What Article 44 requires
Producers (and their Article 45 authorised representatives) must register in each Member State where they place packaging on the market — the national EPR register. No registration ⇒ cannot place product on the market lawfully. Registration is due on 12 August 2026, in the existing national registers: the 12 February 2026 date often quoted was the Commission's own deadline to adopt the Article 44(14) implementing act fixing the harmonised registration format, and that act has not been adopted. It was never an obligation on producers. Information to supply: Annex IX, Part B point 3. When the manufacturer is outside the EU, the importer making the packaged products available for the first time in a Member State is the "producer" (Article 3(1)(15)) and owes the registration there — EPR is national, country by country. The declared volumes include the transport level: the pallet, stretch film and strapping arriving around imported goods are packaging placed on the market and count toward the EPR declarations alongside the sales packaging.
When Article 44 applies
One line per dated paragraph. Applies — the date has passed. Firm — written in the regulation, nothing in the pipeline can push it back. Conditional — a floor: the obligation starts on that date, or a set number of months after the act it waits on enters into force, whichever is later.
| Paragraph | Date | What starts | Status |
|---|---|---|---|
| Art. 44 | Register of producers | Applies |
Related articles
Read the text
Article 44 on EUR-Lex · Regulation (EU) 2025/40, full text
Legal review of 2026-09-02
Each date above is a literal read from the regulation or the Commission guidance, never derived by arithmetic from entry into force. A date present in the reference with no entry in the catalogue fails our build.