PPWR Update, October 2026: What Moved Between 28 September and 21 October
What Changed for the PPWR Between 28 September and 21 October 2026?
Between 28 September and 21 October 2026, the European Parliament voted on the proposal suspending the Article 45(3) authorised-representative obligation, Austria asked the Council for a de minimis exemption, the Commission published two pages for small businesses, and no implementing act under Regulation (EU) 2025/40 was adopted. Six Member States moved on national packaging rules.
PPWR Update is a dated monthly digest for brands, importers, converters and distributors. This second issue covers 28 September to 21 October 2026 and follows the September 2026 issue; press reports are named as such.
Key Facts
- On 20 October 2026, Parliament voted on report A10-0266/2026 on the suspension of the EPR authorised-representative rules by 616 votes to 9, with 39 abstentions, according to HowTheyVote.eu.
- On 12 October 2026, Austria, supported by Czechia and Estonia, asked the Environment Council for a de minimis exemption from registration and EPR obligations for EU-established producers, in Council note 14126/26.
- On 19 October 2026, the Commission published the factsheet PPWR and small businesses: What do I need to know?.
- The Article 12(6) implementing acts were due by 12 August 2026 and have not been adopted.
- The draft producer-register format under Article 44(14) shows 7,438 contributions and no adoption on the Commission portal on 21 October 2026.
What Did the European Parliament Vote on 20 October 2026?
On 20 October 2026, the European Parliament voted on report A10-0266/2026 on Commission proposal COM(2025) 982, which would suspend the application of Article 45(3) of Regulation (EU) 2025/40 on the EPR authorised representative. The Legislative Observatory records the vote under procedure 2025/0395(COD); the adopted text was not published when this issue was written.
An authorised representative for the extended producer responsibility is the person that a producer referred to in Article 3(1), point (15)(c) and (d), appoints by written mandate in each Member State where it first makes packaging available, other than its Member State of establishment, under Article 45(3). That obligation has applied since 12 August 2026, and no amending act has been published. The companion report A10-0267/2026, procedure 2025/0396(COD), passed the same day by 612 votes to 8, with 39 abstentions, according to HowTheyVote.eu.
According to EUWID Recycling on 6 October 2026, the ENVI committee limited the exemption to micro and small enterprises with fewer than 50 employees, where the Commission had proposed it for all EU-based producers; we could not read whether the plenary kept that limit. No Council mandate was published by 21 October 2026, so no trilogue has started. Our article on the authorised representative before the Parliament vote sets out the committee positions.
The chemicals omnibus, procedure 2025/0531(COD), has its plenary debate and vote on the text agreed in interinstitutional negotiations scheduled for 22 October 2026; it was not yet voted when this issue was written.
What Did the Council and the European Council Say in October 2026?
At the Environment Council of 12 October 2026, Austria, supported by Czechia and Estonia, raised a proportionate EPR framework for small producers under the PPWR, and Italy raised a stable EU market for secondary plastic raw materials. Both were any-other-business items, and the Council adopted no conclusions on packaging.
Council note 14126/26 of 9 October 2026 states that Article 45(1) attaches EPR obligations to any quantity of packaging placed on the market, without any volume-based de minimis exemption. The note asks for a de minimis exemption, a flat-rate EPR contribution above it, a single EU entry point for EPR registration, and a stop the clock on Article 45(3), and asks that the registration implementing act wait for that entry point.
In Council note 14077/26, Italy suggests possible milestones towards the PPWR recycled content targets. The European Council conclusions of 16 October 2026 call for advancing negotiations on the environmental simplification package and name fragmented labelling and packaging requirements among Single Market barriers; they do not name Regulation (EU) 2025/40.
What Did the Commission Publish for Small Businesses on 19 October 2026?
On 19 October 2026, the Commission published the factsheet PPWR and small businesses: What do I need to know?, reference KH-01-26-088-EN-N, alongside a page on EPR for packaging for small businesses. Neither Commission document is law; both set out how the Commission reads the rules for small producers.
The factsheet states that the declaration of conformity "only needs to cover the PPWR's requirements on substances of concern", naming the limits on lead, cadmium, mercury and hexavalent chromium of Article 5(4) and the PFAS limits for food-contact packaging. Under Article 5(5), food-contact packaging containing PFAS above the thresholds has been prohibited from being placed on the market since 12 August 2026. On marking, the factsheet states that "there is no need to re-package or destroy packaging already produced, if it does not have these markings".
On the authorised representative, the EPR page states that "since August 2026 the requirement applies to all Member States" and that the Commission has called on Member States to enforce the obligation "in a constructive and pragmatic way and abstain from sanctioning operators" while the proposal is examined. The page also recalls the flexibilities for producers below 10 tonnes; under Article 44(8), such a producer submits the information of Part B, point 2, of Annex IX by 1 June each year. Our guide to packaging EPR and distance selling covers who is the producer in each Member State.
Where Do the PPWR Implementing and Delegated Acts Stand on 21 October 2026?
On 21 October 2026, no implementing or delegated act under Regulation (EU) 2025/40 had been adopted since the September issue. The Commission portal lists the harmonised-label decision and three recycled-content acts for adoption in the fourth quarter of 2026, and shows the producer-register format as a draft with 7,438 contributions.
| Act | PPWR basis | Status on the Commission portal, 21 October 2026 |
|---|---|---|
| Producer-register format, Ares(2026)7688068 | Article 44(14), format of registration and reporting | Draft published 6 August 2026; feedback closed 10 September 2026; 7,438 contributions; not adopted |
| Harmonised labels, implementing decision | Article 12(6), due by 12 August 2026 | Planning entry of 14 September 2026; no draft; adoption planned for the fourth quarter of 2026 |
| Calculation and verification of recycled content, initiative 18753 | Article 7(8), by 31 December 2026 | Planning entry of 14 July 2026; no draft; adoption planned for the fourth quarter of 2026 |
| Sustainability criteria for plastic recycling technologies, initiative 19033 | Article 7(9), delegated act, by 31 December 2026 | Call for evidence closed 16 September 2026, 82 contributions; adoption planned for the fourth quarter of 2026 |
| Conditions for importing recycled materials, initiative 18752 | Article 7(10), by 31 December 2026 | Planning entry of 14 July 2026; no draft; adoption planned for the fourth quarter of 2026 |
The harmonised label becomes mandatory from 12 August 2028, or 24 months after the Article 12(6) or 12(7) implementing acts enter into force, whichever is the latest. Under Article 44(1), each Member State establishes its national register within 18 months of the entry into force of the first implementing act adopted under Article 44(14), so the register clock has not started. Our article on the draft producer-register format reads the draft itself.
Separately, the Commission opened a call for evidence from 28 September to 26 October 2026 on its early warning report on waste 2027. Under Article 41, the Commission draws up such reports with the European Environment Agency at the latest three years before each deadline of Articles 43 and 52.
What Moved at National Level in October 2026?
Six Member States moved between 28 September and 21 October 2026. Italy converted Decree-Law No 143 on compostable packaging into law, France dropped its draft household-packaging EPR specifications, Germany postponed its draft plastic packaging tax, and the Netherlands, Belgium and Spain follow below.
| Country | Measure | Date | Status | Source |
|---|---|---|---|---|
| Italy | Law No 173 of 5 October 2026 converting, with amendments, Decree-Law No 143 of 7 August 2026 on mandatory compostability of certain packaging types | Gazzetta Ufficiale No 232 of 6 October 2026 | Law | Gazzetta Ufficiale |
| France | The government dropped its draft specifications reforming household-packaging EPR; local authorities may sign performance contracts with the eco-organisations on a voluntary basis | Announced 30 September 2026 in Nantes | Announcement | According to Actu-Environnement; Citeo release of 8 October 2026 |
| Germany | VerpackDG, replacing the Verpackungsgesetz, has had effect since 12 August 2026; the draft plastic packaging tax is dated 30 September 2026, and the planned cabinet decision on that draft was postponed | Reported 19 October 2026 | Law in force; tax still a draft | Federal Environment Ministry; according to Kleeberg |
| Netherlands | Verpact 2027 tariffs: an additional incentive for recycled plastic from Europe, a separate tariff for plastic drinks bottles without a deposit, higher tariffs for drinks cartons, aluminium and deposit packaging | Published 28 September 2026; from 1 January 2027 | Scheme decision | Verpact |
| Belgium | Fost Plus states that the Green Dot logo may no longer be used on packaging as of 12 February 2027 and has discontinued its licence | 12 February 2027 | Scheme decision | Fost Plus |
| Spain | Deposit, return and refund system: operator applications still pending before the Community of Madrid, no authorisation granted | 25 September 2026 | Pending | According to FoodRetail |
Scheme tariffs are reported here by structure only, never by amount.
What Moved Outside the EU and in Neighbouring Rules?
Outside the EU, PackUK published its first annual report on 30 September 2026, and Minnesota takes comments on its draft needs assessment through 13 November 2026. In neighbouring rules, ECHA's Committee for Risk Assessment recommends classifying trifluoroacetic acid as toxic to reproduction, according to LexisNexis.
- United Kingdom, 30 September 2026. The PackUK annual report states that the 2025 to 2026 financial year was the first full year of operation for the scheme and that RAM 2027 was published on 1 July 2026.
- United States, Minnesota. The draft needs assessment feeds the state's packaging EPR programme.
- Chemicals. According to LexisNexis on 6 October 2026, ECHA's Committee for Risk Assessment adopted on 5 June 2026 opinions recommending that trifluoroacetic acid be classified as toxic to reproduction, category 1B. A CLP classification is not a PPWR rule.
What Is New in PPWR Connect and the Academy?
PPWR Connect publishes a dated list of what shipped, and three entries from 3 to 15 October 2026 bear on this digest: an action center that works as a to-do list, company invoices on subscriptions, and a new Academy course on substances and supplier data, each with its date.
- 15 October 2026. The action center groups actions by packaging, filters them by type and priority, and Mark done records who did it and when.
- 13 October 2026. The payment page asks for the company name, billing address and VAT number, and each invoice is issued in the company's name.
- 3 October 2026. The Academy course "Substances & Supplier Data" covers what a brand must ask and what a supplier must provide under Article 16 and the Article 5 limits. The course costs €89 and is included in the Academy Pass. The Academy Pass is €349.
Which Dates Should Packaging Teams Watch Before the November Issue?
Five events on four dates fall before the November issue. On 22 October 2026, Parliament is scheduled to vote on the chemicals omnibus and Eurostat plans a data update. On 26 October, the early warning report consultation closes. On 11 November, the Commission plans to present the Circular Economy Act, according to EUWID. On 13 November, Minnesota comments close.
According to EUWID Recycling on 6 October 2026, the Circular Economy Act proposal is expected to include measures to harmonise EPR systems. National penalty rules remain due by 12 February 2027 under Article 68; see our article on grace periods and enforcement.
What Does the Referential Not Confirm?
Our dated PPWR referential (baseline reviewed 3 October 2026) confirms three statements here: the overdue Article 12(6) implementing acts, the 2028 date of the harmonised label, and the Article 5(5) PFAS prohibition, but not the points below.
- Articles 5(4), 7(8), 7(9), 7(10), 12(7), 41, 44(1), 44(8), 44(14), 45(3) and 68 as phrased here, read on the Official Journal text, not recorded in our referential.
- The Parliament vote counts, which rest on HowTheyVote.eu, a non-official site, while the Legislative Observatory records the vote without figures; the committee limit, which rests on EUWID; and the adopted text, which we could not read.
- Every item outside the Regulation, read on the cited page on 21 October 2026; nothing here is legal advice.
Frequently Asked Questions
Is the EPR authorised-representative obligation suspended after the vote of 20 October 2026?
No. Article 45(3) of Regulation (EU) 2025/40 has applied since 12 August 2026. A suspension needs an act adopted by Parliament and Council and published in the Official Journal, and none exists on 21 October 2026.
Is there a de minimis threshold in the PPWR for packaging EPR?
No volume-based exemption exists, as Council note 14126/26 states. Article 44(8) sets a simplified report for producers below 10 tonnes per calendar year in a Member State, not an exemption.
How PPWR Connect Helps
PPWR Connect is software: it is not a legal adviser, a producer responsibility organisation or an authorised representative. The EPR declaration engine (XLSX/CSV) is included in the Professional and Enterprise plans, and since 15 October 2026 the action center groups actions by packaging. To see which October changes touch your packaging, start with our PPWR compliance software or the PPWR readiness assessment.
Published by
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.