ComplyMatrix — Product compliance, from product to proof

Abstract editorial cover: overlapping blank regulation document sheets with thin rules

Three documents moved, and one of them changed the law

Three documents we re-checked on EUR-Lex on 5 November 2026 still matter for importers, and all three were published earlier: the Commission's PPWR guidance of 10 June 2026, a proposal of 10 December 2025 to suspend the EPR authorised-representative rules, and seven corrigenda that have altered the PPWR text.

The Commission's PPWR guidance is now the reference text

On 10 June 2026 the Commission published a guidance document for Regulation (EU) 2025/40 in the C series of the Official Journal (C/2026/3084). It runs to 32 numbered sections and states that it "does not replace, add to, or amend" the Regulation: the guidance is the Commission's reading, not a new obligation.

Two of its sections change how a shipment is prepared. Section 6 addresses the recyclability requirement. Article 6(1) says all packaging placed on the market shall be recyclable, without giving that sentence a date of its own. The Commission reads it as applying from 12 August 2026, the date the Regulation applies. The design-for-recycling criteria in Article 6(2)(a) apply later: from 1 January 2030, or 24 months after the delegated act under Article 6(4), whichever is later. The recycled-at-scale condition in Article 6(2)(b) starts on 1 January 2035, or five years after the implementing acts under Article 6(5), whichever is later.

Section 4 addresses who the importer is. The definition requires a person established in the Union that places packaging from a third country on the market. A branch, the Commission says, has no separate legal personality and therefore cannot be the importer; a non-EU manufacturer with only a branch must incorporate a subsidiary or appoint an authorised representative where the Member State requires one.

Who is affected: any seller placing packaged goods on the EU market, especially one that has named an EU branch as the responsible entity.

A proposal to pause the EPR authorised representative rule until 2035

On 10 December 2025 the Commission proposed a directive suspending the appointment rules for authorised representatives under extended producer responsibility (COM(2025) 983, procedure 2025/0396(COD)). Article 1 of the proposal suspends three provisions until 1 January 2035: Article 22a(3) of the Waste Framework Directive 2008/98/EC, Article 17(2) of the WEEE Directive 2012/19/EU, and Article 8(7) of the Single-Use Plastics Directive 2019/904.

The WEEE provision is the one most sellers have met, though not quite as it is usually described. Article 17(2) does not reach a third-country producer directly: it requires a producer established in one Member State, selling EEE by distance into another Member State where it is not established, to appoint an authorised representative in that Member State. For a seller with an EU company in one Member State and customers elsewhere, that is the appointment obligation; a third-country distance seller registers through that representative (Article 16(1)). The Waste Framework Directive provision behind it, Article 22a(3), is the one aimed at producers established in a third country that make textiles, textile-related products or footwear listed in Annex IVc available for the first time in a Member State. Under the proposal neither requirement would apply until 1 January 2035. Member States would keep the option to require an authorised representative for those textile producers, or to secure traceability by other means.

The proposal is not law. As of 5 November 2026 the procedure is still listed on EUR-Lex as ongoing (2025/0396/COD), and the text still carries a placeholder transposition deadline.

Who is affected: producers of EEE selling cross-border from an establishment in one Member State, and third-country producers of textiles, textile-related products and footwear. Also anyone who has already appointed an authorised representative for either obligation.

Seven corrigenda have changed the text you quote

Since May 2025 the PPWR has been corrected seven times — EUR-Lex records corrigenda dated 22 May 2025, 9 September 2025, 25 November 2025, 28 November 2025, 21 July 2026, 4 August 2026 and 18 September 2026. We read the German and Italian ones in full and checked the metadata of the other five; we did not read their text. A corrigendum is a separate act that does not update the original text, so an older copy can be out of date.

Two of them, the two we read in full, changed operative wording rather than punctuation. The German corrigendum of 4 August 2026 (OJ L 2026/90654) replaces "Rohstoffe" with "Waren" in Article 29(4)(b), the exemption for packaging used to transport large machinery and equipment and designed to the individual requirements of the ordering economic operator. The Italian corrigendum of 18 September 2026 (OJ L 2026/90776) rewrites Article 3(1)(15)(c) and (d), the definition of producer: "consumatori" becomes "utilizzatori finali" (end users), and a broken sentence in point (d) is repaired.

The Italian change is the one to watch, but only as a wording fact: the English text of those points already reads "end users". Whether the Italian wording before the correction was narrower — and therefore whether professional end users were previously outside the definition in that version — is an inference from comparing language versions, not a statement the corrigendum makes. If you rely on the Italian text in a contract or a marketplace declaration, date the version you quoted and have the comparison checked by counsel.

Who is affected: anyone who quotes the PPWR in one of those languages in a contract or a marketplace declaration.

What to do this month

Ask suppliers for total-fluorine data on food-contact packaging. The PFAS limits in Article 5(5) apply from 12 August 2026, and the guidance treats total-fluorine screening as the first analytical step.
Check the entity named as importer on your EU paperwork against guidance section 4. A branch is not enough.
Do not cancel an authorised-representative arrangement on the strength of the proposal. Nothing is suspended until the directive is adopted and transposed.
Keep a dated copy of the PPWR text in each language you rely on, and re-check it after any corrigendum.
Separate the two recyclability questions: whether packaging is recyclable at all (now), and whether it meets the harmonised design criteria (from 2030).

What we do not know yet

Whether the suspension will be adopted, and in what form. There is no adopted act and no agreed transposition date; the Parliament and Council positions were not in the sources we read.

Whether the Commission will adopt the Article 6(4) delegated act by 1 January 2028; the guidance says it "should", and the 2030 date depends on it.

How Member States will enforce the PFAS limits. There is no harmonised EU test method for PFAS in food-contact packaging; the guidance recommends a stepwise approach but calls it a recommendation, not a rule.

Whether other language versions will be corrected in the same direction as the Italian text. We read the German and Italian corrigenda in full and the metadata of the other five, not their text.

PPWR guidance, a paused EPR rule and seven corrigenda