Articles
What we checked, where the sources disagree, and what changed. Every note dated.
AI answers on PPWR checked: Article 8 is bio-based feedstock, 94/62/EC is repealed, EPR has no single EU registration date, the micro rule has two wordings.
Under PPWR Article 45(3), only a producer selling packaging directly to end users in another EU country must appoint an EPR authorised representative there.
Under the PPWR the manufacturer of transport packaging is the company whose brand is on it, the maker of generic packaging, or whoever orders it custom-made.
The PPWR declaration of conformity (Art. 39, Annex VIII) has eight points, is drawn up per packaging type by the manufacturer and kept for 5 or 10 years.
The PPWR was proposed in 2022 because EU packaging waste grew faster than the economy. Who pushed it, who opposed it and why, with the votes and sources.
PPWR is Regulation (EU) 2025/40: one EU law for packaging design, documentation, labels and EPR, in force since February 2025, applying from 12 August 2026.
EPR fees are kilograms by material times a rate set by the scheme or the state, often graded by recyclability. Real 2026 figures from five countries.
EPR (extended producer responsibility) makes whoever first places packaging on a market register, report kilograms by material and pay for its collection.
Registering and joining a scheme are two steps. Spain requires both, Denmark requires a scheme for single-use packaging, and Latvia has no register at all.
EPR, PPWR and the national tax are three separate duties, not one. A declaration of conformity does not register you, and a scheme contract is not compliance.
Latvia taxes a wooden pallet as packaging. Denmark charges nothing for a reusable Europallet sold on for reuse — but the seller must take it back.
Packaging you can document as leaving Denmark is not reported to DPA — but the receiving country's EPR applies. A reusable pallet pays nothing at all.
Spain has two packaging obligations: the RPP register with a scheme, and a plastic tax at 0.45 €/kg collected by the tax authority. They are not the same.
LUCID in Germany, IDU in France, BDO in Poland. In six of the 27 there is no packaging producer number at all — the form asks for what does not exist.
Germany counts material groups, France counts UVC, the Netherlands counts the unit a consumer throws away. The kilograms are the easy part.
Fifty per cent, not forty. From 2030, not 2026. And the article number matters, because a declaration of conformity names the articles you assessed.