The PPWR (Regulation (EU) 2025/40) has applied across the EU since 12 August 2026, and the date was not moved. What is still being settled is the detail around it: who has to appoint a representative, how existing reuse systems are treated, which technical standards define recyclable design, and what a running deposit scheme delivers.
Status below is as of 9 November 2026. Several sources here are law firms, a standards body and a compliance-software vendor, so the vendor’s figures and commentary are attributed by name. This is information, not legal advice; check the official text where a decision depends on it.
The thread: the law is in force, the working rules arrive in pieces
All four items share one pattern. The Regulation sets obligations and dates, while guidance, implementing acts, standards and national schemes decide what a brand owner, converter, retailer or recycler actually has to do on a given SKU. One compliance vendor, PPWR Connect, counted no implementing act under the Regulation adopted between 28 September and 21 October 2026, which fits the wider picture of late secondary legislation.
Authorised representatives: Parliament and Council differ, nothing is law
The authorised representative duty in Article 45(3) has applied since August. The Commission’s proposal COM(2025) 982 would suspend it, and the file has moved in the past three weeks.
According to PPWR Connect, Parliament voted on 20 October 2026 on report A10-0266/2026 by 616 votes to 9, with 39 abstentions (the vendor cites HowTheyVote.eu for the count). On the following day the Council’s Permanent Representatives Committee agreed a narrower mandate, which the same vendor reports covers producers below 1 tonne per member state and year, until 1 January 2032, and that neither position binds producers or authorities.
Law firm Luther adds that the Commission aims for a suspension in force before the end of November, that the competent authorities are not required to follow the Commission’s recommendation in the meantime, and that the Commission published a factsheet for small businesses on 19 October 2026. The three versions on the table:
| Version | Who would be relieved | Suspended until | Status on 9 November 2026 |
|---|---|---|---|
| Commission, COM(2025) 982 (10 December 2025) | EU-established producers | 1 January 2035 | Proposal |
| Parliament | EU-established micro and small enterprises (committee text used under 50 employees and up to EUR 10 million turnover) | 1 January 2035 | Position adopted 20 October 2026 |
| Council | EU producers placing under 1 tonne of packaging per year in another member state | 1 January 2032, review by 31 December 2030 | Mandate of 21 October 2026 |
Trilogue negotiations come next, and the gap between 2032 and 2035 is only one of the open points. If you are signing a new mandate now, a termination right in case of suspension is a sensible clause to ask for.
Reuse: existing systems stay, labels and rotation data come later
Commissioner Jessika Roswall answered industry questions about maintaining and reporting on reusable packaging systems, Packaging Europe reports. Existing reuse systems are expressly recognised as compliant and can keep operating as long as they meet Article 26 and Annex VI.
Reusable packaging placed on the market before the new labelling rules apply may stay in circulation without redesign. The Commission is preparing an implementing act on label specifications that will apply 24 months after it enters into force, and a second act under Article 12(1) will set the data and method for counting rotations. Packaging Europe also notes that the Commission has issued guidance for small producers on EPR duties, allowing member states and producer responsibility organisations to limit administrative procedures for them.
For operators of returnable crates, bottles or pallets, this removes one near-term worry: there is no need to rewrite documentation just to prove a system is compliant. A separate Packaging Europe summary of the Commission’s guidance says only sales packaging with an evident transport function is held to the binding transport reuse targets, and that those targets apply only within the Union, so both importer and distributor must be located in the EU. The targets themselves start on 1 January 2030, subject to the usual “or a set period after the Commission’s act” rule for later dates.
Design for recycling: standards arrive before the delegated act
The 1 January 2030 requirement for recyclability grades A, B or C needs criteria that the Commission has not yet adopted. In the meantime CEN has published the EN 18120 series: 14 standards on the recyclability of plastic packaging, issued in April 2026, according to Belgian producer responsibility organisation Fost Plus.
CEN-CENELEC describes a series that starts with principles and terminology (EN 18120-1) and includes an evaluation process for sortability (EN 18120-3), covering near-infrared, magnetic and eddy-current separation. Design features are rated green for full compatibility with recycling, yellow for limited compatibility and red for incompatible.
The standards are not the law. A playbook from Dutch producer responsibility organisation Verpact points out that the PPWR does not call for harmonised standards on design for recycling, and that the secondary legislation could differ from the CEN texts in places. European Bioplastics reports that CEN has also approved four technical specifications for rigid and flexible biodegradable plastics (CEN/TS 18382, 18383, 18395 and 18396), which feed into the delegated act on design for recycling scheduled for adoption by 1 January 2028.
For converters and brand owners the working approach is to assess new plastic packs against EN 18120 now, since the standards are a detailed public method, and to record any red or yellow features that a later delegated act might treat differently. Fibre, glass and metal packs have no equivalent series in these sources.
Romania’s deposit scheme: 85% collection in 2026
Deposit return is where the EU already has operating evidence. Balkan Green Energy News reports that Romania’s scheme (SGR) collected more than 12.5 billion single-use beverage containers in three years, with a national collection rate of 85% between January and September 2026, up from 82% in the same period of 2025. The national target for the third year is 90%.
The scheme covers glass, PET and aluminium containers from 0.1 to 3 litres, and runs through roughly 80,000 registered collection points organised by retailers. The deposit is 0.50 RON per container, according to Interreg Europe. The full-year 2025 rate was 83%, per Romania Insider quoting the scheme administrator RetuRO.
Source: Balkan Green Energy News (Jan-Sep 2025 and 2026, third-year target); Romania Insider quoting RetuRO (full year 2025)
The source puts the output at more than 900,000 tons of sorted material (its unit). Our calculation: 900,000 t x 1,000,000 g/t / 12.5 billion containers = about 72 g of material per container. Both inputs are “more than” figures, so treat 72 g as a rough average across glass, PET and cans, not a specification.
Under the PPWR, member states must ensure deposit schemes for single-use plastic bottles and metal containers up to 3 litres by 1 January 2029, as Kirkland and Ellis summarises. Romania shows the retailer workload (collection points) and the recycler benefit (a steady supply of sorted PET, aluminium and glass) in one system.
What to do now
- Representatives: keep existing appointments in force and check whether you sell in a member state with its own representative rule. Re-read the scope once a trilogue text exists.
- PFAS in food-contact packaging: the Commission has said there is no stock-exhaustion period, so packs first placed on the market on or after 12 August 2026 must comply. The UK’s Food and Drink Federation, in its PPWR guidance, notes that the limits apply to the whole pack including inks, coatings, varnishes and adhesives. Ask fibre-packaging suppliers for test evidence per pack type, not a general declaration.
- Reuse: map which of your flows are sales packaging with an evident transport function, and confirm that your existing system’s documentation refers to Article 26 and Annex VI.
- Recyclability: run new plastic designs through EN 18120 and keep the output with your technical documentation.
- Deposit schemes: if you fill beverage bottles or cans up to 3 litres, check your national scheme timeline against the 1 January 2029 date, and compare it with Romania’s performance for planning return volumes.
Sources
- European Commission, Environment: New EU packaging rules start to apply, including restrictions on PFAS in food-contact packaging
- CEN-CENELEC: EN 18120, Europe sets a new benchmark for recyclable plastic packaging
- Luther: PPWR / EmpCo Update, suspension of the authorised representative requirement?
- PPWR Connect: PPWR Update, October 2026
- PPWR Connect: EPR authorised representative, the Parliament vote of 20 October 2026 and the Council mandate
- Packaging Europe: EU Commissioner Jessika Roswall clarifies PPWR’s reuse requirements
- Packaging Europe: Diving deeper into the EU’s latest guidance on the PPWR
- Fost Plus: PPWR Insights 1, what do the new recyclability requirements mean for your business?
- Verpact: No regrets! The journey to design your plastic packaging
- European Bioplastics: CEN approves Design for Recycling Technical Specifications
- Balkan Green Energy News: Romania’s deposit return scheme recovers 12.5 billion beverage containers in three years
- Interreg Europe: The Deposit-Return System in Romania (RetuRO SGR)
- Romania Insider: Romanians returned over 5.2 billion containers under deposit-return system in 2025
- Kirkland and Ellis: The New EU Packaging and Packaging Waste Regulation
- Food and Drink Federation: PPWR Business Guidance
Header image: illustration, AI-generated.