EU PPWR FAQs Updated August 2026 - Flipbook - Page 63
Finally, the PPWR also harmonises the criteria for eco-modulation of EPR-fees. The ecomodulation
will be based on the recyclability performance grades set in Article 6. Member States are allowed
to use additional criteria, such as reusability and recycled content, when they apply the framework
for eco-modulation in their national EPR schemes.
In other areas, Member States continue to have a wide flexibility to organize EPR systems and
waste management according to the national conditions and legal settings.
3) Which is the first calendar year that producers must report to the register of
producers?
All Member States shall establish a register of producers that producers must register in and report
to. By February 2026, the Commission shall adopt an implementing act laying down the format for
EPR registering in and reporting to the EPR register (Article 44(14) PPWR). Member States will
have 18 months to establish the register after the adoption of the act (Article 44(1) PPWR).
Producers shall report by June for each full preceding calendar year, and producers will therefore
have to report to the national EPR registers according to the new harmonised rules for the first time
by 1 June 2030.
4) What is the scope of the activities that online platforms can fulfil on behalf of their
sellers?
Based on a written mandate by producers, online platforms can offer to pay the EPR fees in each
Member State where the packaging or packaged products are made available on the market directly
to consumers (Article 45(4) PPWR). However, only the producer, or its PRO or authorised
representative, is responsible for the EPR registration and reporting. An online platform cannot
fulfil these obligations on their behalf unless the producer has chosen to appoint the platform as an
authorised representative.
5) Does an online platform need to check every producer before allowing them to use the
platform?
To prevent free riding as regards EPR obligations, and in line with the obligations in the Digital
Services Act (DSA)33, the PPWR provides that online platforms that allow consumers to conclude
distance contracts with producers shall obtain information from producers that they are registered
in the EPR register in the Member State where the consumer resides and a self-certification
confirming that their EPR-obligations for packaging are fulfilled.
The online platform shall obtain this information prior to allowing the producers to use the
platform9s services. The online platform shall make best efforts to assess whether the information
provided is reliable and complete, by using or verifying freely available online databases and online
interfaces (Article 45(6) PPWR). This may include requesting the producers to provide supporting
documents (Article 45(8) PPWR). Making best efforts usually requires the verification of the
information provided by the producer with the data in the register of producers.
6) Can Member States ask for information beyond what is specified in the PPWR to
monitor extended producer responsibility obligations? NEW!
The PPWR harmonises the information to be provided when producers register and report amounts
of packaging made available, collected and recycled in a Member State to a Member State9s register
of producers.
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Regulation (EU) 2022/2065 of the European Parliament and of the Council of 19 October 2022 on a Single Market
For Digital Services and amending Directive 2000/31/EC (OJ L 277, 27.10.2022, pp. 13 102)
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