The European Commission has presented a draft for uniform rules on the registration and reporting of packaging producers. The planned implementing regulation for the European Packaging and Packaging Waste Regulation (PPWR) is intended to specify what data producers must submit to national registers and how they must report on the quantities of packaging placed on the market.
The draft This is specified in Article 44 of Regulation (EU) 2025/40. Under this provision, Member States must establish national registers to monitor compliance with extended producer responsibility requirements. Producers must register in these registers and report relevant data. The Commission intends to specify EU-wide standardised formats for this purpose, thereby avoiding differing national requirements as far as possible.
Standardised format for registration
For registration, the draft provides for several areas. These are to cover the registration of a producer, details on how the producer fulfils their obligations under extended producer responsibility, certificates from producer responsibility organisations, and the registration of authorised representatives.
If there are separate systems for the management of packaging waste in a Member State, the register must be able to identify the respective systems. A producer whose packaging is assigned to several systems must register the respective packaging collected accordingly in a separated manner.
The data must be submitted electronically via a data processing system that enables a fully automated process. Provision is also made for the possibility of bundled verification of registration numbers and digital certificates to fulfil extended producer responsibility.
Different messages depending on the packaging quantity
For reporting, it makes a distinction the draft regulation inter alia according to the quantity of packaging made available in a Member State. A separate reporting format is planned for producers that make available at least ten tonnes of packaging on the respective national market per calendar year. A separate format shall apply to producers with less than ten tonnes.
Other parts of the reporting format relate to the quantities of separately collected single-use plastic beverage bottles and metal beverage containers with a capacity of up to three litres. In addition, there are details on other collected packaging waste and on packaging waste that is disposed of, recovered or recycled inside or outside the EU.
Material components must be reported individually
Particular importance is attached to the material composition of packaging. Packaging that is made available for the first time in a Member State and reported accordingly shall initially be classified according to its predominant material. The decisive factor is the material with the highest proportion by weight.
However, for packaging made from multiple materials, including composite packaging, this classification is not sufficient. In addition, the weight of all materials contained must be reported within the respective material categories. Individual components of a packaging unit must also be taken into account. One of the reasons for this is that, after use, components enter different material streams and, due to their design and material composition, can have varying recyclability.
The basis of the information should be the technical documentation in accordance with Annex VII of the PPWR. Alternatively, the draft provides for an equivalent complete description of the packaging unit, including all integrated and separate components.
Digital data transmission planned
The Commission justifies the harmonisation with the objective, among others, of limiting the administrative burden for businesses. Producers are to be able to submit their data in the member states in a uniform format. This is intended to prevent different national registration and reporting formats from developing.
If a packaged product is covered by EU regulations on a digital product passport, the system should also make it possible to use the information stored there for the manufacturer register.
Furthermore, the planned format should be able to incorporate additional reports resulting, for example, from the Single-Use Plastics Directive or further national measures. It should also be possible to include data for calculating the annual consumption of plastic carrier bags.
In the case of the present document it is still a draft. The European Commission explicitly points out that this has neither been adopted nor endorsed and merely reflects the preliminary view of the Commission services. The final implementing regulation is scheduled to enter into force on the twentieth day following its publication in the Official Journal of the European Union and will be directly applicable in all Member States.
Source: EU Commission
