Commission publishes Draft Implementing Act on Packaging Producer Registers
The Packaging and Packaging Waste Regulation (EU) 2025/40 (PPWR) has applied since 12 August 2026. For the practical implementation of certain provisions, the PPWR provides for further implementing acts to be adopted by the European Commission, including an implementing act concerning the national producer registers pursuant to Article 44 PPWR.
On 6 August 2026, the European Commission published an initial draft of the implementing act on national producer registers and launched a public consultation on the draft.
Producer Registers in All EU Member States
As a general rule, producers within the meaning of the PPWR must register in each Member State in which they make packaging or packaged products available for the first time or unpack packaged products without being the end user.
In most EU Member States, the producer registers are currently still being established or need to be adapted to the PPWR. Final alignment with the harmonised requirements will only be possible once the implementing act has been adopted.
In particular, the European Commission’s planned implementing act is intended to harmonise the format for registration and reporting to the national registers and to specify the level of detail of the data to be reported, as well as the relevant packaging and material categories.
The Current Situation in Belgium and Germany
In Belgium, the producer register is still being established. According to the competent authority, EPRiBEL, registration numbers cannot currently be issued. Where a producer joins a Producer Responsibility Organisation (PRO), registration in the Belgian producer register is expected to be handled by the PRO in the future.
In Germany, the LUCID Packaging Register already provides an operational producer register. In particular, companies should assess whether they have been subject to a registration obligation since 12 August 2026 due to the PPWR’s new definition of “producer”, which is broader in certain respects than the previous definition under the German Packaging Act.
We Support You
With our EU Service, we keep you up to date on producer registers and registration requirements across EU Member States.
In our 90-minute “Packaging in Germany” workshop, we provide hands-on support to help you meet your registration obligations. You will receive a clear overview of your responsibilities as a producer, guidance on selecting a suitable Producer Responsibility Organisation (PRO), and step-by-step support with your registration in Germany’s LUCID Packaging Register. We will also highlight the latest action items arising from the EU Packaging and Packaging Waste Regulation (PPWR), so you know what to prepare for next.
