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Requirement · OPS-05

Before making packaging available, verify that the producer is registered in the Art. 44 register, that the packaging carries its Art. 12 labelling, and that the manufacturer and importer have marked their identification; do not make it available until any non-compliance is corrected.

Distributors of packaging must comply, and this is law in force.

Why it matters

This is law in force, not a proposal.

  • It is Art. 19(1) to (3), in the Packaging and Packaging Waste Regulation. as of 2026-08-18
  • The act gives its timing as: From 12 August 2026 (Art. 71). as of 2026-08-18
  • It names one industry by name: Retail. as of 2026-08-18
  • Compliance is checked by documentary check on the producer register, continuous. as of 2026-08-18
Addressee Distributors of packagingAct Regulation (EU) 2025/40, base actArticle Art. 19(1) to (3)Class Businesses

What changes

Wholesalers and retailers. A due-diligence duty over the register and the labelling of everything they stock, plus a duty to protect conformity during their own storage and transport.

The rule

New — no predecessor
Trigger

before making packaging available on the market

Obligation

Before making packaging available, verify that the producer is registered in the Art. 44 register, that the packaging carries its Art. 12 labelling, and that the manufacturer and importer have marked their identification; do not make it available until any non-compliance is corrected.

Who is affected

Addressee
Distributors of packaging
Class
Businesses
Sectors
Names Retail and distribution · Reaches Plastics converting, Paper and board, Glass and ceramics, Aluminium and metals, Wood and wood products, Food, drink and tobacco
Applies
From 12 August 2026 (Art. 71)

Burden drivers

D1 · D5 — 2 of 7 marks fire on this provision.

No size threshold.

Source text

Verbatim

Before making packaging available on the market, distributors shall verify that: (a) the producer that is subject to the obligations on extended producer responsibility for the packaging is registered in the register of producers referred to in Article 44; (b) the packaging is labelled in accordance with Article 12; and (c) the manufacturer and the importer have complied with the requirements set out in Article 15(5) and (6) and Article 18(3), respectively.

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