When must I submit my packaging return?

The deadline varies by country of registration

There is no fixed European date for packaging reporting: it is determined by the producer register of the country where the packaging is first placed on the market. The PPWR requires registration in each such country, but the regulation itself does not prescribe a reporting deadline — each national register regulates that separately.

In the Netherlands, Verpact currently applies a threshold: registration is not mandatory for packaging under 50,000 kg per year on the Dutch market, although record-keeping still applies. Verpact indicates that this threshold is expected to be withdrawn once the PPWR producer register becomes operational, at the earliest from 12 August 2027, with 2028 as the first reporting year and declaration before 1 June 2029. For companies under 10,000 kg, a simplified declaration will then apply. In Germany, LUCID has no threshold: registration applies from the first packaging, and in practice marketplaces block sellers without a registration number even before a supervisor addresses it. Anyone remaining below the threshold in the Netherlands but also supplying to Germany is therefore already a producer there from that first package. For Belgium (Fost Plus and Valipac), France (CITEO) and Austria, the exact deadlines and thresholds have not yet been verified — for those countries the official source of the register is the starting point.

What Article 44 of the PPWR requires

Article 44 of Regulation (EU) 2025/40 requires registration in the producer register of each country where packaging is first placed on the market, and determines that packaging from an unregistered producer may not be traded; the precise reporting deadline and frequency are set by the national register, as Verpact demonstrates for the Netherlands.