PPWR implementation in the EU: The status in all 27 member states

When the Packaging and Packaging Waste Regulation (PPWR) became applicable across the EU on August 12, 2026, exactly two of the 27 member states had fully aligned their national legislation with it: Germany and Hungary. The rest of the EU sits somewhere between draft legislation, public consultation, and complete silence. For manufacturers, importers, and distributors placing packaging on the market in multiple European countries, that is more than a legal footnote. It means 27 different registers, deadlines, and authorities, all evolving in parallel, while the PPWR itself already applies in full.

This article maps the national implementation status of all 27 EU member states: which country has or plans which law, where it stands in the legislative process, and what that means in practice for your registration, EPR, and authorized representative obligations.

The PPWR is an EU regulation, but national implementation still matters

The PPWR (Regulation (EU) 2025/40) was adopted on December 19, 2024, entered into force on February 11, 2025, and has applied directly in all member states since August 12, 2026. Unlike a directive, an EU regulation does not need to be transposed into national law. That is exactly why this article talks about national implementation rather than transposition: the substantive obligations (conformity assessment, the EU declaration of conformity, technical documentation, labeling, and the PFAS limits for food-contact packaging) apply regardless of whether a given member state has already passed its own law.

What member states still have to regulate: designating competent authorities and market surveillance, adapting existing producer registers and Extended Producer Responsibility (EPR) systems to the PPWR, setting penalties by February 12, 2027 at the latest, and repealing or replacing the old national laws that still rest on the superseded Directive 94/62/EC. That national layer is exactly what the country overview below tracks. For what the PPWR regulates in general and who it applies to, see PPWR explained: The EU Packaging Regulation's deadlines and obligations.

PPWR implementation at a glance: The status of all 27 EU member states

The table below shows the status as of August 26, 2026, sorted from the most advanced to the earliest implementation stage.

The big picture: only Germany and Hungary were fully done when the regulation became applicable. Roughly a third of member states have a draft or bill in progress. The rest currently rely on the regulation's direct effect and their legacy national packaging laws, with February 12, 2027 as the next real deadline, since all member states must have their penalty rules in place by then.

Five implementation clusters: Where individual countries stand

Fully implemented. Germany took the lead with the Packaging Law Implementation Act (VerpackDG): passed by the Bundestag on June 11, 2026, by the Bundesrat on July 10, 2026, published in the Federal Law Gazette on July 17, 2026, and in force since August 12, 2026 (BMUKN law page). The LUCID register remains in place, with fines of up to EUR 200,000 possible. Hungary reached the same point through a staged amendment by decree (Government Decree 412/2025), with MOHU continuing as the EPR concession holder.

Advanced, but not yet final. Italy created the authorization for implementing decrees through its European Delegation Law 2025 (L. 36/2026), due by the end of 2026, and has already issued a first decree on compostable packaging (Gazzetta Ufficiale). France regulated EPR for professional packaging through Décret 2025-1081, while the actual legislative alignment, Article 48 of the DDADUE omnibus bill, still has to pass the National Assembly (Sénat dossier). Sweden has deliberately chosen a staged ordinance adjustment through 2027 instead of a new law, coordinated by the Swedish Environmental Protection Agency (Naturvårdsverket). Belgium regulates EPR through an interregional cooperation agreement (in force since February 9, 2026), but the packaging-specific adjustment itself had not been finally adopted as of late August 2026. Finland, Luxembourg, and Lithuania all have their bills in the parliamentary process, with a target date of August 12, 2026 that was not confirmed as final in any of the three cases.

Draft published, process underway. Denmark, Slovenia, Estonia, Poland, Bulgaria, Czechia, and Spain have all published a draft bill or consultation document, but still have to get through parliamentary adoption. Most visibly: Poland's new Act on Packaging and Packaging Waste (UC100) has been moving through the government legislative process since August 2025, but a date in the Sejm is still pending, and the existing 2013 act is not due to be repealed until 2029. Slovenia's draft decree on EPR and PPWR implementation is in consultation until August 29, 2026, with adoption to follow.

Stalled in parliament. Romania is a special case: there is no government bill, but a parliamentary EPR bill (L26/2026) that the Senate rejected on March 30, 2026, and that is now with the Chamber of Deputies. Until that is resolved, the existing Law 249/2015 remains the only national framework.

No published draft yet. Austria, the Netherlands, Slovakia, Latvia, Ireland, Croatia, Portugal, Greece, Malta, and Cyprus had not published a public draft bill as of late August 2026. That ranges from active preparation (Austria's ministry has at least issued guidance explaining that existing rules continue to apply) to no visible activity at all (Cyprus, Malta). Ireland occupies a middle position: S.I. No. 541/2025 designated the competent authorities, but a broader overhaul of the register and authorized representative rules is still pending.

What manufacturers must do now, regardless of national legislative status

The most important point for practice: your obligations as a manufacturer under the PPWR do not depend on whether your target country already has its own law. Four areas are relevant in every case, though they are often organized differently from country to country.

First, registration in the national producer register. These systems already existed in most countries before the PPWR and are now being adapted step by step: LUCID in Germany, MOHU in Hungary, CONAI in Italy, Verpact in the Netherlands, Repak in Ireland, ISOH in Slovakia. Anyone placing packaging on the market in one of these countries for the first time cannot avoid registering, regardless of whether the national law fully reflects the PPWR yet.

Second, EPR fees. The same principle applies: existing systems continue to run, but are increasingly tiered according to the PPWR's eco-modulation, for example by recyclability. We explain exactly how that works in the LUCID register in EPR under the PPWR: Extended producer responsibility, modulated fees, and registration.

Third, the authorized representative. Under Article 45 of the PPWR, manufacturers with no establishment in an EU member state must appoint an authorized representative in each country where they place packaging on the market. As part of its omnibus package, the European Commission has proposed temporarily suspending this obligation (COM(2025)982), but a final decision was still pending as of late August 2026. Until then, the obligation stands unchanged, and in countries like Ireland the national legal basis to implement it in practice is still missing, which adds further legal uncertainty for manufacturers.

Fourth, the declaration of conformity, technical documentation, and labeling. These obligations follow directly from the PPWR itself and have applied uniformly across the EU since August 12, 2026, independent of any national law. We summarize exactly what you need to provide in PPWR declaration of conformity (DoC): What companies must present since August 2026. If you are unsure which role (manufacturer, importer, supplier, or distributor) determines a given obligation, you'll find the distinctions in Understanding PPWR roles: Producer, manufacturer, importer, supplier, and distributor.

The next deadline: February 12, 2027

Even countries that have not yet published a draft are under time pressure. By February 12, 2027, all 27 member states must have their national penalty rules for PPWR violations in place. For manufacturers, that means the gap between the EU regulation and national enforcement is closing in almost every country at roughly the same time over the coming months, and with it, the window in which uncertainty still works as an excuse. We break down the complete deadline map from 2026 to 2040 chronologically in PPWR deadlines 2026-2040: The complete compliance timeline for companies.

Why 27 different registers become a risk for manufacturers

For a company with operations or sales in just one country, this patchwork is manageable. For industrial companies placing packaging on the market in ten or more EU countries, 27 potentially different registers, reporting deadlines, fee models, and authorities add up to a substantial compliance burden. Precisely where national rules are still changing, as is currently the case in Poland, France, or Belgium, the risk grows that a deadline extension or a new registration requirement simply gets missed.

Status and methodology: The country status in this article is based on research conducted on August 26, 2026, using official ministry, parliamentary, and consultation sources for each member state, corroborated with the PPWR country overview from the Austrian Federal Economic Chamber (WKO) and law firm sources such as Taylor Wessing. Since several processes (including those in France, Belgium, Poland, and Bulgaria) were in a decisive phase in September 2026, the status of individual countries may change at short notice.