EU Proposes Harmonized Registration Formats and Reporting Requirements for Packaging Producers Under PPWR

On August 6, 2026, the European Commission initiated a public consultation on a draft implementing regulation of the Packaging and Packaging Waste Regulation (EU) 2025/40, with the core objective of establishing harmonized registration formats and reporting requirements for producer registers.

I. Registration Requirements (Annex I)

When registering, producers (or their producer responsibility organizations, authorized representatives) must submit the following information:

Section	Content
Part A	Basic producer information: Name, legal form, address, tax/VAT number, brand names, contact details, etc.
Part B	How the producer fulfills Extended Producer Responsibility (EPR): Self-compliance or delegation to a Producer Responsibility Organization (PRO), with relevant authorization documents attached
Part C	Certificate of compliance issued by the Producer Responsibility Organization
Part D	Authorized representative information (for non-EU producers): Name, address, tax number, represented producer(s), etc.

Key Requirements: Information must be submitted electronically, supporting fully automated processing and batch verification. If multiple packaging waste management systems exist within a Member State, separate registration is required for each.

II. Reporting Requirements (Annex II)

Producers must annually report packaging placement and waste treatment data, using different forms based on production volume:

Section	Applicability	Reporting Content
Part A	Producers placing ≥10 tonnes/year	Detailed reporting by weight of packaging placed on the market, categorized by primary material (glass, paper/cardboard, iron, aluminum, various plastics, wood, textiles, ceramics, and 23 other categories)
Part B	Producers placing <10 tonnes/year	Simplified reporting with broader material categories
Part C	All relevant parties	Quantity of separately collected single-use plastic beverage bottles and metal beverage containers (capacity ≤3 liters), distinguishing whether included in a deposit-return system
Part D	All relevant parties	Quantity of various packaging waste collected within the Member State
Part E	All relevant parties	Quantity of packaging waste disposed of, recovered, and recycled within the EU
Part F	All relevant parties	Quantity of packaging waste disposed of, recovered, and recycled outside the EU

Key Requirements:

Composite materials shall be classified according to their main component (the material with the highest weight percentage), but the weight of each constituent material must also be reported.
Data must be based on the product's technical documentation or an equivalent complete description (linked to EU conformity assessment requirements).
If the product already has a Digital Product Passport (e.g., compliant with (EU) 2024/1781), it may be used directly to provide registration information.

CIRS Insights

The consultation period for this draft ends on September 10, 2026. Although the draft has not yet been formally adopted, given that the (EU) 2025/40 PPWR is already in effect, companies should immediately begin the following preparations:

Inventory current packaging placement volumes in each EU Member State to determine whether the 10-tonne threshold is triggered.
Evaluate authorized representative establishment options (for non-EU enterprises, consider establishing a unified representative in a key market country).

Why Choose CIRS for PPWR Compliance

CIRS Group provides end-to-end, full-lifecycle compliance services for the EU PPWR to support businesses working through these requirements, including:

✅ Heavy metal & PFAS testing for packaging materials (backed by CNAS and CMA accreditations);

✅ Conformity assessment support & Declaration of Conformity (DoC) documentation assistance;

✅ EU packaging EPR registration across member states;

✅ Packaging recyclability assessments and optimization recommendations;

✅ Recycled content verification;

✅ Technical compliance Analysis for compostable packaging requirements;

✅ Tailored PPWR consulting and in-house regulatory Training services.

If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.

Further information

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