — not just Germany and France.
  2. Start registration immediately in countries with long processing times (Poland, Spain, Belgium).
  3. If you are a non-EU seller, appoint an Authorized Representative before August 12.
  4. Prepare your Declaration of Conformity for all packaging.
  5. Check if your food-contact packaging contains PFAS — the ban takes effect August 12.
  6. Do not wait for Italy's registry to open — prepare your documents now so you can register as soon as the system launches.

Need Help With Multi-Country EPR Registration?

ekoniq handles packaging EPR registration and compliance in 29 EU/EEA countries. We manage the entire process — from document preparation to registration and ongoing reporting. Contact us for a free compliance assessment.

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