PPWR: The Producers’ Register and Packaging Administration

The Producers’ Register and Packaging Administration

Proof of Responsibility

In this second part of our two-part series, the focus shifts from responsibility to proof.

The Producers’ Register and Packaging Administration

Proof of Responsibility

In this second part of our two-part series, the focus shifts from responsibility to proof.
Where Article 45 of the PPWR (Extended Producer Responsibility) defines who is responsible for packaging placed on the market, Article 44 explains how that responsibility becomes visible and verifiable through the Producers’ Register. The two are inseparable: without registration, no proof; without administration, no insight. We can expect the official format for this register no later than 12 February 2026, and 18 months later the register must be operational. It sounds far away, but time flies—especially if setting up your own internal administration still requires some effort.

A coherent system

According to Article 45, the producer remains ultimately responsible, but may organise their obligations through a recognised producer organisation (Article 46). In the Netherlands, this is of course Verpact. Regardless of how the responsibility is fulfilled, one element is unavoidable: registration. Article 44 obliges all market players who place packaged products on the EU market—large or small, within or outside the EU—to register. The register forms the basis for a complete reporting system that enables Member States to monitor whether packaging targets are being met.

That system is not intended to punish, but to ensure a level playing field. Foreign sellers and drop-shippers fall under the same obligation. Producers placing more than 1,000 kg of packaging material on the market per year must register. That is almost everyone. This creates one transparent system in which data is centralised to verify compliance and prevent unfair competition.

Data with meaning

In addition to individual registrations, the register also tracks total packaging volumes per Member State. Companies already reporting to Verpact (from 50,000 kg of packaging per year) are familiar with this principle. By extending the scope to nearly the entire market, Europe gains—for the first time—a complete overview of how much packaging is truly in circulation and how progress on reduce, reuse, and recycle is developing.

This data collection therefore becomes strategically valuable. It forms the basis for policy, innovation, and benchmarking between Member States. The register becomes not just an administrative tool, but also a source of insight into where the greatest (environmental) gains can be achieved.

The administration itself

You register yourself as a producer, but not your individual packaging items. The exact implementation will follow no later than 12 February 2026 (Article 44, paragraph 14). What must be included are the totals—similar to what is currently required by Verpact—but you remain responsible for fulfilling the full scope of EPR. The administration proving that you comply with Article 45 is held locally, but must be retrievable. That means your internal administration must be accurate and audit-proof. Annex VII describes a conformity assessment procedure (a great hangman word) guiding you step-by-step through the sustainability requirements of your packaging and the elements of your packaging dossier—and Annex VIII contains the declaration itself.

A well-structured process makes the difference between reactive compliance and proactive steering. The associated administration provides insight into material use, recyclability, and optimisation opportunities. Anyone who actively uses this information can simultaneously save costs, reduce risks, and accelerate sustainability.

From obligation to strategy

As with producer responsibility, the same applies here: those who see the administration solely as an obligation will struggle with it. But those who use it as a guide will discover that the PPWR offers a roadmap to structural sustainability. The administration is not only proof of compliance but also a mirror of progress. Those who have their packaging data in order can justify decisions, demonstrate success, and convince customers. By linking responsibility, registration, and proof, the PPWR becomes not an obstacle but a catalyst for innovation.

Section 3 of the PPWR defines who is responsible, how that responsibility is controlled, and where the proof lies. Those who connect these three elements in time—and intelligently—transform compliance into competitive advantage.