Packaging reporting

Do you place packaging on the EU market? Then you have reporting obligations. You need to register, report the type and volume of packaging you use, and contribute to national recycling schemes also called PRO's (Producer Responsibly Organizations). Every country has its own rules. And that can get complicated quickly.

The current Packaging Directive stays in place until the end of 2025. From 2026, it will be replaced by the Packaging and Packaging Waste Regulation (PPWR). A new set of EU-wide rules. More detailed. Now’s the time to prepare.

What do the current rules require?

Under today’s EPR (Extended Producer Responsibility) legislation, you’re expected to:

• Register with local authorities or compliance schemes
• Report on packaging types and volumes (by material)
• Pay the required fees for recycling and collection
• Keep your records up to date and available for inspection
  
  The goal: reduce waste, improve recycling and boost circular packaging.
  

Smart, structured and supported. Now and in 2026

Too much to keep up with? That’s where we come in. We make sure your Packaging Reporting is complete, correct and on time. And we help you get ahead of what’s coming.

This is how we work:

• We identify your packaging obligations
  per country
• We handle registrations and local communication
  clearly, without delay
• We collect and verify your data
  clean, consistent, complete
• We submit your reports
  and keep you compliant without stress

Let’s make sure you’re ready. Want to get started?

What’s next: the PPWR

In 2026, the current packaging rules will be replaced by the Packaging and Packaging Waste Regulation (PPWR). This new EU regulation will:

• Apply directly across all member states
• Set stricter requirements on recyclability and design
• Change how, when and what you need to report
  
  Don’t wait until it’s too late.

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Want to learn more? Check out the most frequently asked questions about EPR.

FAQ

• What is packaging EPR?

  Packaging Extended Producer Responsibility (EPR) is a system that holds companies responsible for the packaging they place on the market. In the EU, thisrequirement is part of the Packaging and Packaging Waste Regulation (PPWR) (EU 2025/40), which succeeds the Packaging Directive (94/62/EC).

  What does this mean for you? If your organization sells or supplies packaging, or products in packaging, you help finance the collection, sorting, recycling and disposal of that packaging once it becomes waste. The goal is to reduce packaging waste and to encourage companies to use less packaging and make it easier to recycle, as a step toward a circular economy.

• What counts as packaging?

  Packaging includes all materials used to contain, protect, handle, deliver or present a product, whether to an end user or to another organization. This also includes packaging used for transport or shipping. In short: almost every material that accompanies a product from production to final delivery to the end user can count as packaging.

• Which countries have packaging EPR?

  Within the EU, the PPWR establishes packaging EPR in all 27 Member States. Packaging EPR is not limited to the EU. Countries and states worldwide have their own EPR systems, for example the United Kingdom, Canada, Australia, India, South Africa and several US states. Keep in mind that every EPR system is country specific. Each country or state has developed its own requirements, so the rules you need to follow can differ per market.

  Status at the time of publication: October 2026.

• Who is considered the "producer" under the EU PPWR?

  In general, the producer is the company that first makes packaging or packaged products available on a country's market, regardless of the sales channel used. Whether your organization is the producer depends on several factors. The most important one is your business model: how do you sell or distribute your products? For example, if a Dutch company sells packaged products directly to customers in Germany, that Dutch company may be considered the producer in Germany. In that case, it may need to comply with German packaging rules. When you are considered the producer, and which requirements you need to meet, can differ per country or state.

• What is the role of an Authorized Representative (AR) under the PPWR? And when do you need one?

  An Authorized Representative (AR) is a company or person appointed in a country to handle certain legal obligations on behalf of another company. For packaging EPR, the AR acts as your local representative for compliance communication when your company has no local presence in that country. For example, a company based in the Netherlands that sells directly to consumers in Spain may need an AR in Spain if it has no local entity there.

• What is the difference between the PPWR and packaging reporting?

  PPWR = the legal framework. EPR reporting = one of the obligations within it. The PPWR is the legal basis. Packaging EPR reporting is one of the ways it organizes the financing of packaging collection and recycling. On top of EPR reporting, the PPWR also sets requirements for the packaging itself. These aim to increase recyclability and reduce the amount of packaging that companies use.

• How do reuse and recyclability targets affect packaging design under the PPWR?

  The PPWR encourages companies to (re)design their packaging to reduce packaging waste and use packaging more efficiently. It introduces specific packaging requirements, each with a deadline by which they must be met. For example:

  • Less material: reduce unnecessary packaging materials.
  • Recycled content: increase the use of recycled content.
  • Reuse: develop reusable packaging systems where required.

  In other words, the PPWR stimulates the shift toward more environmentally friendly packaging.

• What is the 50% empty space rule under the EU PPWR?

  By 2030, the PPWR introduces a maximum empty space ratio of 50%. The rule aims to reduce oversized packaging, such as shipping boxes that are only partly filled. It applies in particular to e-commerce and transport packaging. Empty space is not just air. Filler materials such as bubble wrap, packing peanuts and air cushions also count as empty space.

• What is the Declaration of Conformity (DoC) under the PPWR?

  A Declaration of Conformity (DoC) is a formal document in which the manufacturer declares that the packaging complies with the requirements of the PPWR. The manufacturer must prepare the DoC before placing the packaging on the EU market. The DoC is supported by technical documentation. It serves as evidence that the packaging meets the applicable PPWR requirements, such as:

  • packaging minimization
  • recyclability
  • recycled content (where applicable)
  • labeling
  • other design-related obligations

• What can Pincvision do for you?

  Packaging obligations differ per country, and they keep developing. We help you keep an overview:

  • We determine which packaging obligations apply to your organization, where they apply and what you need to do in each country.
  • We support registrations and help collect, structure and enrich the required product and sales data in our automated reporting system.
  • We manage recurring reports on your behalf and monitor legislation, adjusting the process where needed.

  This gives you one centralized approach across Europe, carried out from start to finish, without having to build and maintain all regulatory knowledge and country-specific processes internally. We act as your external team, working closely with yours.