PPWR – Reporting instructions

Branded packaging

Operators that had producer responsibility until 11 August 2026:

• Companies that pack products in packaging bearing another company's brand
• Companies that manufacture branded service packaging or primary production packaging
  

→ If any of the above applies to your company, report branded packaging placed on the market up to 11 August 2026.

Operators with producer responsibility from 12 August 2026:

• Companies that have packaging manufactured or designed under their own name or trademark
• Companies that order custom-made packaging
  

→ If any of the above applies to your company, report branded packaging placed on the market from 12 August 2026 onwards.

Exceptions for micro-enterprises and imports

The change in producer responsibility for branded packaging does not apply to a micro-enterprise if the packaging supplier is located in the same Member State. In this case, producer responsibility may shift to the packaging supplier.

→ If your company meets the criteria for a micro-enterprise, continue to report branded packaging as you did before the change on 12 August 2026. However, a micro-enterprise is still subject to producer responsibility as an importer.

Criteria for a micro-enterprise:

• fewer than 10 employees
• annual turnover or balance sheet total of no more than EUR 2 million.

For imports of branded packaging, the importer has producer responsibility unless the products are sold directly to end users through distance selling. This applies to companies of all sizes.

Transport packaging

Operators that had producer responsibility until 11 August 2026:

•  Companies that pack products in transport packaging or import transport packaging
  

→ If any of the above applies to your company, report transport packaging placed on the market up to 11 August 2026.

Operators with producer responsibility from 12 August 2026

• Branded transport packaging: companies whose name or trademark appears on the packaging
• Unbranded transport packaging: companies that manufacture or import generic transport packaging

→ If any of the above applies to your company, report transport packaging placed on the market from 12 August 2026 onwards.

Note on imports: The importer reports both branded and unbranded transport packaging if the importer is not the end user.  

New packaging to be reported  

PPWR has brought new types of packaging under producer responsibility reporting.

From 12 August 2026, tea bags and coffee capsules must also be included in producer responsibility reporting.

Tea bags are reported as:

• Consumer packaging
• Single-use
• According to main material
  • Paper-based tea bags – Fiber packaging
  • Mesh and pyramid tea bags (nylon, PET, PLA) – Plastic packaging
  • In detailed reporting, other materials should also be taken into account (e.g. label and string)
    
  
  

Coffee capsules are reported as:

• Consumer packaging
• Single-use
• According to main material
  • Aluminum capsules – Metal packaging
  • Plastic capsules – Plastic packaging
  • Biodegradable capsules (PLA) – Plastic packaging
  • Plastic body and aluminium lid – reported separately as plastic packaging and metal packaging