In our PPWR blog, we provide an overview of developments in the period from 16 July to 10 September 2026. We divide the articles into EU level and national level (Germany, Austria, Switzerland). As always: this overview makes no claim to completeness and does not replace legal advice.
EU level
PPWR now applies
The European Packaging and Packaging Waste Regulation (EU) 2025/40 (PPWR) has applied directly in all Member States since 12 August 2026.
- The restrictions on heavy metals for all packaging materials and the PFAS limit values for food-contact packaging take effect immediately.
- The harmonised labelling system will follow in 2028.
- Requirements on recycled content, reusability, empty space minimisation and recyclability will apply from 2030.
At the same time, the Commission announced that enforcement authorities should initially give economic operators the opportunity to take corrective action until February 2027 before imposing penalties.
Second edition of the Commission’s PPWR FAQ
Shortly before the Regulation became applicable, the Commission published an updated version of its FAQ document on the uniform interpretation of the PPWR.
Clarifications include:
- the manufacturer role for retailers’ private labels,
- the distinction between sales, grouped and transport packaging,
- the handling of existing stock, and
- evidence requirements for declarations of conformity.
A graduated, initially cooperative approach is recommended for enforcement authorities. Incidentally, a provisional list of the competent authorities in the individual Member States can be found here.
The Commission’s FAQ can be downloaded here.
New guidelines on demonstrating compliance with the PFAS requirements
The sector group “Contact Sensitive & Food Contact Plastics Regulatory Experts (CFREP)” of the European Plastics Converters association (EuPC) has published new guidelines on demonstrating compliance with the PFAS requirements under Article 5(5) PPWR.
As there is not yet a harmonised EU test method, these guidelines are intended to offer companies a practical, risk-based approach.
Information page and downloads
Environmental Omnibus – Parliament’s work on EPR simplifications under way
In the ongoing preparatory phase ahead of the trilogue on the “Environmental Omnibus” – which provides, among other things, for a possible suspension of the obligation to appoint an authorised representative for extended producer responsibility (EPR) registration in EU Member States (Art. 45(3) PPWR) and for the harmonisation of EPR reporting cycles – the European Parliament’s ENVI Committee is currently developing its own positions.
Among other things, rapporteurs Solis Pérez and ter Laak propose a centralised digital reporting mechanism and a suspension of the authorised representative obligation limited to micro-enterprises and time-limited until 2035.
Votes on the authorised representative obligation and on reporting frequencies are expected in October and November 2026 respectively.
Recycling associations are urging that adjustments be made comprehensively rather than piecemeal as part of the upcoming Circular Economy Act.
ECHA presents draft list of “substances of concern” (Art. 5 PPWR)
On 16 July 2026, ECHA’s PPWR team sent packaging stakeholders a draft list of around 700 “substances of concern” (SoC) which, under Art. 5 PPWR, packaging may in future contain only in minimised concentrations.
The list was narrowed down from an original pool of around 6,000 substances via intermediate steps (2,500) to around 700 (731 according to other sources); the assessment criteria were risks under chemicals legislation and impacts on recycling and reuse. Heavy metals and PFAS are already regulated separately and are not part of this list.
Known hazard profiles exist for 616 substances (SVHC, CMR, Annex VI REACH, etc.). No hazard profile exists for 115 substances, but they were included because they are assumed to impair the recycling of packaging waste.
Of particular interest in the second category are intentionally added substances (IAS), which include a number of very common antioxidants, UV absorbers, stabilisers, plasticisers and pigments.
Comments could be submitted to ECHA until 24 August 2026; the final list or a corresponding delegated act is expected later in the year.
Germany
VerpackDG replaces VerpackG
On 12 August 2026, at the same time as the PPWR became applicable across the EU, the German Packaging Law Implementation Act (Verpackungsrecht-Durchführungsgesetz, VerpackDG) entered into force, adapting the established structures of the dual system to the European requirements.
It contains clarifications on responsibilities along the supply chain as well as increasing recycling rates for plastic waste from dual systems (75 % from 2028, 80 % from 2030).
Official press release of the German Federal Government
Austria
PPWR applies directly, national amendment of the AWG still pending
The PPWR has also been directly applicable in Austria since 12 August 2026. However, according to the Austrian Economic Chambers (WKO), as of 9 September 2026 there is still no draft for consultation (Begutachtungsentwurf) of the necessary amendment to the Austrian Waste Management Act (AWG) – covering, among other things, extended producer responsibility, collection and recovery systems and administrative penal provisions. Until then, existing Austrian regulations will remain in force for the time being. (WKO web page on “Consultations on waste and resources”)
As an interim measure, the Austrian Federal Ministry of Agriculture and Forestry, Climate and Environmental Protection, Regions and Water Management (BMLUK) has published an interpretation guidance sheet on the application of the PPWR. In parallel, in August 2026 Altstoff Recycling Austria (ARA) published an updated edition of its practical guide for companies (ARA PPWR Guide 08/2026 (download as PDF)). It focuses in particular on the PFAS limit values that apply with immediate effect and on role-related and conformity obligations.
Switzerland
PPWR also takes effect for Swiss exporters
Although Switzerland is not an EU member, Swiss companies exporting packaging to the EU have had to comply with the PPWR requirements since 12 August 2026 – in particular the EU declaration of conformity and technical documentation as well as the new PFAS limit values for food-contact packaging.
Existing stock does not have to be replaced immediately; authorities are initially expected to require corrective action rather than impose penalties. Swiss Recycle points out that Swiss companies will therefore have to keep an eye on two regimes in parallel: the EU PPWR for exports to the EU and, for the domestic market, the separate Swiss Packaging Ordinance (VerpV), which is more moderate in detail and is due to enter into force at the beginning of 2027.
