The EU's Draft Producer-Register Format: What Every Packaging Producer Would Declare
What Changed for Packaging Producer Registers in August and September 2026?
On 6 August 2026, the European Commission published for feedback a draft implementing regulation, Ares(2026)7688068, that sets one format for registration in, and reporting to, the national registers of producers under Article 44(14) of Regulation (EU) 2025/40. Feedback closed on 10 September 2026 with 7,438 contributions. On 8 October 2026, the Commission's portal listed no adopted act.
This article covers what is new since our guide to producer registration across EU markets: the fields the draft proposes, the calendar it would start, and what it means for brands, importers, distributors and distance sellers active in several Member States, the subject of seven customer questions in 30 days, the last on 10 September 2026. Everything attributed to the draft is a proposal, not law.
Key Facts
- Under Article 44(14), the Commission adopts implementing acts establishing the format for registration in, and reporting to, the register; the Regulation gave it until 12 February 2026.
- Draft Ares(2026)7688068 was open for feedback from 6 August to 10 September 2026 and drew 7,438 contributions, according to the Commission's Have your say portal.
- Under Article 44(1), each Member State establishes its national register within 18 months of the date of entry into force of the first implementing act adopted under Article 44(14).
- Under Article 44(7) and 44(8), producers report by 1 June for each full preceding calendar year, in a simplified form when they made available less than 10 tonnes of packaging in that Member State.
- Our dated PPWR referential (baseline reviewed 3 October 2026) vouches none of these lines; see "What does the referential not confirm?".
What Did the European Commission Publish on 6 August 2026?
On 6 August 2026, the European Commission published draft implementing regulation Ares(2026)7688068 on the format for registration in, and reporting to, the register of producers under Regulation (EU) 2025/40. The draft has three articles and two annexes. Feedback ran until 10 September 2026, and the draft states that it has not been adopted or endorsed by the Commission.
Annex I of the draft sets the registration format in four parts, and Annex II sets the reporting format in six parts. The Have your say portal lists an adoption planned for the first quarter of 2026, a period that has passed, and on 8 October 2026 it showed no adoption date.
An implementing regulation is a Commission act that lays down uniform conditions for applying an EU regulation. Under Article 44(14), this one is adopted by the examination procedure referred to in Article 65(2). Our digest PPWR Update, September 2026 lists the other pending acts.
What Does Article 44(14) of Regulation (EU) 2025/40 Ask the Format to Do?
Article 44(14) of Regulation (EU) 2025/40 asks the Commission to establish the format for registration in, and reporting to, the register of producers, and to specify the granularity of data, the packaging types and the material categories covered. The format must be interoperable, based on open standards and machine-readable data, and transferable without vendor lock-in.
Recital 126 gives the reason: producer registration requirements should be harmonised across the Union to the greatest extent possible, given that producers make packaging available in different Member States. Recital 1 of the draft gives the same reason, to avoid divergent formats.
The draft names no technical standard or file format. Its Article 1(3) requires electronic submission via a data processing system that allows for a fully automated process and supports bulk verification of registration numbers.
What Would a Producer Declare When It Registers?
Under Annex I of draft implementing regulation Ares(2026)7688068, a producer registering in a Member State would declare its identity and contacts, its brand names, its tax and national identification numbers, how it meets its extended producer responsibility, and, where relevant, its producer responsibility organisation and its authorised representative. Each field is marked mandatory, filter-dependent or optional.
| Part of draft Annex I | What it covers | Fields named in the draft (examples) |
|---|---|---|
| Part A | Registration of a producer | Name, legal or natural person, e-mail, phone and web address if available, brand names, legal address, European or national tax identification number, national identification code, contact person, registration number of the authorised representative |
| Part B | Declaration on how the producer meets its responsibilities under Article 45 | Individual or collective fulfilment; for collective fulfilment, the producer responsibility organisation; a declaration that the information is accurate |
| Part C | Certificate of the producer responsibility organisation, where Article 46(1) applies | Member State, registration number, name of the organisation, contract period |
| Part D | Registration of an authorised representative | Identity and address in the Member State, national tax number, name and registration number of the producer represented |
Fields marked with an asterisk in the draft would form the list of registered producers that Article 44(13) requires to be easily accessible, publicly available and free of charge. In Part A, those fields are the producer's name, brand names, tax identification number and national identification code.
Annex IX, Part A, of the Regulation already lists most of this content: name and brand names, address, a national identification code with a trade register number and a tax identification number, and a declaration on how the producer meets its responsibilities under Article 45. The draft turns that list into fields with a fixed status. Under Article 1(2) of the draft, a producer in more than one separate packaging waste system of a Member State would register the packaging covered by each system separately in Parts B and C.
What Would the Annual Report Contain?
Under Annex II of draft implementing regulation Ares(2026)7688068, a producer making 10 tonnes or more of packaging available in a Member State in a year would report tonnes per packaging category, with the weight of each constituent material. Below 10 tonnes, a simplified table groups the categories. Further parts cover collected, recycled, recovered and disposed packaging waste.
The categories of the draft follow the numbering of Table 1 of Annex II of the Regulation, from glass to ceramics, and add an "other" category. Sub-categories separate single-use beverage containers with a capacity of up to 3 litres. Each row carries columns for glass, paper and cardboard, ferrous metal, aluminium, plastic, wood and other.
Under Article 2(3) of the draft, packaging is reported on the basis of its predominant material, and the weight of all constituent materials is reported in the respective columns. Recital 8 of the draft adds that components separable from the main body of the packaging should be reported separately. Under Article 2(4), the report is based on the technical documentation drawn up in accordance with Annex VII, or on an equivalent complete description of the packaging unit.
| Item | Regulation (EU) 2025/40, Annex IX, Part B | Draft Ares(2026)7688068, Annex II |
|---|---|---|
| Report at 10 tonnes or more | Quantities by weight of the packaging categories of Table 1 of Annex II (point 1) | Part A: tonnes per category and beverage sub-category, with the weight of each constituent material |
| Report below 10 tonnes | Weight for glass, plastic, paper/cardboard, ferrous metal, aluminium, wood, other and total (point 2) | Part B: grouped categories, single-use beverage containers shown where relevant |
| Multi-material packaging | No rule in Annex IX | Predominant material, plus the weight of each constituent material; separable components reported separately |
| Basis of the figures | No rule in Annex IX | Annex VII technical documentation or an equivalent complete description |
| Packaging waste data | Collected, recycled, recovered and disposed quantities (point 3, Article 44(10)) | Parts C to F, submitted by the economic operator responsible for reporting on waste |
Our article on the Annex VII technical documentation describes the file the draft would use as the basis of the figures.
When Does the 18-Month Clock of Article 44(1) Start?
The 18-month period of Article 44(1) of Regulation (EU) 2025/40 starts on the date of entry into force of the first implementing act adopted under Article 44(14), not on 12 August 2026 and not on publication of the draft. Within those 18 months, each Member State establishes its national register. On 8 October 2026, no such act had been adopted.
Under Article 3 of the draft, the act would enter into force on the twentieth day following its publication in the Official Journal; the draft sets no separate date of application. The 18 months are a period for Member States to establish registers. No provision of Article 44 gives producers a later date for their own registration.
Article 71 applies the Regulation from 12 August 2026. Our referential records producer registration as due from 12 August 2026 in existing national registers. Under Article 44(4), a producer does not make packaging available for the first time in a Member State where it, or its authorised representative for the extended producer responsibility, is not registered. See also what applies now and what waits on a secondary act.
What Changes for a Producer Selling in Several Member States?
For a producer selling in several Member States, the draft format would keep one registration and one report per Member State under Article 44(2) of Regulation (EU) 2025/40, with the same fields, categories and units in each. One structured packaging dataset, by category and constituent material, could then feed every national register.
- Brand owners and manufacturers. Under Article 2(4) of the draft, the reported weights rest on the Annex VII technical documentation, so the weight of each material and of each separable component becomes reporting data as well as conformity data.
- Importers and authorised representatives. Part D of draft Annex I registers an authorised representative with the name and registration number of the producer it represents. Under Article 44(6), a representative of more than one producer already provides the name and contact details of each one, separately.
- Distributors. Under Article 19(2)(a), a distributor verifies, before making packaging available, that the producer subject to extended producer responsibility for it is registered in the register referred to in Article 44.
- Online platforms and distance sellers. Under Article 45(4), online platforms obtain the producer's registration number in the Member State where the consumer is located. Recital 11 of the draft says that this information can be verified in bulk.
Member States keep room to differ. Article 44(5) lets a Member State request additional information or documents; Article 44(8) lets it set a threshold lower than 10 tonnes for a specific calendar year; Article 44(9) lets it require quarterly reporting for budgetary reasons.
What Does the Draft Not Settle Yet?
Draft implementing regulation Ares(2026)7688068 does not settle its final wording, its adoption date or the date on which national registers switch to it. The draft names no technical standard and contains no definitions and no transitional rule for registrations already held. Its annexes may still change after the 7,438 feedback contributions received by 10 September 2026.
What Does the Referential Not Confirm?
Our dated PPWR referential (baseline reviewed 3 October 2026) confirms no regulatory statement in this article. Each point below is read on the linked Official Journal text or official Commission page.
- Article 44(1), (2), (4), (5), (6), (7), (8), (9), (10), (13) and (14), Annex IX, Parts A and B, Table 1 of Annex II, Article 19(2)(a), Article 45(4), Article 65, Article 71 and recital 126, as phrased here.
- The reading that no provision of Article 44 gives producers a later registration date than the Regulation's application date; the referential records producer registration as due from 12 August 2026 in existing national registers.
- Everything attributed to draft Ares(2026)7688068, read on the Have your say portal on 8 October 2026. The draft may change, and nothing here is legal advice.
Frequently Asked Questions
Would the draft create a single EU registration?
No. The draft sets a common format, and registration stays national. Under Article 44(2) of Regulation (EU) 2025/40, a producer registers in each Member State where it makes packaging available for the first time, and under Article 44(11) each competent authority grants the registration and provides a registration number.
Should a producer wait for the final format before registering?
No. Article 44(4) bars making packaging available for the first time in a Member State without registration there, and the Regulation has applied since 12 August 2026. The final format changes how information is submitted, not whether a producer registers.
How PPWR Connect Helps
PPWR Connect is software: it is not a producer responsibility organisation, an authorised representative or a legal adviser. Since 12 September 2026, a per-market obligation profile answers "who is the producer" per jurisdiction, and registrations, volumes and the EPR matrix follow the markets a SKU is sold in. Since 13 September 2026, EPR declarations record what they were computed from, with an input hash and references; since 24 August 2026, past declaration runs are kept and consultable instead of being overwritten by the next one. The EPR declaration engine (XLSX/CSV) is included in the Professional and Enterprise plans. The Academy offers the course "EPR in the EU: PPWR Rules and National Schemes". To check which markets and packaging data your registrations rest on, start with our PPWR compliance software or the PPWR readiness assessment.
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Rutherford (rutherford.fr) develops production control software for offset printers and converters, including ColorLoop. Veoria (veoria.com) develops inline colour measurement for label and packaging presses, including DeltaOne.