PPWR this week: crystal glass, label delay, AR vote, German fines

The PPWR has applied since 12 August 2026, and that date has not moved. What has moved, across the second half of October, is the material around it: a new derogation, a later labelling act, a Parliament position on authorised representatives and the first detail on how Germany will fine breaches. As of 31 October 2026, these four items show which parts of the regulation are fixed and which are still being adjusted.

Most sources below are trade press, law firms and national news agencies. Several compliance-service vendors also comment on the German law; we name them where used, since they sell help with the rules they describe.

Four developments at a glance

Development	Legal status (31 Oct 2026)	Who is most affected	Key date
Crystal glass heavy-metal derogation	Adopted: Delegated Decision (EU) 2026/1948	Crystal glass producers, brand owners using crystal packaging	Production of leaded packaging to 31 Dec 2028
Harmonised labelling act	Delayed; consultation planned, adoption expected Q2 2027	Brand owners, converters, retailers, label suppliers	Two years to comply after adoption
Authorised representative suspension (Article 45(3))	Proposal; Parliament position voted 20 Oct 2026, Council position outstanding	EU micro and small producers selling cross-border	Proposed suspension to 1 Jan 2035 at the latest
German VerpackDG fines	Adopted national law, in force since 12 Aug 2026	Anyone placing packaging on the German market	PPWR-related penalties enforceable from 12 Feb 2027

Crystal glass gets a time-limited route around the heavy-metal limit

ChemLinked reports that Commission Delegated Decision (EU) 2026/1948 was published on 28 October 2026 and took effect the next day, amending Decision 2001/171/EC. It lets crystal glass packaging exceed the PPWR’s 100 mg/kg combined heavy-metal limit, subject to safeguards. EU Law Live adds that the decision was adopted on 12 August 2026 and is meant as a transitional period while the industry moves towards lead-free production.

The dates are the practical part. Crystal glass packaging containing intentionally introduced or residual lead may be manufactured only until 31 December 2028, and packaging made before then may be placed on the market until 31 December 2029. A producer therefore has about two years of leaded production left and a further year to sell through stock.

The conditions matter as much as the dates. The draft text sent to the Council on 21 August 2026 refers to return, traceability and recycling of crystal glass packaging through a controlled loop, and dealkalisation requirements. It also preserves the existing recycled-glass derogation. That is a draft, so check the Official Journal text for the final wording before relying on it.

For brand owners, the point is supplier evidence. If a crystal decanter or perfume flacon is in your range, ask the producer which side of the 2028 and 2029 dates each article falls on, and whether it will be lead-free by then. Ordinary soda-lime glass buyers are unaffected by the new decision.

Labelling slips to 2027, and the two-year clock slips with it

letsrecycle.com reports that the implementing act, originally scheduled for 12 August 2026, is now anticipated in the second quarter of 2027. Packaging Insights confirms the Commission will include a public consultation in the adoption process. The labels will cover sorting guidance, reusable packaging, packaging covered by deposit return systems, and recycled and bio-based content.

The UK’s On-Pack Recycling Label scheme (OPRL) prompted the coverage. Its managing director Jude Allan, quoted by Sustainable Packaging News, called the two-year window for changing label designs extremely challenging, especially for producers with extensive ranges. She also said it is not yet known whether the deadline refers to packaging on shelf or in production. OPRL expects UK pEPR labels to align with the EU, which would help firms trading in Northern Ireland.

Our calculation: the original adoption date of 12 August 2026 plus two years gives 12 August 2028, which matches the labelling date we had been working from. Adoption between 1 April and 30 June 2027 now means a label deadline of 1 April to 30 June 2029 if the clock runs from adoption. That is a slip of roughly 7.5 to 10.5 months from 12 August 2026 (about 7.6 months to 1 April 2027, about 10.6 months to 30 June 2027). The newer reporting supersedes the earlier August 2028 expectation, though the final application date depends on the act itself.

Press coverage says the rules are expected to extend labelling requirements to all packaging, including secondary and tertiary packaging. Brand owners and converters should not redesign artwork yet, because the pictograms are not final. The Joint Research Centre has proposed a material-based, pictogram-oriented approach, which is the direction to watch in the consultation.

Parliament narrows the authorised representative suspension

Commission proposal COM(2025) 982 would suspend the Article 45(3) authorised representative obligation until 1 January 2035. Our brief for this piece described it as a proposal as of early October. Today’s leads show it has moved: ProdLaw reports the Parliament voted on 20 October 2026, and the suspension would be restricted to EU-established micro and small enterprises, with medium-sized and large firms still required to appoint a representative.

The Parliament text also ends the suspension in January 2035 or on the application date of the expected act, whichever is earlier. It would not exempt producers from other EPR obligations such as financial contributions or recycling targets. The earlier committee step was a 5 October 2026 vote in the Environment Committee, according to PAQR, a compliance-service provider.

This is still not law. Until the Council gives its approval, the existing EPR and authorised representative obligations continue to apply unchanged, according to Ecosistant, another compliance vendor. PAQR notes the Council paused work on the suspension on 24 June 2026, so the Council’s position is the open question.

In practice, a Dutch or Polish SME that sells into Germany and France faces the representative requirement today. A larger EU brand owner would not benefit from the Parliament’s version at all. Producers outside the EU should read the Parliament text as offering them nothing, since it is limited to EU-established firms.

Germany sets its fine tiers, with a delay on PPWR breaches

FreshPlaza reports that Germany’s Packaging Law Implementation Act (VerpackDG) designates the ZSVR as the competent authority for registering economic operators, and that companies registered under the old VerpackV count as registered. Failure to register can cost up to €100,000, while other offences range from €10,000 to €200,000.

The law is not a transposition. Packlab, a consultancy, notes that the PPWR is directly applicable in Germany and does not require transposition into national law. The act was published on 17 July 2026 and entered into force on 12 August 2026. A transitional provision delays the penalties until 12 February 2027.

The tiers, as summarised by compliance firm Regsurance from section 66 of the act, are in the chart below. Not joining a dual system carries up to €200,000; not registering in LUCID carries up to €100,000. Placing packaging on the market that breaches PPWR requirements such as the heavy-metal limit, or without a conformity assessment, carries up to €10,000.

Maximum fine per breach under Germany's VerpackDG, by breach type. Maximum fine (EUR): PPWR conformity or declaration breach 10000, Not registering in LUCID 100000, Not joining a dual system 200000 (EUR) — Maximum fine per breach under Germany's VerpackDG, by breach type
Source: Regsurance summary of section 66 VerpackDG; FreshPlaza (as of 31 October 2026)

Low ceilings do not mean low exposure. Packa, a compliance software vendor, points out that authorities can also order sales bans and confiscate profits derived from non-compliance. For retailers and fulfilment providers, Packaging Insights quotes a lawyer who describes a knock-on effect, with distributors and fulfilment providers facing bans if they offer, sell or store non-compliant packaging.

Germany is one member state. Brussels Signal, an outlet with an editorial line critical of the regulation, reports that Article 68 obliges member states to lay down penalties and notify them by 12 February 2027. We did not find confirmed penalty schedules for other member states in this round of research.

The readiness gap outside the EU

Enforcement meets uneven preparation. The Korea International Trade Association (KITA) surveyed 610 current or prospective EU exporters between 21 August and 2 September 2026, and Financial News reports that 82.5% were either unaware of the PPWR or knew only its outline. Only 16.7% had assessed whether the rules applied to their products.

The documents gap is more telling. More than half of the 356 plastic packaging users had not secured documents from recycled-material suppliers, recyclability assessments or EPR reporting materials. The survey is of Korean firms, so read it as an indicator for non-EU exporters, not a measure of EU producers. It still matches the supply-chain pattern importers and retailers see when they ask suppliers for declarations of conformity.

What links the four

None of the four changes the 12 August 2026 application date. Two of them (crystal glass and German fines) are fixed and have dates attached. The other two (labelling and authorised representatives) are unfinished and may reshape workloads for brand owners, converters and retailers over the next year.

That split suggests a sorting rule for planning. Treat adopted acts and national penalty law as fixed inputs, and treat proposals and delayed implementing acts as scenarios to track.

What to do now

Crystal glass: list any crystal or lead-bearing glass articles in your range, ask producers for their lead-free timetable, and read the final Decision (EU) 2026/1948 text on EUR-Lex.
Labelling: hold artwork changes until the consultation draft appears, but start an inventory of every pack format, including secondary and tertiary packaging, so the two-year window is not spent on counting.
Authorised representatives: keep existing appointments, and if you sign a new one, agree a termination right in case a suspension is adopted. Check whether you count as an EU micro or small enterprise, because the Parliament text would not cover larger firms.
German market: confirm LUCID registration and dual-system participation for every packaging type, and draft declarations of conformity and technical documentation before 12 February 2027.
Suppliers outside the EU: request recycled-content evidence, recyclability assessments and EPR reporting data now, since these are the documents the Korean survey found missing.

This article is information, not legal advice. Where a date or a fine matters to a decision, check the official text or take legal advice.

Sources

Header image: illustration, AI-generated.