The PPWR says every producer must register. But the new "EU producer register" doesn't exist yet. If you've been waiting for a European system to open, you're waiting for the wrong thing.
TL;DR — The new EU producer register has no opening date yet — but the registration duty is already in force, so register today with the national registers that already work.
The obligation is live; the register is not
Two different things are easily confused. The registration duty (Article 44(4)) has applied since 12 August 2026 — you may not make packaging available without being registered. But the PPWR's new producer register has no opening date.
Why the register has no date
Each member state must set up its register within 18 months of the first implementing act under Article 44(14) — the act that fixes the registration and reporting format. That act was due by 12 February 2026 and has not been published. The 18-month clock has therefore not started. Any claim that "the register opens in 2027" is conjecture, not a date.
So where do you register today?
With the national registers that already exist and already issue the numbers marketplaces and authorities accept:
- Germany — LUCID
- Belgium — Fost Plus / Valipac, overseen by EPRiBEL
- France — ADEME via its producer responsibility organisations
- Poland — BDO
The PPWR obligation is fulfilled through these until the new EU register replaces them. Waiting for the new system means waiting for the wrong thing — the duty is already in force.
For non-EU sellers, representation comes first
If you're not established in the country of sale, you must appoint an authorised representative there before you can register — and the AR itself must be registered (in Belgium, with EPRiBEL).
The practical takeaway: don't wait for an EU register that has no date. Register today with the national registers that already work — the obligation is already in force, and marketplaces are already checking.
Sources: PPWR Packaging — the producer register and myDPP — PPWR current status.
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