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Requirement · REG-01

Register in the national producer register of every Member State where you first make packaging or packaged products available, or where you unpack packaged products without being an end user, supplying the Annex IX Part A information; do not make packaging available at all until registered.

Producers of packaging and packaged products must comply, and this is law in force.

Why it matters

This is law in force, not a proposal.

  • It is Art. 44(2), (4) and (5), in the Packaging and Packaging Waste Regulation. as of 2026-08-18
  • The act gives its timing as: 18 months after the first Art. 44(14) implementing act (Art. 44(1)). as of 2026-08-18
  • It names 7 industries by name: Plastics converting, Paper and board, Glass, Aluminium, Wood, Food and drink and Retail. as of 2026-08-18
  • Compliance is checked by competent authority, within 12 weeks, per Member State, then on change. as of 2026-08-18
Addressee Producers of packaging and packaged productsAct Regulation (EU) 2025/40, base actArticle Art. 44(2), (4) and (5)Class Businesses

What changes

Every producer selling packaged goods into more than one Member State faces up to 27 separate registrations. Genuinely new at Union level: 94/62/EC had no producer register, only the Art. 7(2) requirement that EPR schemes exist by end-2024. Art. 44(11)(d) lets competent authorities charge cost-based registration fees.

The rule

New — no predecessor
Trigger

first making packaging or packaged products available in a Member State, or unpacking without being an end user

Obligation

Register in the national producer register of every Member State where you first make packaging or packaged products available, or where you unpack packaged products without being an end user, supplying the Annex IX Part A information; do not make packaging available at all until registered.

Who is affected

Addressee
Producers of packaging and packaged products
Class
Businesses
Sectors
Names Plastics converting, Paper and board, Glass and ceramics, Aluminium and metals, Wood and wood products, Food, drink and tobacco, Retail and distribution · Reaches Waste and landfill, Hotels, restaurants and catering
Applies
18 months after the first Art. 44(14) implementing act (Art. 44(1))

Burden drivers

D1 · D3 · D7 — 3 of 7 marks fire on this provision.

No exemption from registration by size. The 10-tonne threshold in Art. 44(8) reduces what must be REPORTED, not whether registration is required -- see REG-02.

Source text

Verbatim

Producers shall be obliged to register in the register referred to in paragraph 1 of this Article in each Member State where they make packaging or packaged products available on the territory of the Member State for the first time

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