Regulatory changelog: what changed in the datasets, and when.

2026-10-03 — law-watch run

The periodic law-versus-app audit compared the datasets with the text of Regulation (EU) 2025/40 and jätelaki 646/2011. Every entry below was re-read against the official text on 2026-10-03; the quoted words are the law's own. DATASET_VERSION moves from v2026-08-01 to v2026-10-03. PPWR_TIMELINE now holds 44 rows: two bundled rows were split so that a fixed date and an act-dependent date no longer share one status. Act adoption status is this run's check of the Commission's Have Your Say records and the Publications Office: the Art 44(14), Art 12(6) and Art 13(2) implementing acts had not been adopted on 2026-10-03. Each changed English string is a dictionary key, so its Finnish, Swedish and German entries were re-keyed with it.

• 2026-10-03 · EU · DATASET_VERSION · v2026-08-01 → v2026-10-03.
• 2026-10-03 · EU · PPWR_TIMELINE 2026-02-12 "Art 44" · "gates the national register go-live 18 months after it enters into force" → "each Member State must establish its national register within 18 months of the act entering into force (Art 44(1)): an outer deadline, not a go-live date, so a register may be established or designated earlier". Art 44(1) reads "Each Member State shall, within 18 months of the date of entry into force of first implementing act adopted pursuant to paragraph 14, establish a national register". Source: Regulation (EU) 2025/40, Art 44(1)
• 2026-10-03 · EU · PENDING_ACTS "Art 44(14)", what it blocks · "National register go-live (EIF + 18 months)" → "National register deadline — Member States must establish it within 18 months of the act entering into force (Art 44(1)); a register may exist earlier". Same Art 44(1) wording. Source: Regulation (EU) 2025/40, Art 44(1)
• 2026-10-03 · EU · PPWR_TIMELINE 2026-08-12 "Art 14" · "Environmental claims about packaging allowed only for properties EXCEEDING the PPWR minimums … misleading sustainability labels barred (Art 12(8))" → claims "about packaging properties for which the PPWR sets requirements" only where the property exceeds the applicable minimum; claims about other properties stay under Directive 2005/29/EC as amended by Directive (EU) 2024/825; and the Art 12(8) clause now states the prohibition's scope as the text does: "without prejudice to other harmonised EU labels, labels, marks, symbols or inscriptions likely to mislead or confuse consumers or other end users with respect to the sustainability requirements for packaging, other packaging characteristics or packaging waste management options for which harmonised labelling has been laid down in the Regulation are barred". Art 14 reads "Environmental claims as defined in Article 2, point (o), of Directive 2005/29/EC concerning packaging properties for which legal requirements are set out in this Regulation may be made in relation to packaging placed on the market if they fulfil the following requirements". Art 12(8) bars labels "that are likely to mislead or confuse consumers or other end users with respect to the sustainability requirements for packaging, other packaging characteristics or packaging waste management options for which harmonised labelling has been laid down in this Regulation"; it opens "Without prejudice to requirements concerning other harmonised EU labels". Source: Regulation (EU) 2025/40, Arts 12(8) and 14
• 2026-10-03 · FR · COUNTRY_REQUIREMENTS caveat and EPR_REGISTERS_EU authorised-representative field · "the PPWR requires an EPR authorised representative of every producer under Art 3(1)(15)(c)-(d) … (Art 45(3)); a Member State may also require one of producers established in third countries (Art 45(3) second sentence)" → the duty is stated on the first sentence for every (c)-(d) producer "whether established in another Member State or in a third country", and "the second sentence of Art 45(3) is a separate option letting a Member State require a representative of producers established in third countries when they first make packaging available on its territory". Art 45(3) reads "A producer referred to in Article 3(1), point (15)(c) and (d), shall appoint, by written mandate, an authorised representative for the extended producer responsibility in each Member State where the producer makes packaging or packaged products available for the first time, other than the Member State where the producer is established. Member States may provide that producers established in third countries shall appoint, by written mandate, an authorised representative for the extended producer responsibility when making packaging or packaged products available on their territory for the first time." The French statements (R. 541-174 "peut désigner") are unchanged. Source: Regulation (EU) 2025/40, Art 45(3)
• 2026-10-03 · EU · PPWR_TIMELINE 2026-08-12 "Art 70(1)" · two bridges named → all four. Added: for Member States, Directive 94/62/EC Arts 5(2)-(3), 6(1)(d)-(e), 6a, 12(3a)-(3c) and 12(4) continue until 31 Dec 2028, and their data transmission to the Commission until 31 Dec 2029. Art 70(1)(c) reads "Article 5(2) and (3), Article 6(1), points (d) and (e), and Article 6a of Directive 94/62/EC, which shall continue to apply until 31 December 2028". Source: Regulation (EU) 2025/40, Art 70(1)
• 2026-10-03 · EU · PPWR_TIMELINE 2027-06-01 "Art 44(7)", text and status · UPCOMING → PENDING_ACT. The row now says the return is due "for each full preceding calendar year" to the authority responsible for the Art 44(1) register, that 1 June 2027 is the earliest first return, and that it falls due only once the national register exists. The date stays. Art 44(7) requires the information to be submitted "to the competent authority responsible for the register, by 1 June for each full preceding calendar year"; the Art 44(14) act was a draft (feedback closed 10 September 2026), not adopted. Sources: Regulation (EU) 2025/40, Art 44(7), Have Your Say 15352
• 2026-10-03 · EU · PPWR_TIMELINE 2027-02-12 "Art 10/11/25/68" (one row, act pending) → two rows: "Art 11(2)", the minimum-rotations delegated act, still act pending; and "Art 10/25/68", the Commission's minimisation standardisation request and Annex V guidelines and the Member States' penalty rules, now a fixed date. Only Art 11(2) is an act: it says "the Commission shall adopt a delegated act in accordance with Article 64". Art 25(6) reads "By 12 February 2027, the Commission shall publish guidelines", and Art 68(1) reads "By 12 February 2027, Member States shall lay down the rules on penalties applicable to infringements of this Regulation". Source: Regulation (EU) 2025/40, Arts 10(3), 11(2), 25(6), 68
• 2026-10-03 · EU · PENDING_ACTS "Art 68" · "Exact figures only — Art 68(2) already fixes that breaches of Arts 24-29 MUST carry administrative fines in every Member State" → the penalties "include administrative fines or, where a Member State's legal system has none, fines imposed by its competent national courts on the authority's initiative"; the subject now says it is a Member State duty, not a Commission act. Art 68(2) reads "Where the legal system of the Member State does not provide for administrative fines, this paragraph may be applied in such a manner that the fining procedure is initiated by the relevant authority and that the fine is imposed by competent national courts". Source: Regulation (EU) 2025/40, Art 68(2)
• 2026-10-03 · EU · PPWR_TIMELINE 2028-01-01 "Art 6" · "economic operators then have 3 years from each act's entry into force to comply with new or updated criteria" → "the first criteria apply from 1 Jan 2030 or 24 months after these acts enter into force, whichever is later (Art 6(2)-(3)); when the criteria are later updated or new ones added, economic operators have 3 years from the amending act's entry into force to comply (Art 6(4))". Art 6(4) reads "Economic operators shall comply with new or updated design for recycling criteria within 3 years of the date of entry into force of the relevant delegated act". Source: Regulation (EU) 2025/40, Art 6(3)-(4)
• 2026-10-03 · EU · PPWR_TIMELINE 2028-02-12 "Art 9(1)/24(4)" · the Art 9(2)(a) Member State option no longer sits under the 12 February 2028 "fixed dates". It is now stated as open since 12 Aug 2026, with its bio-waste condition. Art 9(2) sets no date: "Member States may require that the following packaging shall be made available on their territory for the first time only if the packaging is compostable". The option is open from the Regulation's application date; Art 71 reads "It shall apply from 12 August 2026." Source: Regulation (EU) 2025/40, Arts 9(2) and 71
• 2026-10-03 · EU · PPWR_TIMELINE 2029-01-01 "Art 50" · "wine, aromatised wine and other fermented beverages, spirits, and milk and milk products excluded, containers under 0.1 l may be exempted" → the exclusion names the grapevine categories Art 50(4)(a) lists (sparkling wine, points 4-7, not among them), "other fermented beverages of CN 2206 00", spirits of CN heading 2208, milk and milk products, and the Member State option for under 0.1 l "where participation is not technically feasible". Art 50(4)(a) reads "categories of grapevine products listed in points 1, 3, 8, 9, 11, 12, 15, 16 and 17, Part II of Annex VII to Regulation (EU) No 1308/2013 or for aromatised wine products as defined in Regulation (EU) No 251/2014". Source: Regulation (EU) 2025/40, Art 50(4)
• 2026-10-03 · EU · PPWR_TIMELINE 2029-02-12 "Art 67(5)" · "take-away food containers" → "food containers for immediate consumption (on-the-spot or take-away, typically eaten from the receptacle, no further preparation)". Point 7 as replaced covers food "intended for immediate consumption, either on-the-spot or take-away". Source: Regulation (EU) 2025/40, Art 67(5)
• 2026-10-03 · EU · PPWR_TIMELINE 2030-01-01 "Art 6/7/10/24/25" (one row, upcoming) → two rows: "Art 10/25", the fixed-date minimisation duty and Annex V restrictions, upcoming; and "Art 6/7/24", the grade floor, recycled-content minimums and 50 % empty-space cap, now act pending, because each applies only from 1 January 2030 or a period after its act, whichever is later. Art 6(3) reads "from 1 January 2030 or 24 months from the entry into force of the delegated acts adopted pursuant to paragraph 4 of this Article, whichever is the latest, packaging shall not be placed on the market unless it is recyclable within grades A, B or C". Source: Regulation (EU) 2025/40, Arts 6(3), 7(1), 10(1), 24(1), 25(1)
• 2026-10-03 · EU · PPWR_TIMELINE 2030-01-01 "Art 28(5)" · "to refill stations" → "to refill stations for both food and non-food products". Art 28(5): final distributors "shall endeavour to dedicate 10 % of that sales area to refill stations for both food and non-food products". Source: Regulation (EU) 2025/40, Art 28(5)
• 2026-10-03 · EU · OPERATOR_ROLES final distributor · "endeavour 10% of sales area to refill" → "endeavour to dedicate 10% of sales area to refill stations for both food and non-food products, from 1 Jan 2030". Same Art 28(5) wording. Source: Regulation (EU) 2025/40, Art 28(5)
• 2026-10-03 · EU · ANNEX_V_BANS point 3 question · "Member States may allow micro-enterprises to continue" → adds "where it has been demonstrated that doing without such packaging, or getting access to the infrastructure a re-use system needs, is not technically feasible". Art 25(4) allows it only "where it has been demonstrated that it is not technically feasible not to use such packaging or to obtain access to infrastructure that is necessary for the functioning of a re-use system". Source: Regulation (EU) 2025/40, Art 25(4)
• 2026-10-03 · EU · RETENTION_RULES note · "supply-chain traceability records under Art 22" no longer sit under the placing-on-the-market start date. The note now says that the supplier identity (Art 22(1)(a)) is kept 5 or 10 years "from the date it supplied or was supplied with the packaging". It also has Finnish, Swedish and German text for the first time. Art 22(2)(a) reads "as regards single use packaging: for 5 years from the date they supplied or were supplied with the packaging". Source: Regulation (EU) 2025/40, Art 22(2)
• 2026-10-03 · ES · COUNTRY_REQUIREMENTS headline and caveat citations · "(Art 13(2), same date)" and "(Art 13(2))" → "(RD 1055/2022 Art 13(2), same date)" and "(RD 1055/2022 Art 13(2))". Bare "Art 13(2)" reads as the PPWR, where it is a Commission duty to adopt receptacle-label acts. The Spanish duty is RD 1055/2022 art. 13.2: "Los envases indicarán su condición de reutilizable" and "Los envases domésticos indicarán la fracción o contenedor en la que deben depositarse dichos residuos de envases" (BOE consolidated text, fetched 2026-10-03). Sources: Real Decreto 1055/2022 (BOE), Regulation (EU) 2025/40, Art 13(2)
• 2026-10-03 · GB · COUNTRY_REQUIREMENTS caveat, Northern Ireland · not stated → "by Article 13(3) of the Windsor Framework the PPWR applies to and in the UK in respect of Northern Ireland in place of Directive 94/62/EC", except the provisions the Commission notice lists. The UK pEPR statements are unchanged. The notice reads "the reference to Directive 94/62/EC in point 25 of Annex 2 to the Windsor Framework shall therefore now be read as referring to Regulation (EU) 2025/40" and "Those provisions are: — Article 23; — Articles 29-33; — Article 34 and Article 56(1)(b) unless the United Kingdom in respect of Northern Ireland takes measures to achieve a sustained reduction in the consumption of lightweight plastic carrier bags in accordance with Article 34(1); — Articles 41-55; — Paragraphs 1(a), 1(c) and 6 of Article 56; and — Articles 57 and 63." Both quotes were verified live on 2026-10-03. Source: Commission notice C/2025/946 (Publications Office), CELEX 52025XC00946
• 2026-10-03 · FI · FI_THRESHOLD_HISTORY 2024 and 2025 rows · "producer responsibility follows the VAT small-business limit" / "VAT small-business limit EUR 20,000 …" → "the statutory test is professional operation ("ammattimaisesti") … no VAT or turnover figure is written into it". The VAT limit (EUR 15,000 in 2024, EUR 20,000 from 2025) is kept as the authorities' practical sign, and from 12.8.2026 the packaging producer is defined by PPWR Art 3(1)(15) (§48(1)(6)). An unused dictionary entry with the same reading was removed. Jätelaki § 6(1)(15) reads "tuottajalla ammattimaisesti tuotteita markkinoille saattavaa luonnollista henkilöä tai oikeushenkilöä, joka eritellään tuotekohtaisesti tarkemmin 48 §:ssä"; neither jätelaki nor VNA 1029/2021 contains a VAT test. Source: jätelaki 646/2011, § 6 and § 48
• 2026-10-03 · FI · FI_PRODUCER_GATE, the professional-operator question · "Do you operate professionally — registered for VAT, or voluntarily registered for VAT while under the limit?" → "Do you operate professionally — that is, do you place packaging or packaged goods on the market, or sell them to Finnish users, in the course of a business ("ammattimaisesti")? Being registered for VAT, or voluntarily registered for VAT while under the limit, is the usual sign." The question no longer defines professional operation as VAT registration. Jätelaki § 48(1) covers producers "ammattimaisesti markkinoille saattavia tai etäkaupalla suoraan käyttäjille myyviä", and § 6(1)(15) defines the producer as one who "ammattimaisesti tuotteita markkinoille saattavaa". The storage key 'professional' is unchanged. Source: jätelaki 646/2011, § 6 and § 48
• 2026-10-03 · FI · FI_AUTHORITIES food-control row, role · "recycled-content surveillance for food-contact packaging" → "contact-sensitive plastic packaging (food contact, but also medicinal products, medical devices and the other uses Art 3(1)(49) lists) and single-use plastic beverage bottles". § 24 a(4) reads "Elintarvikelain (297/2021) 24 ja 27 §:ssä tarkoitettu viranomainen valvoo markkinavalvontaviranomaisena pakkausasetuksen 7 artiklan 1 kohdan a–c alakohdan ja 2 kohdan a–c alakohdan vaatimusten noudattamista". Source: jätelaki 646/2011, § 24 a
• 2026-10-03 · SE · gate limb q4 · "established outside the EEA" → "established outside the EU — Norway, Iceland and Liechtenstein included", so a seller in an EEA-EFTA state that supplies Swedish end users directly is no longer left outside both q3 and q4. The key q4 is unchanged. Art 3(1)(15)(c) covers an operator "established in a Member State or in a third country" that "makes available for the first time on the territory of another Member State, directly to end users". Source: Regulation (EU) 2025/40, Art 3(1)(15)
• 2026-10-03 · SE · gate.foreignSellers · "A producer established in another EEA country … Sweden has NOT exercised the Art 45(3) second-sentence option to require a representative of producers established OUTSIDE the EEA" → the duty rests on Art 45(3) first sentence, "which covers producers established in a Member State or in a third country alike"; "The Art 45(3) second sentence is a separate option for Member States regarding producers established in third countries"; that Sweden has not exercised it (Naturvårdsverket's proposal, no ordinance) is unchanged. Same Art 45(3) wording as the FR entry. Source: Regulation (EU) 2025/40, Art 45(3)
• 2026-10-03 · SE · keyDates, PPWR Art 44 register · 2027-08-12 "Naturvårdsverket's reading of the deadline" → 2028-04-01, a placeholder: the deadline runs 18 months from the entry into force of the Art 44(14) act, which was not adopted on 2026-10-03, so it cannot fall before April 2028. The entry says that Naturvårdsverket's 12 August 2027 assumed the act on its due date. Art 44(1) reads "within 18 months of the date of entry into force of first implementing act adopted pursuant to paragraph 14". Sources: Regulation (EU) 2025/40, Art 44(1), Have Your Say 15352
• 2026-10-03 · SE · keyDates 2028-08-12 · substances-of-concern labelling no longer shares the 2028 / 24-month label date. It is a digital marking under the methodology due by 1 January 2030. Art 12(7) second subparagraph reads "By 1 January 2030, the Commission shall also adopt implementing acts to establish the methodology for identifying substances of concern by means of standardised, open, digital-marking technologies". Source: Regulation (EU) 2025/40, Art 12(1), (7)
• 2026-10-03 · SE · keyDates 2029-02-12 · "Reusable packaging must be marked as reusable and identify its reuse system; XPS and certain formats banned" → the Art 67(5) bans stated by item (XPS joins EPS for food containers for immediate consumption, beverage containers and cups, plus shrink wrap, protective chips and multi-pack rings), and the reusable label "from 12 February 2029 or 30 months after the Art 12(6) implementing act enters into force, whichever is later", with the Art 12(3) open-loop exemption. Art 12(2) reads "Reusable packaging placed on the market from 12 February 2029 or 30 months from the date of entry into force of the implementing act adopted pursuant to paragraph 6, whichever is the latest, shall bear a label informing users that the packaging is reusable". Source: Regulation (EU) 2025/40, Arts 12(2), 67(5)
• 2026-10-03 · EE · gate limb q5 · "do you make transport, serving or primary-production packaging available in Estonia for the first time" → adds the conditions of limbs (a) and (c): established in Estonia and supplying from within and on Estonian territory, or established elsewhere and supplying end users in Estonia directly. The key q5 is unchanged. Art 3(1)(15)(a) reads "is established in a Member State and makes available for the first time from within the territory of that Member State and on that same territory transport packaging, service packaging, or primary production packaging". Source: Regulation (EU) 2025/40, Art 3(1)(15)
• 2026-10-03 · EE · keyDates 2028-08-12 · "mandatory on all packaging placed on the market, transport and deposit packaging excepted" → "from 12 August 2028 or 24 months after the Art 12(6)/(7) implementing acts enter into force, whichever is later — transport and deposit packaging are excepted, but e-commerce packaging is included". The importer details are moved to the date they apply, 12 August 2026 (Art 18(3)). Art 12(1) reads "With the exception of e-commerce packaging, this obligation does not apply to transport packaging or to packaging that is subject to a deposit and return system". Source: Regulation (EU) 2025/40, Art 12(1)
• 2026-10-03 · EE · keyDates 2029-02-12 · the reusability label and QR code now carry "or 30 months after the Art 12(6) implementing act enters into force, whichever is later" and the Art 12(3) open-loop exemption; Art 67(5) still applies from that date. Same Art 12(2) wording. Source: Regulation (EU) 2025/40, Art 12(2)
• 2026-10-03 · EE · openQuestions, Art 44 register · "the register is due 18 months after" → "the register must be established within 18 months of". Same Art 44(1) wording. Source: Regulation (EU) 2025/40, Art 44(1)
• 2026-10-03 · IT · keyDates 2027-02-12 · "The digital EPR-membership identifier is due under PPWR art. 12(9)" → "packaging in an EPR scheme MAY be identified as such, and only through a symbol in a QR code or other standardised, open digital marking … an option, not a duty". Art 12(9) reads "By 12 February 2027, packaging included in an extended producer responsibility scheme may be identified throughout the territory of the Member States in which that scheme or system applies". Source: Regulation (EU) 2025/40, Art 12(9)
• 2026-10-03 · IT · labelling.extra · "a digital identification … due by 12 February 2027 under PPWR art. 12(9)" → "an OPTIONAL digital identification … a permission, not a duty". Same Art 12(9) wording. Source: Regulation (EU) 2025/40, Art 12(9)
• 2026-10-03 · IT · openQuestions (deposit system) · "the derogation route turns on the 2028 separate-collection rate" → "the 2026 separate-collection rate (PPWR art. 50(5)(a)), with the request and implementation plan due by 1 January 2028". Art 50(5)(a) reads "is 80 % or more by weight of such packaging made available on the territory of that Member State for the first time in the calendar year 2026". Source: Regulation (EU) 2025/40, Art 50(5)
• 2026-10-03 · BE · keyDates 2028-08-12 · "the presence of substances of concern and the share of recycled material must be conveyed" → the material-composition label from 12 August 2028 or 24 months after the Art 12(6)/(7) acts, whichever is later; a recycled-content label stays optional and follows Art 12(4) only where used; substances-of-concern marking has no 2028 date. The source moves from Fost Plus to the Regulation. Art 12(4) applies where packaging "is marked with a label containing information on the share of recycled content". Source: Regulation (EU) 2025/40, Art 12(1), (4), (7)
• 2026-10-03 · BE · labelling.extra · the same two corrections, and the 12 February 2029 reusable-packaging information now carries "or 30 months after the Art 12(6) implementing act if that is later". Same Art 12(1), (2) and (4) wording. Source: Regulation (EU) 2025/40, Art 12
• 2026-10-03 · BE · openQuestions (shared-dataset differences, item 5) · "harmonised PPWR material labelling becomes mandatory from 12 August 2028" → adds "or 24 months after the Art 12(6)/(7) implementing acts enter into force, whichever is later". Art 12(1) reads "From 12 August 2028 or 24 months from the date of entry into force of the implementing acts adopted pursuant to paragraphs 6 or 7 of this Article, whichever is the latest". Source: Regulation (EU) 2025/40, Art 12(1)
• 2026-10-03 · NL · keyDates 2028-08-12 · "The uniform disposal-instruction logos become mandatory on packaging" → adds "from 12 August 2028 or 24 months after the Art 12(6)/(7) implementing acts enter into force, whichever is later". Same Art 12(1) wording. Source: Regulation (EU) 2025/40, Art 12(1)
• 2026-10-03 · NL · labelling.extra · the same condition added to "from 12 August 2028 the uniform disposal-instruction logos become mandatory". Same Art 12(1) wording. Source: Regulation (EU) 2025/40, Art 12(1)
• 2026-10-03 · ES · keyDates 2028-08-12 · "waste-receptacle labelling with it" → receptacle labels run on their own clock, "12 August 2028 or 30 months from the adoption of the art. 13.2 implementing acts, whichever is later", and the duty is the Member State's. Art 13(1) reads "By 12 August 2028 or 30 months from the adoption of the implementing acts referred to in paragraph 2, whichever is the latest, Member States shall ensure that harmonised labels". Source: Regulation (EU) 2025/40, Art 13(1)
• 2026-10-03 · ES · labelling.extra · the material-composition and receptacle labels no longer share "24 months after their implementing acts"; each now has its own Art 12(1) and Art 13(1) timing. Same wording. Source: Regulation (EU) 2025/40, Arts 12(1), 13(1)
• 2026-10-03 · ES · openQuestions (deposit-system differences) · "PPWR art. 50.4 excludes wine" → "the grapevine-product categories it lists (wine among them, sparkling wine not)". Same Art 50(4)(a) wording. Source: Regulation (EU) 2025/40, Art 50(4)
• 2026-10-03 · EU · PPWR_TIMELINE 2026-08-12 "Art 26-28" · "refill sellers display the rules for refill and meet Annex VI Part C (Art 28)" → "refill sellers inform end users of the rules for refill, displayed on the premises or otherwise provided (Art 28(1)), and their refill stations meet Annex VI Part C, which includes displaying the container hygiene standards, container types and the final distributor's contact details (Art 28(2))". Display is one of two ways to give the rules for refill; the unconditional display duty is the refill station's, for the Part C(a) items only. Art 28(1) reads "The rules for refill shall be regularly updated and shall be either clearly displayed on the premises or otherwise provided to end users." Annex VI Part C(a) reads "the refill station displays clear and precise information on: (i) the hygiene standards that the end user’s container must meet in order for it to be used to purchase products at the refill station; (ii) the types and features of containers that can be used to purchase products through refill; (iii) the contact details of the final distributor to ensure compliance with hygiene standards under applicable law". Date, article and status are unchanged. Source: Regulation (EU) 2025/40, Art 28 and Annex VI Part C

2026-09-04 — national producer-responsibility modules, small-business page and wording corrections (dataset v2026-08-01 unchanged)

Eleven national producer-responsibility modules now sit beside Finland's in the app and on the public pages. Each one is computed from its own national law and price list. No figure, date or rate in assets/data.js or assets/data-fi.js moved. So DATASET_VERSION stays at v2026-08-01. The module data files carry their own dataVersion stamps, quoted per bullet. Fee figures from these modules are estimates from the published price lists, never amounts owed or filings.

• 2026-09-04 · AT · national producer-responsibility module · absent → EDM (Elektronisches Datenmanagement Umwelt) and the VKS list of system participants. The law read is Abfallwirtschaftsgesetz 2002 (AWG 2002) and VerpackVO 2014. The data file is assets/data-at.js, dated 2026-08-30. Module confidence: gate high, fees high, reporting high, drs high, penalties high. Source: AWG 2002 § 22 (RIS)
• 2026-09-04 · BE · national producer-responsibility module · absent → no producer register yet. The operative act is the annual declarations to Fost Plus and Valipac, plus the information return to EPRiBEL. The law read is the Samenwerkingsakkoord van 4 november 2008 and of 9 February 2026. The data file is assets/data-be.js, dated 2026-08-30. Module confidence: gate high, fees high, reporting high, drs high, penalties high. Source: EPRiBEL FAQ (IVCIE)
• 2026-09-04 · DE · national producer-responsibility module · absent → Verpackungsregister LUCID. The law read is the Verpackungsrecht-Durchführungsgesetz (VerpackDG), in force 12 August 2026. The data file is assets/data-de.js, dated 2026-08-29. Module confidence: gate high, fees high, reporting high, drs medium, penalties high. Source: Zentrale Stelle Verpackungsregister
• 2026-09-04 · DK · national producer-responsibility module · absent → Producentregistret. The law read is the emballagebekendtgørelsen. The data file is assets/data-dk.js, dated 2026-08-29. Module confidence: gate high, fees high, reporting high, drs high, penalties high. Source: Emballagebekendtgørelsen (retsinformation.dk)
• 2026-09-04 · EE · national producer-responsibility module · absent → Pakendiregister (PAKIS). The law read is the Pakendiseadus. The data file is assets/data-ee.js, dated 2026-08-29. Module confidence: gate high, fees high, reporting high, drs high, penalties high. Source: Pakendiseadus (Riigi Teataja)
• 2026-09-04 · ES · national producer-responsibility module · absent → Registro de Productores de Producto (RPP), sección envases. The law read is Real Decreto 1055/2022. The data file is assets/data-es.js, dated 2026-08-30. Module confidence: gate high, fees medium, reporting high, drs high, penalties high. Source: Real Decreto 1055/2022 (BOE)
• 2026-09-04 · FR · national producer-responsibility module · absent → SYDEREP (ADEME). The law read is the Code de l'environnement, art. L. 541-10. The data file is assets/data-fr.js, dated 2026-08-30. Module confidence: gate high, fees high, reporting medium, drs high, penalties high. Source: ADEME — identifiant unique
• 2026-09-04 · IT · national producer-responsibility module · absent → no packaging producer register. The operative act is joining CONAI. The law read is D.Lgs. 152/2006, Parte IV. The data file is assets/data-it.js, dated 2026-08-30. Module confidence: gate high, fees high, reporting high, drs high, penalties high. Source: D.Lgs. 152/2006 (Normattiva)
• 2026-09-04 · NL · national producer-responsibility module · absent → no producer-facing register yet. The operative act is joining Verpact. The law read is the Besluit beheer verpakkingen 2014 and the Besluit UPV. The data file is assets/data-nl.js, dated 2026-08-29. Module confidence: gate medium, fees high, reporting high, drs high, penalties high. Source: Besluit UPV (wetten.overheid.nl)
• 2026-09-04 · PL · national producer-responsibility module · absent → the BDO register (Baza danych o produktach i opakowaniach oraz o gospodarce odpadami). The law read is the Ustawa z dnia 13 czerwca 2013 r. o gospodarce opakowaniami i odpadami opakowaniowymi. The data file is assets/data-pl.js, dated 2026-08-29. Module confidence: gate high, fees medium, reporting high, drs high, penalties high. Source: Ustawa o gospodarce opakowaniami (Sejm)
• 2026-09-04 · SE · national producer-responsibility module · absent → Naturvårdsverkets producentansvarsregister. The law read is Förordning (2022:1274) om producentansvar för förpackningar. The data file is assets/data-se.js, dated 2026-08-29. Module confidence: gate high, fees high, reporting medium, drs high, penalties high. Source: Förordning (2022:1274) (Riksdagen)
• 2026-09-01 · pricing · Micro plan · EUR 2.90 → EUR 4.90 per month. Source: pricing
• 2026-09-04 · site · new reference page small-business.html. It covers the micro-enterprise provisions, the Finnish gate and the costs. Source: Regulation (EU) 2025/40, jätelaki 646/2011
• 2026-09-04 · EU · Art 45(3) EPR representative, status. The page did not state it. It now says: "COM(2025) 982 (10 December 2025) would suspend Art 45(3) for EU-established producers until 1 January 2035; Council did not advance it in June 2026; EP ENVI pursuing a narrower exemption; a proposal, not law". That status line is compiled from secondary reporting, re-checked against EUR-Lex before each republish. Source: COM(2025) 982
• 2026-09-04 · FI · deadlines row 2026-08-12 (assets/data-fi.js FI_KEY_DATES). The row said: "PPWR applies; act 648/2026 in force; Tukes continues as the jätelaki §24a market-surveillance authority; producer definition widens (transport, service, primary-production packaging)". It now says: "jätelaki § 48(1) 6 kohta (648/2026) defines the packaging producer by reference to PPWR Art 3(1)(15); transport-packaging responsibility moves to the packaging manufacturer or importer". Source: jätelaki 646/2011
• 2026-09-04 · FI · distance seller into Finland, finland.html step 2 (assets/fi-workflow.js). The page said: "names someone in Finland to act for it; a producer community through the Rinki service, or Sumi". It now says: "must appoint, by written mandate, an authorised representative established in Finland for producer responsibility (Regulation (EU) 2025/40 Art 45(3); jätelaki § 66 a refers packaging to that Article); the representative is treated as the producer". Source: Regulation (EU) 2025/40, jätelaki 646/2011
• 2026-09-04 · FI · Tukes market surveillance, as described on finland.html. The page said: "Tukes is designated for PPWR market surveillance from 12 August 2026". It now says: "Tukes is the market-surveillance authority for packaging requirements under jätelaki § 24 a, a role it already held before the PPWR applied; from 12 August 2026 that covers the PPWR product requirements (Arts 5-12)". Source: jätelaki 646/2011

2026-08-29 — wording and citation corrections (dataset v2026-08-01 unchanged)

These entries correct how the published pages state the law. No figure, date or rate in assets/data.js or assets/data-fi.js moved. So DATASET_VERSION stays at v2026-08-01, and no generated document changes its stamp. Every EU entry was re-read against the Official Journal text of Regulation (EU) 2025/40 on 2026-08-29.

• 2026-08-29 · FI · producer definition, service and primary-production packaging. The page said: "from 12 August 2026 the definition of producer widens to transport, service and primary-production packaging". It now says: "the producer of service and primary-production packaging has been the manufacturer or importer of that packaging since 1 January 2024, under jätelaki 646/2011 § 48". Source: ELY Centres
• 2026-08-29 · FI · producer definition, transport packaging. The page said: "from 12 August 2026 the definition of producer widens to transport, service and primary-production packaging". It now says: "from 12 August 2026 producer responsibility for transport packaging moves from the packer to the packaging manufacturer or importer, under PPWR Art 3(1)(15)". Source: Lupa- ja valvontavirasto
• 2026-08-29 · FI · producer gate. The page said: "the threshold is evaluated by date, so the rule that answers is the one in force today". It now says: "the gate is professional operation; the EUR 1 000 000 turnover threshold was removed with effect from 1 January 2024, and the ELY Centres treat an operator established in Finland that is not liable for VAT as not acting professionally". Source: ELY Centres
• 2026-08-29 · FI · producer gate, what the VAT test proves. The page said: "an operator established in Finland that is not liable for VAT is not acting professionally, so a company that registered for VAT voluntarily is inside". It now says: "an operator established in Finland that is not liable for VAT is not acting professionally. The test does not run backwards: being liable for VAT is not on its own proof that you act professionally". The ELY release states only the negative test. Its wording is "Mikäli Suomeen sijoittunut toimija ei ole arvonlisäverovelvollinen, toimintaa ei katsota ammattimaiseksi, eikä se ole tuottajavastuussa". The converse was not theirs to state. Source: ELY Centres
• 2026-08-29 · FI · dated threshold history, as described on the page. The page said: "the EUR 1,000,000 turnover rule up to the end of 2023, professional operation on its own after it". It now says: "beverage packaging alone until May 2015, the EUR 1,000,000 turnover threshold on top of professional operation until the end of 2023, and after that the VAT registration limit as the practical test, EUR 15,000 in 2024 and EUR 20,000 from 2025". The panel now describes the periods the app actually evaluates in FI_THRESHOLD_HISTORY. ALV 1501/1993 § 3 currently reads "Myyjä ei ole verovelvollinen, jos kuluvan kalenterivuoden ja sitä edeltäneen kalenterivuoden liikevaihto on enintään 20 000 euroa, ellei häntä ole oman ilmoituksensa perusteella merkitty verovelvolliseksi". The EUR 15,000 figure for 2024 is the then-current wording of the same section. The dated table carries it; it was not re-verified here. Source: Jätelaki 646/2011, ALV 1501/1993 § 3
• 2026-08-29 · EU · Art 12(1) harmonised label, start date. The page said: "until the harmonised Art 12 labelling arrives in 2028". It now says: "from 12 August 2028 or 24 months from the entry into force of the implementing acts adopted under Art 12(6) or (7), whichever is the latest". Source: Regulation (EU) 2025/40
• 2026-08-29 · EU · Decision 97/129/EC, status. The page did not state it. It now says: "repealed with effect from 12 August 2028 (PPWR Art 70(2)), which need not fall on the same day as the Art 12 label start". Source: Regulation (EU) 2025/40
• 2026-08-29 · EU · Art 5(5)(c) total fluorine, who owes the evidence. The page said: "total fluorine trigger, EOF confirmation, then the three targeted limits". It now says: "where total fluorine exceeds 50 mg/kg, the manufacturer, importer or downstream user as defined in REACH must on request give the packaging manufacturer or importer proof of how much of that fluorine is PFAS". Source: Regulation (EU) 2025/40
• 2026-08-29 · EU · Art 15(5) pack identification. The page said: "or in an accompanying document where the pack is too small". It now says: "or that information in a document accompanying the packaged product, where the size or nature of the packaging does not so allow (Art 15(5))". Source: Regulation (EU) 2025/40
• 2026-08-29 · EU · Art 5 limit values, inclusive or exclusive. The page did not state it. It now says: "the three PFAS limits in Art 5(5) bind at a concentration equal to or above the value; the Art 5(4) heavy-metals sum shall not exceed 100 mg/kg and the 50 mg/kg total-fluorine trigger has to be exceeded". Source: Regulation (EU) 2025/40
• 2026-08-29 · EU · Art 5(4) citation · "Art 5" → "Art 5(4)". The 100 mg/kg lead, cadmium, mercury and hexavalent chromium sum is in paragraph 4. Paragraphs 7 and 8 both refer back to it as "paragraph 4 of this Article". Source: Regulation (EU) 2025/40
• 2026-08-29 · EU · Art 39(2) citation · "Art 39" → "Art 39(2)". Paragraph 2 carries the duty to draw up the EU declaration of conformity in the languages the Member State of placing requires, or to translate it into them. Source: Regulation (EU) 2025/40

v2026-08-01 — baseline

• 2026-08-01 · ALL · Initial dataset compiled from public legislation and price lists. The sources are PPWR 2025/40, SUPD 2019/904, Decision 97/129/EC, jätelaki 646/2011, VNA 1029/2021, the Rinki and Sumi 2025-2026 price lists, and the Palpa terms. This is the baseline. Later entries record deltas only.