Guide

PPWR2027guide:penalties,deadlinesandcompliance

Discover what PPWR enforces from 2027, what your EPR already covers, and the 6 steps to get your packaging data ready before year end.

What's inside
  • Deadline for the 27 national penalty regimes to be in force
  • Packaging waste per European, per year (2023)
  • Per-infringement fine already on the table in France
  • Roadmap to have done before the end of 2026
Dcycle Team ·
LegislationComplianceEUSustainability

On 12 August 2026, Regulation (EU) 2025/40 (PPWR) became fully applicable across the 27 member states. It is not a roadmap, it is binding, directly applicable law that replaced the old Packaging Directive. The next date on the calendar is the one that changes the stakes: from 12 February 2027, every member state must have its penalty regime in force, and the risk stops being reputational and becomes financial and operational.

This 2027 edition maps what is already enforceable today, what your existing EPR scheme already covers in Spain, and the genuinely new obligations that are decided by the packaging data you gather before the end of 2026.

What you’ll find in this guide

  • What has been live since August 2026: PFAS in food contact, recyclability under Art. 6.1, marketplace EPR checks and refill in HORECA
  • Why 2027 is the year penalties arrive, and the four ways the risk hits your P&L
  • What your Spanish EPR already covers (Ley 7/2022, RD 1055/2022) and the real delta
  • Recyclability grades A to C, minimum recycled content and digital labelling (QR), each with its deadline
  • How to tell the manufacturer role apart from the producer role, and who answers in an audit
  • The master timeline from 2025 to 2040, and the 6 steps to have done before year end

Download the full guide

If you already report to a national EPR scheme, the paperwork side is mostly handled. What is genuinely new lives in packaging design and in the technical data of every format you place on the market. When an audit lands, or a marketplace asks for your valid registration before it lets you sell, the difference between answering in hours or in weeks is whether your packaging data is connected to its real source.

Over 2,000 companies use Dcycle to collect packaging, material and supplier data once and reuse it across PPWR, CSRD and their carbon footprint. Request a demo and reach February 2027 with your data in order.

PPWR 2027 guide: penalties, deadlines and compliance

Download the full resource for free.

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Key highlights

12 Feb 2027 Deadline for the 27 national penalty regimes to be in force
178 kg Packaging waste per European, per year (2023)
€100,000 Per-infringement fine already on the table in France
6 steps Roadmap to have done before the end of 2026

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