Where does your packaging stand under PPWR and EPR?

Twelve questions on how your packaging reaches the EU market and what you can currently evidence. You get a structured read of where the gaps sit, with links to the primary sources so you can verify everything yourself.

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CIRCUSHIFT

Packaging compliance & circularity advisory · circushift.com

PPWR & EPR readiness check

Your readiness check

Your findings are below, most urgent first. Scroll to the end if you would like these written up properly, or to book a call.

Want this turned into a plan?

This check shows you where the gaps are. Working out what to do about them, in what order, is the next step. Send it over and I'll come back with a written read on your position, or book a call.

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How to use this. This is a screening tool, not legal advice and not a conformity assessment. It points to where obligations are most likely to apply to you and what to verify; it does not determine your legal position. Requirements under Regulation (EU) 2025/40 continue to be developed through delegated and implementing acts, and national implementation differs by market. Always confirm against the primary sources linked in each finding, and take formal advice before relying on any position.

Where your packaging touches food, separate food-contact legislation applies alongside PPWR. That is a distinct assessment and is deliberately outside the scope of this check.

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Primary sources

Everything in this check points back to these. They are free and public, and if you are making decisions on any of it, they are what you should be reading rather than anyone's summary.

Regulation (EU) 2025/40 - the PPWR itself

The legal text on EUR-Lex. Entered into force 11 February 2025, applies generally from 12 August 2026. Check here for the consolidated version, which reflects any amendments.

Commission FAQ on the PPWR

DG Environment's answers to the interpretation questions it has actually received, organised by theme. The single most useful document if you are trying to work out how a provision applies to you.

Directorate-General for Environment, 3 August 2026 · ISBN 978-92-68-42316-5 · Catalogue number KH-01-26-068-EN-N

Commission PPWR overview

The Commission's own summary of what the regulation does, and where its guidance and implementing measures are published as they appear.

Directive (EU) 2024/825 - Empowering Consumers for the Green Transition

Amends EU consumer law on environmental claims, sustainability labels and durability information. Applies from 27 September 2026. Implemented through national law, so check the transposing legislation in each market where you sell.

Commission packaging waste pages

The wider policy area, including the EPR framework that sits alongside PPWR and continues to be administered nationally.

Zentrale Stelle Verpackungsregister (ZSVR) - German packaging register

The supervisory authority operating the LUCID register, where producers placing packaging on the German market must register. It also publishes the minimum standard for assessing recycling-friendly packaging design, which is the recognised benchmark in Germany. Registration is free and cannot be delegated; note that registration alone is not compliance, as a separate dual system contract is also required.

For markets other than Germany, each has its own national register and producer responsibility organisations. The ZSVR participates in the European National Registers network, which is a useful starting point for identifying counterparts elsewhere.

Note that Commission guidance is interpretative. It reflects the Commission's reading of the regulation and does not itself create obligations; final authority on the interpretation of EU law rests with the Court of Justice. Detailed criteria for several requirements are still being set through delegated and implementing acts.