Sources read on 2026-09-12 · Written by PPWR Connect from the sourced rules; legal review pending.
At a glance
| Regime | Scope | Obligated party | Entry threshold | Verified |
|---|---|---|---|---|
| PPWR — Regulation (EU) 2025/40 | Product rules on every packaging placed on the EU market (Declaration of Conformity, recyclability grades, recycled content, labelling) | The manufacturer, importer or distributor as defined in Article 3(1)(15); registration per Member State under Article 44 | None: the Regulation applies to every packaging unit | OJ text |
| National EPR — Germany (LUCID — Zentrale Stelle Verpackungsregister (ZSVR)) | Registration, scheme contract, volume declarations and fees per material | The producer established in the country, or its importer; representative regime varies by state | none | 2026-08-18 |
| UK pEPR — The Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024, SI 2024/1332 (adopted text, read with its amendments, incl. SI 2025/1369 in force 1 January 2026) | Packaging data reporting to the environmental regulator; disposal fees set by PackUK | Qualification depends on the activity and the packaging, not on a single linear cascade. Activities in the regulations: supplying filled packaging under your own brand; packing or filling; importing filled packaging; supplying unfilled packaging; hiring or loaning reusable packaging; owning an online marketplace through which packaging is supplied into the UK from outside; selling filled packaging to the end user. All three criteria must be met: established in the UK, more than 25 tonnes of packaging supplied or imported in the UK, and a turnover of more than £1 million. In a group, count only the group companies established in the UK that supply or import packaging — not the whole international group. Reference years: for the 2026 obligation, the tonnage is the 2025 data and the turnover comes from the latest accounts available before 7 April 2026. Charities are exempt from the obligations concerned (SI 2025/1369), but not their commercial subsidiaries; being non-profit is not in itself an exemption. | £1,000,000 · 25 t · all criteria | 2026-08-23 |
| California SB 54 — SB 54 (2022), Plastic Pollution Prevention and Packaging Producer Responsibility Act; final regulations effective 1 May 2026 | Registration with the producer responsibility organisation, annual supply reports, source-reduction targets | The brand owner or licensee first, then the importer or distributor in California; no residence condition — a foreign brand owner can be the producer (secondary source). | $1,000,000 (in-state) · — · any one criterion exempts | 2026-09-12 |
What the PPWR asks — once, per packaging unit
Regulation (EU) 2025/40 sets product requirements: a Declaration of Conformity per packaging unit, a recyclability grade, recycled-content minimums for plastics, harmonised labelling. It is the same obligation in the 27 Member States and it is met once, by the producer who places the packaging on the market.
Its Chapter VII adds one EPR rule at Union level: Article 44 requires the producer to be registered in every Member State where it first makes packaged goods available, and Article 45(3) requires an authorised representative for cross-border distance sales to end users. How to register, which scheme to contract and what to pay stay national.
What national EPR asks — per Member State
Each Member State runs its own register and approves its own schemes. The producer registers before the first sale (in Germany, LUCID; in France, the SYDEREP identifier), contracts a scheme for household packaging and declares volumes by material on the scheme’s grid. Thresholds, categories and calendars differ by country: our jurisdiction table reads them from the official source, with the date.
What the UK pEPR asks
Outside the Union, the UK runs one scheme for its four nations. Qualification depends on the activity and the packaging, not on a single linear cascade. Activities in the regulations: supplying filled packaging under your own brand; packing or filling; importing filled packaging; supplying unfilled packaging; hiring or loaning reusable packaging; owning an online marketplace through which packaging is supplied into the UK from outside; selling filled packaging to the end user. All three criteria must be met: established in the UK, more than 25 tonnes of packaging supplied or imported in the UK, and a turnover of more than £1 million. In a group, count only the group companies established in the UK that supply or import packaging — not the whole international group. Reference years: for the 2026 obligation, the tonnage is the 2025 data and the turnover comes from the latest accounts available before 7 April 2026. Charities are exempt from the obligations concerned (SI 2025/1369), but not their commercial subsidiaries; being non-profit is not in itself an exemption.
The entry threshold combines turnover and tonnage (£1,000,000 — 25 t — all criteria); large producers report per semester, small ones once a year. Being established in the UK is one of the criteria. Without a UK entity, check separately who may be obligated: the UK importer or first UK owner, or the online marketplace operator — their activity, their size and the packaging concerned. A direct sale from abroad does not create an obligated UK importer, and a contract organises tasks between the parties but does not designate the obligated party for the regulator. Two separate obligations for large producers: disposal fees (first fee year 2025-26, first invoices October 2025, modulated by the Recyclability Assessment Methodology from 2026-27 — RAM 1.1 for packaging supplied in 2026, RAM 2027 for 2027, with no automatic conversion from an A/B/C grade) and recycling obligations evidenced by PRN/PERN. RAM assessment is not required of every small producer. Household / non-household: primary and shipment packaging are presumed household unless the conditions and evidence for non-household are met; a B2B channel alone is not enough. Fibre-based composite packaging with plastic layers of no more than 5% by weight is reported as paper or card, with evidence (SI 2025/1369). Civil sanctions and offences exist; they depend on the breach and the authority, and are not automatic.
What California SB 54 asks
The brand owner or licensee first, then the importer or distributor in California; no residence condition — a foreign brand owner can be the producer (secondary source).
Small-producer exemption on the revenue test only — no tonnage test in this state. Reporting is annual to the producer responsibility organisation (Circular Action Alliance); the covered-material categories are the state’s, not the PPWR’s.
Why one record is enough
All four regimes ask questions of the same object — the packaging unit, its components, materials and weights, and the units placed on each market. Describe it once, and the PPWR grade, the German material declaration, the UK RAM rating you declare and the Californian category can each be derived from that record, with the market and the period as the only variables. That is what PPWR Connect does; it does not file in any register for you and never quotes a fee.
Fee amounts are deliberately absent: schemes revise them every year. We describe the structure and link the current schedule.
Five questions
- Is the PPWR an EPR scheme?
- No. The PPWR is a product regulation with one EPR provision (Articles 44–45: registration in each Member State and an authorised representative for distance sales). Registration, schemes and fees remain national.
- Does registering for the PPWR cover UK pEPR?
- No. The UK is outside the Union; pEPR has its own producer definition, thresholds and reporting to the UK environmental regulator, with fees set by PackUK.
- Is SB 54 the US version of the PPWR?
- No. SB 54 is a California producer-responsibility law with a single PRO, its own producer definition (brand owner first) and small-producer thresholds; other US states have their own laws, and there is no federal scheme.
- Can one dataset serve all four?
- Yes, if it is kept at component level: material, weight, format and units placed per market and period. Each regime’s grid is a mapping of that record.
- Does PPWR Connect file for me?
- No. It prepares the declaration from your packaging record in each scheme’s format; you sign into the register in your own name. Fee amounts are never stated.
Primary sources
What the sourced rules imply — an indication provided for information, not legal advice. National, UK and state rules change every year: verify with the official register before acting.