JBCE Feedback on PPWR Rules on National Registers

On 9 September 2026, JBCE published its position paper on the European Commission’s consultation on rules on national registers of producers under the Packaging and Packaging Waste Regulation (PPWR).

JBCE welcomes the European Commission’s initiative to establish harmonised requirements for producer registration and reporting under Article 44 of the PPWR. While a harmonised framework has the potential to reduce administrative burdens, improve consistency across Member States and strengthen the functioning of the EU Single Market, further efforts are needed to ensure practical implementation, reflect the availability of data in practice, and maintain a clear distinction between technical documentation and EPR reporting obligations

Key messages:
• Ensure EU Harmonisation Before National Implementation
• Eliminate Duplicate Reporting and Reduce Administrative Burden
• Reduce Compliance Burdens for Cross-Border Operators
• Align Reporting Requirements with the Policy Objectives of the PPWR
• Ensure Practical Data Availability is Reflected in Reporting Requirements
• Clear Separation Between Technical Documentation and EPR Reporting Obligations

For more information, please contact info@jbce.org