Three Weeks Until the PPWR Deadline: Volume Thresholds To Be Removed
The European Packaging Regulation (PPWR) will come into force on 12 August 2026. For many companies, this may mean that, for the first time, they will be required to register, report volumes and pay EPR fees.
The PPWR no longer provides for national volume thresholds. Manufacturers who were previously exempt from national obligations due to low packaging volumes may therefore also fall under the extended producer responsibility from 12 August 2026.
The previous volume thresholds include, for example:
Belgium and the Czech Republic: 300 kilograms of packaging per year
Ireland: 10 tonnes of packaging and annual turnover of at least EUR 1 million in Ireland
The Netherlands: 50 tonnes of packaging per year. According to the latest information from Verpact.nl, this threshold is expected to remain in place until the end of 2026.
Implementation Remains Unclear in Many Countries
Although the PPWR will apply from 12 August 2026, there is still considerable uncertainty in many Member States regarding its practical implementation. In some cases, it remains unclear from what date companies – which, until now, have not been subject to EPR obligations due to volume thresholds – will be able to join a national producer responsibility organization (PRO) and register in a packaging register.
In addition, many Member States still need to establish a dedicated producer register for packaging for the first time. In Germany, a corresponding structure already exists in the form of the LUCID packaging register. In countries such as Belgium or Ireland, however, such a register has yet to be created.
The main reason for the delays is that many Member States yet lack the legal framework to align their national packaging laws with the requirements of the PPWR. Companies should therefore not assume that the practical implementation will already be fully in place in all countries by the deadline.
What Companies Should Do Now
Even where national procedures have not yet been finalised, companies should get prepared. Key steps include:
identifying the countries in which producer obligations have not previously applied due to volume thresholds,
joining a national packaging PRO where this is already possible,
continuously monitoring national registration requirements,
and preparing a reliable data basis for future packaging reports.
Do you need support with implementing the new requirements or have questions about the new rules? Submit your enquiry via the Bitkom Compliance Solutions request form here.
