The planned implementing regulation aims to streamline registration and reporting under the EU Packaging Regulation (PPWR, Packaging and Packaging Waste Regulation, Article 44). The German Chamber of Commerce and Industry (DIHK) considers this generally a potential contribution to greater legal clarity and the avoidance of duplicate reports. However, the draft still allows parallel national procedures and leads to extensive data requirements, which could particularly burden small and cross-border companies.
Background
The Regulation (EU) 2025/40 on Packaging and Packaging Waste (PPWR) includes provisions for producer registration and reporting to producer registers. Based on Article 44 of the PPWR, the draft implementing regulation now establishes a standardized format and the information to be submitted. Reliable data is considered by the economy to be a useful contribution to enforcement and further development of packaging policies. However, reporting obligations should be proportionate, digitally implementable, and practical for companies, the DIHK emphasizes. Specifically, the still-provisioned national registers, additional national requirements, and the extensive breakdown of packaging data could burden the internal market.
Key Facts at a Glance
- The European Commission aims to simplify obligations stemming from the contentious Packaging Regulation. In the assessment of the German Chamber of Commerce and Industry (DIHK), however, uniform registration and reporting formats alone are insufficient. A central European registration system based on the one-stop-shop and once-only principle is necessary.
- The planned reporting on primary material, all material shares, and individual components leads to significant additional data and verification complexity.
- Standardised supplier's declarations and packaging data sheets should suffice for fulfilling reporting obligations. The forwarding of complete technical documentation should not become a de facto requirement.
- The threshold of ten tonnes only reduces the data volume. It does not exempt smaller businesses and companies with occasional cross-border shipments from registration and reporting.
- Publicly accessible data, especially regarding brand names, should be limited to the necessary extent to safeguard confidential supplier relationships.
Economic demands
DIHK appeals to the European Commission and member states to revise the draft. They should:
- establish a central European EPR gateway for registration, master data management, and reporting,
- implement the once-only principle rigorously, to ensure that data already submitted is not requested again,
- define uniform EU-wide definitions, data fields, calculation methods, reporting periods, and machine-readable interfaces,
- avoid additional national administrative acts and authorized representative structures where obligations can be fulfilled and monitored centrally and digitally,
- limit reports to aggregated material quantities necessary for enforcement,
- provide collective categories for minor packaging types, e.g., for shares under one percent of total tonnage,
- allow comprehensible estimation, extrapolation, and sampling procedures, particularly for historical data and varying packaging configurations,
- include additional data categories only when their necessity and legal basis are clearly justified,
- recognize standardized supplier declarations, packaging data sheets, and other reliable evidence as equivalent bases for reports,
- avoid sharing complete design or recipe information and protect trade secrets with clear access rights and the need-to-know principle,
- below a uniform and practical EU-wide volume threshold, enable exemption from reporting or significantly simplified annual reporting,
- provide simplified registration and authorized representative procedures for micro-enterprises and companies with occasional cross-border deliveries,
- design digital systems to prevent duplicate records, allow corrections, and issue understandable error messages,
- not link automated checks with market suspension without warning and a functional correction pathway.
FAQ
Frequently Asked Questions
Which companies are impacted by the planned regulations?
Impacted are companies that bring packaging into circulation within the European Union or sell packaged products across borders. These may include online retailers, direct marketers, regional food producers, craft businesses, and industrial enterprises.
What is the significance of the threshold of ten tonnes?
The draft distinguishes between companies that market at least ten tonnes of packaging per calendar year in a member state and those below this threshold. According to the German Chamber of Commerce and Industry (DIHK), the threshold primarily reduces the scope of data to be reported. Registration, quantity determination, and reporting largely remain even for smaller quantities.
What does a central European EPR Gateway mean?
A European EPR Gateway would centralize registration and reporting. Companies could transmit their data once and use it for multiple member states. This could reduce multiple registrations, parallel national procedures, and additional administrative costs.
Download
The DIHK statement of 10 September 2026 can be accessed here (only available in German):
- Download
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DIHK-Stellungnahme PPWR Herstellerregister
DIHK-Stellungnahme vom 10. September 2026 zum Entwurf zur Festlegung von Durchführungsbestimmungen zur Verordnung (EU) 2025/40 hinsichtlich des Formats für die Eintragung in das Herstellerregister und die Meldung an dieses Register sowie der in diesem Zusammenhang vorzulegenden Informationen
- Information
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File format: PDF (accessible)
File size: 138 KB
Status of: September 2026
Page count: 6 pages
- Relevant in topic:
- Sustainability and Corporate Responsibility
- Key areas:
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- Environment
- Circular Economy
It has been translated with the assistance of AI.
No guarantee is made as to the accuracy or completeness of the translation.
Released 10.09.2026
Modified 11.09.2026
Ansprechpartner
Christoph Petri
Director Environmental and Raw Materials Policy