PPWR Update, September 2026: What Moved in the Six Weeks Since 12 August

What Changed for the PPWR Between 12 August and 28 September 2026?

Between 12 August and 28 September 2026, EUR-Lex listed a corrigendum to Regulation (EU) 2025/40 dated 18 September, for the Italian version. The implementing acts on producer registers and harmonised labels were still not adopted. The proposal to suspend the Article 45(3) authorised-representative obligation was still before Parliament, and on 24 September Poland asked the Council to resume work on the Commission's proposals of 10 December 2025. Neighbouring EU rules on claims, deforestation and recycled plastics moved.

PPWR Update is a dated monthly digest for brands, importers, converters and distributors; this first issue covers events up to 28 September 2026. Each item gives its date, its status (law, proposal, demand or consultation) and its official source.

Key Facts

• A corrigendum to Regulation (EU) 2025/40 dated 18 September 2026 is listed on EUR-Lex for the Italian version only.
• The Article 12(6) implementing acts were due by 12 August 2026 and have not been adopted.
• Under the Commission proposal COM(2025) 982, which is not law, the application of Article 45(3) would be suspended until 1 January 2035.
• Directive (EU) 2024/825 on empowering consumers has applied since 27 September 2026, according to the European Commission.
• Our dated PPWR referential (baseline reviewed 15 September 2026) confirms the second line only.

Has the Text of Regulation (EU) 2025/40 Changed Since 12 August 2026?

EUR-Lex lists a corrigendum to Regulation (EU) 2025/40 dated 18 September 2026, CELEX 32025R0040R(07), for the Italian version. No other corrigendum dated after 12 August 2026 was found on 23 September 2026. According to the Council draft, the Italian corrigendum replaces "consumatori" (consumers) with "utilizzatori finali" (end users) in Article 3(1)(15), point (c), and corrects point (d).

A corrigendum is a correction of errors in an act already published in the Official Journal. According to the same draft, point (d) of the Italian text now reads "direttamente agli utilizzatori finali", directly to end users. In English, Article 3(1)(15), points (c) and (d), makes a manufacturer, importer or distributor established in a Member State or in a third country the producer when it makes packaging or packaged products available for the first time in another Member State, directly to end users. Under Article 3(1)(23), an end user is a natural or legal person in the Union to whom a product is made available as a consumer or as a professional end user, and that does not make that product further available in the form supplied.

The Italian text of point (c) named consumers only, so the correction matters to distance sellers and non-EU suppliers that deliver directly to business customers in Italy. Our article on non-EU manufacturers and EU importers reads points (c) and (d) in full.

Where Do the PPWR Implementing Acts Stand?

Two implementing measures under Regulation (EU) 2025/40 moved on the Commission's Have your say portal, and neither is adopted. Feedback on the draft producer-register format under Article 44(14) closed on 10 September 2026. A harmonised-label implementing decision under Articles 12 and 13 was listed on 14 September 2026, for adoption planned in the fourth quarter of 2026.

Article 44(14) set 12 February 2026 as the Commission's deadline for implementing acts on the format for registration and reporting. The draft implementing regulation, Ares(2026)7688068, published for feedback on 6 August 2026, drew 7,438 contributions. 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). Our guide to producer registration across EU markets covers today's national registrations.

The Article 12(6) implementing acts were due by 12 August 2026 and have not been adopted. The initiative listed on 14 September 2026 covers harmonised pictograms and labelling specifications for packaging and waste receptacles. The harmonised label becomes mandatory from 12 August 2028, or 24 months after the implementing acts under Article 12(6) or 12(7) enter into force, whichever is the latest.

Is the EPR Authorised-Representative Obligation Being Suspended?

The EPR authorised-representative obligation of Article 45(3) of Regulation (EU) 2025/40 has not been suspended and has applied since 12 August 2026. The Commission proposed on 10 December 2025 to suspend its application until 1 January 2035, in COM(2025) 982. The Council discontinued negotiations on that proposal, and Parliament has not voted.

Under Article 3(1)(20), an authorised representative for the extended producer responsibility is a person established in the Member State where a producer established elsewhere first makes packaging available, and appointed to fulfil that producer's obligations under Chapter VIII. Under Article 45(3), a producer referred to in Article 3(1)(15), points (c) and (d), appoints such a representative by written mandate in each Member State where it first makes packaging available, other than its Member State of establishment.

• 10 December 2025, Commission. Article 2 of COM(2025) 982 would suspend the application of Article 45(3) until 1 January 2035. Member States could still require one from producers established in third countries, or ensure traceability and enforcement by other means.
• 24 June 2026, Council. The Council discontinued negotiations on the package's two EPR proposals, citing strong reservations by a vast majority of Member States, according to its press release updated on 2 July 2026.
• 7 September 2026, Germany. The German government proposed that traders placing less than ten tonnes of packaging a year need not appoint an authorised representative, and that registration in the new system be suspended until mid-2028, according to the Federal Environment Ministry release of 8 September 2026.
• 24 September 2026, Poland. At the Competitiveness Council, Poland asked that work in the Council resume as soon as possible on the Commission's proposals of 10 December 2025, and that a voluntary rather than mandatory EPR authorised representative be examined urgently, according to its note to the Council. This is a request from one Member State, not a Council position.
• 19 October 2026, Parliament. After the ENVI rapporteur's draft report, tabled on 22 May 2026, and amendments tabled in committee on 1 July 2026, the first-reading plenary is scheduled on an indicative basis, according to the Legislative Observatory.

Our article on two petitions and the Commission's reply covers the small-business case.

Is There a Grace Period for the PPWR?

Regulation (EU) 2025/40 contains no general grace period: Article 71 applies the Regulation from 12 August 2026, and Article 70 carries over only listed provisions for set periods. On 16 September 2026, the German retail federation HDE asked for an EU-wide grace period until 1 January 2028.

The HDE asked that companies which have demonstrably started implementing the Regulation face no fines, sales bans or recalls in that period, according to its press release. We found no published response from the Commission or the Council by 28 September 2026. National penalty regimes are due by 12 February 2027, under Article 68. Our article on what changed on 12 August 2026 covers existing stock and enforcement.

Which Other EU Rules on Packaging Moved in September 2026?

Three EU rules on packaging moved in September 2026. Directive (EU) 2024/825 on empowering consumers for the green transition has applied since 27 September 2026. Delegated Regulation (EU) 2026/2102, amending the deforestation regulation, has been in force since 18 September 2026. The registration system for food-contact plastic recyclers under Regulation (EU) 2022/1616 has been offline since 11 September 2026.

The Commission Q&A of September 2026 says traders may correct claims on existing packaging with stickers, or with information at the point of sale near the old stock. Article 14 of Regulation (EU) 2025/40 has applied since 12 August 2026. Under Article 14, an environmental claim on a packaging property regulated by the Regulation concerns only a property exceeding the applicable minimum requirement, and states whether it covers the packaging unit, part of it or all the operator's packaging.

Under Delegated Regulation (EU) 2026/2102, packing material and containers used exclusively to support, protect or carry another product fall outside the deforestation regulation. Packing material sold as a product in its own right is not covered by that exclusion.

What Moved at National Level?

Italy, France and Poland moved on packaging. Italy's Decree-Law No 143 requires certified compostable packaging for four single-use families; its conversion bill, amended by the Senate, has been before the Chamber of Deputies since 24 September 2026. Italy's transposition of Directive (EU) 2024/825 has applied since 27 September 2026. France's consultation on household-packaging EPR specifications closed on 18 September 2026. Poland's draft packaging act is planned for government adoption in the third quarter of 2026.

Under Article 77 of the Italian Constitution, a decree-law loses effect from the start if it is not converted into law within 60 days of its publication. For Decree-Law No 143, published on 7 August 2026, that period ends on 6 October 2026.

What Is New in PPWR Connect and the Academy?

PPWR Connect publishes a dated list of what shipped; four entries from 1 to 16 September 2026 bear on this digest: PFAS wording aligned on Article 5(5) of Regulation (EU) 2025/40, EPR declarations per UK semester, markets outside the EU, and Academy purchases without an account.

• 16 September 2026. The PFAS line reads as Article 5(5) does: a component is declared below, or at or above, the limit values.
• 13 September 2026. EPR declarations record what they were computed from and can be generated per UK semester. A packaging version can carry its UK RAM rating, declared by the user.
• 12 September 2026. A SKU can be recorded as sold in California (US-CA) or Ontario (CA-ON), and registrations, volumes and the EPR matrix follow.
• 1 September 2026. An Academy course or the Academy Pass can be bought without creating an account first. The course "EPR in the EU: PPWR Rules and National Schemes" costs €119.

Which Dates Should Packaging Teams Watch in October 2026?

Four October 2026 dates matter. On 1 October, large producers submit January to June 2026 data under UK packaging EPR. On 6 October, the 60-day conversion period of Italy's Decree-Law No 143 ends. On 19 October, Parliament's plenary on the omnibus is scheduled on an indicative basis. Towards the end of October, the Commission expects its new recycler registration system.

The next issue is PPWR Update, October 2026.

What Does the Referential Not Confirm?

Our dated PPWR referential (baseline reviewed 15 September 2026) confirms two statements here: the overdue Article 12(6) implementing acts and the date of the harmonised label. Its claim check found no match for the points below, read on the linked Official Journal text or official page.

• Articles 3(1)(15), (20) and (23), 5(5), 14, 44(1), 44(14), 45(3), 68, 70 and 71 as phrased here, and the reading that the Regulation contains no general grace period.
• The Italian correction as worded in the Council draft of 2 September 2026, and the absence of any other corrigendum dated after 12 August 2026 in our search of 23 September 2026.
• Every EU and national item outside the Regulation, read on the official page cited between 23 and 28 September 2026; each may change after that date, and nothing here is legal advice.

Frequently Asked Questions

Does the Italian corrigendum change who is a producer outside Italy?

No. The corrigendum of 18 September 2026 corrects the Italian version of Regulation (EU) 2025/40 only. The English text of Article 3(1)(15), points (c) and (d), already reads "directly to end users".

Is 27 September 2026 a PPWR date?

No. 27 September 2026 is the application date of Directive (EU) 2024/825. Article 14 of Regulation (EU) 2025/40, on environmental claims about packaging properties, has applied since 12 August 2026.

How PPWR Connect Helps

PPWR Connect is software: it is not a legal adviser, a producer responsibility organisation or an authorised representative. Jurisdictions outside the EU are not capped on any plan, and the EPR declaration engine (XLSX/CSV) is included in the Professional and Enterprise plans. To see which September changes touch your packaging, 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.