The PPWR has applied since 12 August 2026. Many companies waited for that date expecting it to change their relationship with EPR fees. That is not quite what happened. Regulation 2025/40 creates no producer responsibility organisation, sets no tariff and collects nothing. What it changes is quieter and more structural: it redefines who owes the fee, and it puts in place the mechanism that will determine, in time, what each packaging item costs. In the meantime, it is French law that moved, with the launch of the commercial packaging EPR scheme on 1 July 2026.

Two layers that should not be confused

The most common mistake is to place the PPWR and the producer responsibility organisation on the same level. They are two distinct layers.

The PPWR sets the framework. Its Article 44 requires registration in a producer register in every Member State where you first make packaging available. Its Article 45 establishes extended producer responsibility and requires, for a producer not established in a given country, the appointment of an authorised representative for that responsibility. The regulation says who must answer, and for what.

Implementation remains national. Member States accredit the producer responsibility organisations, approve the fee schedules and organise collection. In France, registration goes through the unique identifier issued by ADEME, and joining an accredited organisation remains the standard way of transferring your operational obligations.

In other words: the PPWR does not replace your producer responsibility organisation. It changes the question of whether you are the one who has to join it.

What genuinely changed in 2026

The commercial packaging EPR scheme went live

This is the most concrete change of the year, and it is French rather than European. The decree of 17 November 2025 merged the food service packaging stream with the then forthcoming industrial and commercial packaging stream. The unified scheme has been operational since 1 July 2026.

Three producer responsibility organisations were accredited in early June 2026: Citeo Pro, Léko Pro and Twiice. Their fee schedules were published shortly afterwards, in mid-June. We covered the subject while the framework was still being built, in our article on the commercial packaging EPR scheme; the waiting is over, the schedules exist.

One point deserves flagging for companies that have only ever dealt with Citeo on household packaging: on this stream, you have a choice. The gaps between the three schedules are narrow on plastics, wider on board and wood. Depending on your material mix, the choice of organisation is not a neutral one.

The party commissioning the packaging becomes a producer

This is the real change the PPWR brings to the fee question, and it has gone relatively unnoticed.

The regulation broadens the notion of manufacturer: a manufacturer is not only the party that makes the packaging, but also the party that has it designed or made on its own behalf, under its own brand. Anyone commissioning packaging is therefore treated as a producer, and owes the EPR fee.

In practice, this ends an ambiguity the French market had kept alive around private label and own-brand products. A company that has packaging made in its own colours can no longer treat the fee as its converter’s business. It is the business of both, each in its own capacity.

What did not change, whatever you may hear

Three misconceptions are proving particularly resilient.

There is still no turnover threshold. On commercial packaging, the obligation arises with the first item made available on the French market. Volume determines the amount of the fee, never whether the obligation exists.

There is still no size-based exemption. The relief the PPWR provides for micro-enterprises concerns the conformity of the packaging, not EPR. We set out that boundary in our article on the PPWR and micro-enterprises. Organisations do offer flat-rate arrangements for small volumes, which keeps the fee modest, but that is an adapted tariff, not a waiver. Amounts vary between organisations and from year to year: check the schedule in force rather than a figure read somewhere.

Registration remains the gateway. Without a unique identifier there is no listing on marketplaces, and non-compliance is easy to establish. It is the simplest checkpoint, for an authority and for a customer alike.

What will change the amount: fee modulation by grade

French EPR fees were already modulated, through bonuses and penalties defined stream by stream. The PPWR changes the scale of that mechanism by making it European and tying it to a grade.

The regulation provides for each packaging item to be graded on its recyclability performance: grade A from 95 % recyclability by mass, grade B from 80 %, grade C from 70 %. Below 70 %, packaging is treated as non-recyclable for the purposes of the regulation.

Two consequences answer each other. The first is a market access threshold: from 1 January 2030, only packaging reaching at least grade C may be placed on the Union market, and from 1 January 2038 grade C drops out in turn. The second is financial: fees paid to producer responsibility organisations will have to be modulated according to these grades. The better your packaging is graded, the less it costs.

The timing still depends on the delegated acts that will set the detailed design-for-recycling criteria. The Commission is due to adopt them by 1 January 2028, and modulation by grade is to apply within eighteen months of their entry into force. Worth noting: modulation based on recycled content remains optional for Member States. Recyclability alone becomes a mandatory cost variable.

That is precisely what makes recyclability a design subject rather than a communication one, as we explain in our article on recyclability by design.

What to do now

Start by checking your actual status. Many companies see themselves as simple buyers of packaging when own-brand work or buying and reselling makes them producers. That is the starting point, set out in who is affected by the PPWR.

Next, check that you are covered on both streams. A company selling to consumers and to businesses falls under household packaging and commercial packaging alike, with separate memberships. Since July 2026, an oversight there concerns a live scheme.

Finally, compare the schedules before renewing by default. On commercial packaging, three offers coexist and your volumes by material will make the difference.

The EPR Responsibilities tool places your case in a few questions and lists your concrete obligations. The regulatory roadmap gives you the deadlines, and the complete PPWR guide covers every requirement in detail.

A question about your specific situation? Write to us at contact@packaginghub.fr.