# EPR producer definition: the US states and UK follow the brand, the EU the first sale, India all three

> The EPR producer definition decides which company registers, reports and pays for a pack, and the six definitions SPI compared answer it differently: the EU's PPWR, applied since 12 August 2026, makes the producer whoever first makes the pack available in each Member State; the UK's 2024 regulations name seven producer classes led by the brand owner; Oregon, Colorado and California run a cascade from brand owner to licensee to importer or distributor; and India's rules obligate producers, importers and brand owners side by side.

Publisher: Strategic Packaging Insights  
Published: 2026-11-02  
Last updated: 2026-11-02  
Page: https://www.strategicpackaginginsights.com/insights/epr-producer-definition-eu-uk-us-india/

**The EPR producer definition decides which company registers, reports and pays for a pack, and the six definitions SPI compared answer it differently: the EU's PPWR, applied since 12 August 2026, makes the producer whoever first makes the pack available in each Member State; the UK's 2024 regulations name seven producer classes led by the brand owner; Oregon, Colorado and California run a cascade from brand owner to licensee to importer or distributor; and India's rules obligate producers, importers and brand owners side by side.**

Strategic Packaging Insights (SPI) set the definitions out text by text, from the statute or official instrument, or from an unofficial compilation where the methodology says so, and lined them up against the six roles that decide most cases: brand owner, licensee, importer, first distributor, online marketplace and foreign direct seller. This piece describes what each text says; it does not say whether any reader is a producer, which depends on facts and on counsel.

## Executive summary

Every packaging extended producer responsibility (EPR) law starts with the same question: which company in the chain is the producer? The answer decides who registers, who reports tonnage, who pays fees and who answers to the regulator. SPI read six producer definitions covering the EU, the UK, three US states and India, plus Germany's VerpackDG, which since 12 August 2026 applies the EU's, and found that they use three different logics.

The first logic follows the brand. The UK's Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 make the brand owner the producer of filled packaging that carries its brand (regulation 16), and Oregon, Colorado and California each start their cascade with the manufacturer that sells under its own brand, then move to a licensee and only then to an importer or distributor (ORS 459A.866; C.R.S. 25-17-703(30); PRC 42041(w)).

The second logic follows the first sale. Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation (PPWR), makes the producer the manufacturer, importer or distributor that first makes packaging available in a Member State, or sells directly to end users in another (Article 3(1)(15)). The brand decides who is the manufacturer, a separate role, but not who pays EPR in each country. Germany has followed: the VerpackDG, in force since 12 August 2026, has no producer definition of its own, and the old Verpackungsgesetz definition in section 3(14) has been repealed.

The third logic obligates several groups at once. India's Guidelines on EPR for Plastic Packaging, Schedule II of the Plastic Waste Management Rules, give separate targets to producers of plastic packaging, to importers and to brand owners, and name online platforms, marketplaces, supermarkets and retail chains as brand owners.

The differences matter most at the edges: private label, imports, online marketplaces and small firms. Only the UK and India write the marketplace into the producer list; California's text says the marketplace operator is not the retailer when it meets set criteria. Small producer lines run from USD 1 million of gross annual sales in California to USD 5 million of revenue in Oregon and Colorado, and from more than GBP 1 million and 25 tonnes in the UK.

For leaders, the practical step is a role map: for each SKU and each market, which legal entity each text points to, and why. That map is a business record, not a legal opinion, and it should be checked with counsel where the answer turns on facts.

## Key findings

1. Article 3(1)(15) of Regulation (EU) 2025/40 lists five routes to producer status, points (a) to (e), and the Commission's guidance of 10 June 2026 ties the producer to the Member State where the packaging becomes waste (Notice C/2026/3084, section 3).
2. Germany's section 3(14) VerpackG, which made the Hersteller the distributor that first placed packaging on the market commercially, was repealed at the end of 11 August 2026; section 3(1) VerpackDG now says its definitions supplement Article 3 of the PPWR (buzer.de, unofficial text).
3. The UK regulations name seven producer classes in regulations 16 to 22, and every producer must be established in the UK (regulation 15); an online marketplace operator is the producer for packaging on goods sold by non-UK suppliers and received in the UK (regulation 20).
4. Oregon and Colorado use the same three-step cascade for packaging, brand-owning manufacturer, then brand licensee, then US importer, and both make the person that packs and ships a remote or internet sale the producer of the shipping packaging (ORS 459A.866(1)(b); C.R.S. 25-17-703(30)(b)).
5. California's PRC 42041(w) runs from the brand-owning or licensee manufacturer to the brand owner or its exclusive licensee, then to whoever sells or distributes into the state; producers with gross annual sales under USD 1 million may apply for a temporary, renewable exemption (CalRecycle).
6. India's Schedule II clause 4 obligates three groups in parallel, and the brand owner group excludes enterprises that meet the MSME Ministry's criteria; CPCB's reply of April 2025 lists only micro and small enterprises as excluded ([PR-IN-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-001/)).
7. **SPI analysis:**  across the six definitions in Exhibit 2, the brand owner is named or reached in all six, the importer is named in five, the online marketplace is made a producer in two, the UK and India, and the foreign direct seller is made a producer expressly only in the EU.

## EPR producer definition: the six definitions side by side

Exhibit 2 is the core of this piece: the six definitions, with Germany's reading, set against the six roles that decide most producer questions. Each cell states what the text says, with its provision. Where a text is silent, the cell says so, because silence is itself an answer; it usually means the role falls to the next rung of the chain.

Read down the columns and the three logics in the executive summary appear. The EU and German columns use the same verbs, make available and first, for every role: the brand matters for the manufacturer role, but the producer is found by asking who made the first supply on that national territory. The UK and US columns run as ladders: each rung applies only if the one above it is empty, or, in the UK, if the company above it is not a large producer. The Indian column has no ladder at all; three groups each carry their own target under clauses 7.2, 7.3 and 7.4 ([PR-IN-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-001/)).

SPI analysis

The ladder and the first-sale logic give the same answer for the most common case, a brand owner that fills and sells its own product in its home market. They part company on imports and on cross-border online sales. Under a US ladder, a foreign brand owner with no US presence drops out and the US importer takes its place; under the PPWR, a foreign seller shipping directly to an EU consumer is the producer in that consumer's country, whatever its brand.

## The EU: Article 3(1)(15) and the first supply in each Member State

The PPWR has applied since 12 August 2026, having entered into force on 11 February 2025 ([PR-EU-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-001/)). Its definitions sit in Article 3(1), and the Commission's Notice C/2026/3084 of 10 June 2026 quotes them in full in its sections 2 to 4. SPI read the definitions there, because the HTML text of the Regulation on EUR-Lex serves the recitals reliably but not always the articles ([PR-EU-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-001/)).

The lead-in to Article 3(1)(15) applies the definition irrespective of the selling technique, including distance contracts. The Commission reads making a product available directly to an end user online as making it available in the end user's Member State, so a company with a web shop selling packaged goods to a consumer in another Member State is the producer there (Notice C/2026/3084, section 3). That is the rule behind the authorised representative duty in Article 45(3), which [SPI's Omnibus VIII piece](https://www.strategicpackaginginsights.com/insights/omnibus-ppwr-authorised-representative-non-eu-exporters/) follows through the Council and Parliament positions of October 2026.

Two neighbouring definitions shape the answer. The manufacturer under Article 3(1)(13)(a) is the person that has packaging or a packaged product designed or manufactured under its own name or trademark; under point (b), where the brand owner is a micro-enterprise with fewer than 10 employees and turnover or balance sheet total of no more than EUR 2 million, and its supplier is in the same Member State, the supplier becomes the manufacturer (Notice C/2026/3084, section 2). The importer under Article 3(1)(17) must be established in the Union; the Commission says a branch without legal personality cannot be one (section 4). [SPI's Directive to PPWR piece](https://www.strategicpackaginginsights.com/insights/packaging-directive-to-ppwr-what-changed-brand-owners-converters/) sets out how the manufacturer and producer roles split the conformity file and the EPR file; this piece stays with the producer.

The Commission also explains where the producer role lands geographically. It reads the definition as pointing to the Member State where the packaging becomes waste, and adds that fees already paid in one Member State are to be reimbursed if a distributor later first supplies the packaging in another ([PR-EU-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-001/), from Notice C/2026/3084).

SPI analysis

The EU definition has no small producer line. Thresholds for EPR fees and reporting stay with national schemes, which [SPI's small producers piece](https://www.strategicpackaginginsights.com/insights/small-producers-euro-epr-thresholds-flat-fees/) compares for six euro markets. The only size test in the definitions is the micro-enterprise rule, and it moves the manufacturer role, not the producer role.

## Germany: from section 3(14) VerpackG to the PPWR

From 2019 to 2026 German packaging buyers worked with one sentence: under section 3(14) of the Verpackungsgesetz, the Hersteller was the distributor that first placed packaging on the market commercially, and anyone who commercially brought packaging into Germany also counted as Hersteller (buzer.de, unofficial consolidated text). That sentence no longer applies. Article 7 of the law of 13 July 2026, BGBl. 2026 I Nr. 207, repealed the VerpackG with effect from the end of 11 August 2026, and Article 1 of the same law enacted the VerpackDG (buzer.de).

The register authority, the Zentrale Stelle Verpackungsregister, explains how it applies the PPWR. A company whose name or brand is on the pack is treated as manufacturer and also as producer; for unbranded packaging the producer is found in the Member State where the packaging becomes waste, and the Zentrale Stelle says who is first in the domestic supply chain decides it. A foreign company is the producer only where it ships from abroad directly to an end user, private or commercial, and then needs an authorised representative if it has no German branch (Zentrale Stelle). [SPI's German packaging law piece](https://www.strategicpackaginginsights.com/insights/germany-packaging-law-2026-verpackg-plastic-tax/) covers the registration, system and deadline duties that follow.

A language point catches many readers. In the German text of the PPWR the manufacturer is the Erzeuger and the producer is the Hersteller, so the word that meant producer under the VerpackG still means producer, but its content now comes from Brussels ([Ledger 69](https://www.strategicpackaginginsights.com/insights/packaging-directive-to-ppwr-what-changed-brand-owners-converters/)).

SPI analysis

The practical shift is for companies that relied on a supplier's or a distributor's registration. Under the old first placing test, a German wholesaler that bought unbranded goods abroad was the obvious Hersteller. Under the brand principle, a foreign brand owner whose German customer imports the goods may still be the manufacturer for design and labelling purposes, while that customer is the producer for EPR. The two files now sit with different companies.

## The UK: seven producer classes and the large producer pass-through

The Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024, SI 2024/1332, were made on 11 December 2024 and cover all four UK nations ([PR-GB-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-002/)). Part 2, Chapter 1 sets out who is a producer. Regulation 15 sets three conditions: the person must be established in the UK, fall into one or more of the classes, and carry out the class's functions in the UK in the course of business, directly or through an agent. Where products are sold together as one sales unit, producer status is assessed for each product's packaging and for the sales unit as a whole.

The design choice that sets the UK apart is the pass-through to a large producer. A brand owner that is not a large producer does not carry the obligation for its filled packaging when a packer/filler, an importer or a first UK owner is a producer for it; regulation 16(4) lists those exceptions, and regulations 17, 18 and 19 move the obligation to the larger party. Regulation 15 also tells a company how to judge whether its counterparty is large: use evidence for the year of supply if it has it, and otherwise treat the counterparty as large if it was registered as a large producer in the preceding year under these regulations or listed as one under the earlier packaging data reporting regulations for England, Wales, Scotland or Northern Ireland.

Regulation 20 is the clearest marketplace rule in the six definitions. The operator must control access to and the contents of the marketplace and be involved in all three of setting sale terms, processing payment and ordering or delivery. It is then the producer for packaging on items supplied by a non-UK supplier and received in the UK, and for unfilled packaging such suppliers sell to businesses that are not large producers of the filled pack.

SPI analysis

Because regulation 15 requires UK establishment, the UK has no equivalent of the PPWR's foreign direct seller. A non-UK brand selling to UK consumers is not a producer; depending on the route, the obligation sits with the UK importer, the first UK owner or the marketplace operator. [SPI's UK EPR year 2 piece](https://www.strategicpackaginginsights.com/insights/uk-epr-year-2-ram-ratings-packaging-bill/) covers what the large producers then pay.

In practice: ALDI UK.

The SPI Packaging Buyers Database records 110,305.88 tonnes of own-label primary plastic packaging placed by ALDI UK in 2023 and 1,092 UK stores in October 2026. Under regulation 16, the brand that appears on own-label filled packaging is the retailer's, so the regulation's brand owner class is the one the text points to for most of what the business sells. The profile notes that ALDI UK's Irish stores fall under the PPWR from 12 August 2026, where the first supply test in Exhibit 3 applies instead.

## Oregon, Colorado and California: three cascades, one PRO

The three US states with packaging EPR programmes running through Circular Action Alliance use cascades, but not identical ones (Exhibit 6). [SPI's US state EPR piece](https://www.strategicpackaginginsights.com/insights/us-state-packaging-epr/) compares the fees, deadlines and programme plans across seven states; this section stays with the definitions.

Oregon's law, in ORS chapter 459A, took effect on 1 January 2022, and producers had to be members of a PRO from 1 July 2025 ([PR-US-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-002/)). Food serviceware gets its own rule, which the statute states in a single sentence.

> "The producer of food serviceware is the person that first sells the food serviceware in or into this state."

***Oregon Revised Statutes** , [ORS 459A.866(3)](https://oregon.public.law/statutes/ors_459A.866), Recycling Modernization Act*

DEQ adds a supply chain rule in its producer summary: if another party has registered as producer for all of a company's covered products sold into Oregon, that company need not join the PRO itself ([PR-US-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-002/)).

Colorado's HB22-1355 writes almost the same ladder into C.R.S. 25-17-703(30), with publishers as producers of newspapers and magazines and the first distributor as producer of any other covered material. Neither Oregon nor Colorado names a franchisor or a retailer as such; a retailer appears only as a brand licensee, a shipper or a first distributor.

California's SB 54, Chapter 75 of the Statutes of 2022, takes a different third step. Where no manufacturer owns or licenses the brand, the brand owner is the producer, or, if it is outside the state, its exclusive licensee in California; where neither exists, the producer is whoever sells, offers for sale or distributes the product into the state (PRC 42041(w)). The Assembly Natural Resources Committee's analysis of the bill as amended on 26 June 2022 describes the same three tiers. Subdivision (ae) treats a third-party seller on an online marketplace as the retailer for its own transactions, not the marketplace operator, where the platform meets the criteria in (ae)(3).

SPI analysis

The US ladders favour the brand that manufactures. A brand owner that outsources manufacturing reaches step 1 in California through ownership of the brand, but in Oregon and Colorado the text at step 2 names the licensee. SPI has not yet confirmed how DEQ and the Colorado programme treat a private-label retailer that owns a brand but neither manufactures nor licenses it; that is a question for the agency, the PRO or counsel.

In practice: Circular Action Alliance.

The same organisation is the approved PRO in Oregon, under a 2025 to 2027 plan DEQ approved on 21 February 2025, and the first approved PRO in California, where it submitted its plan to the Advisory Board on 15 June 2026 ([PR-US-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-002/), [PR-US-004](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-004/)). One organisation therefore serves members under statutory definitions that do not always pick the same company for the same pack, so the producer role has to be settled state by state before membership.

In practice: Amazon.

The SPI Packaging Buyers Database profile records US net sales of USD 489,657 million in 2025 and records Amazon as shipper of record for its mailers, paper bags and void fill. ORS 459A.866(1)(b) and C.R.S. 25-17-703(30)(b) make the person that packages and ships a remote or internet sale the producer of the shipping packaging, while the product's own packaging follows the brand ladder. The UK and Indian rows of the same profile point to regulation 20 and to India's inclusion of online platforms among brand owners.

## India: three obligated groups and the MSME exclusion

India's packaging EPR is Schedule II of the Plastic Waste Management Rules, 2016, inserted by G.S.R. 133(E) of 16 February 2022 and revised by G.S.R. 237(E) of 31 March 2026 ([PR-IN-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-001/)). The 2026 amendment changed targets, audits and several definitions, and added a definition of a seller of plastic raw material, but SPI found no change to the definitions of brand owner, producer or importer, or to clause 4 (MPCB copy of G.S.R. 237(E)).

The structure avoids double counting by deduction rather than by a ladder. A brand owner keeps records of packaging bought from registered producers and importers, and those quantities come off the seller's obligation (clause 10.3, [PR-IN-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-001/)). Registration is per packaging category and per state: an entity in more than two states registers with the Central Pollution Control Board (CPCB), and one in one or two states with the State Pollution Control Board, giving PAN, GST and company identification numbers (clauses 6.1, 6.5 and 6.6).

The small firm rule needs care. The 2022 text of clause 4(iii) excludes micro, small and medium enterprises from the brand owner group, while CPCB's reply to the National Green Tribunal of 28 April 2025 lists only micro and small enterprises as excluded ([PR-IN-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-001/)). SPI records the difference and does not resolve it; [SPI's India 2026 rules piece](https://www.strategicpackaginginsights.com/insights/india-plastic-packaging-rules-2026/) covers the targets that follow from registration.

SPI analysis

India is the only text of the six in which an online marketplace and a retail chain are named inside the brand owner group, so a platform can carry brand owner targets in its own right. In the UK the marketplace is a producer only for non-UK sellers' goods; in India the text draws no such line.

## Small producer thresholds, in each law's own terms

Exhibit 8 lists the size tests in each text in their own currency and unit. SPI does not rank them against one another across currencies.

Two details change the arithmetic. First, the UK test is cumulative and lagged: regulation 24 looks at turnover in the last financial year ending before 7 April of the previous year, with accounts available, and at tonnage supplied two years earlier, and a company counts all its producer classes without counting any item twice. Second, the US tests measure different things: California uses gross annual sales, Oregon gross revenue for the most recent fiscal year, and Colorado realised gross total revenue in the prior calendar year, excluding on-premises alcohol sales.

CalRecycle's instruction for small firms shows that the exemption is not automatic.

> "To apply, first register in CalRecycle’s reporting system, known as PEPRS, as a Packaging EPR producer."

***CalRecycle** , [Extensions, Exemptions, and Exclusions](https://calrecycle.ca.gov/packaging/packaging-epr/exemptionsexclusions/), SB 54 guidance page*

## Scenarios: the same firm at three sizes

The two tables below apply the tests in Exhibit 8 to illustrative firms, one currency at a time. They show how the texts sort a company; they are not a finding about any real company.

SPI analysis

The US base case is the one that catches growing brands. A firm with USD 3 million of sales is a small producer in Oregon and exempt in Colorado, yet outside California's USD 1 million exemption, so a single national packaging range can be in scope in one state and out of scope in two. In the UK the tonnage test does the same work: a high-margin brand with modest packaging can stay small at a turnover well above GBP 2 million.

## A framework: six seller archetypes and where each text points

The definitions are easier to use when read from the seller's side. SPI groups sellers into six archetypes by route to market and reads each text for the role it points to (Exhibit 11). The archetypes are SPI's; the cells summarise the text, and the answer for a real company turns on its contracts, its establishment and its size.

Archetype 1 is the easy case, and it is most of the market by volume. Archetypes 4 and 5 are where the texts diverge most, because each regime decided separately how far to reach beyond its borders. The EU reaches the foreign seller itself; the UK refuses to, and reaches the marketplace instead; the US states reach the importer and the shipper; India reaches the platform.

SPI analysis

A company that sells through all six routes should expect to hold different roles for the same SKU in different markets. The risk is carrying one market's answer into another: treating the UK marketplace rule as if it applied in the EU, or the EU's foreign seller rule as if it applied in the US.

## Industry reaction

The voices on producer definitions are mostly regulators, and their guidance is practical in tone. The European Commission's notice of 10 June 2026 explains where the producer's obligations are determined in one line.

> "In practice, this will usually be where the packaging is filled."

***European Commission** , [Notice C/2026/3084](https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52026XC03084), guidance on Regulation (EU) 2025/40, section 3, 10 June 2026*

Germany's register authority applies the same idea to unbranded packaging sold in Germany.

> "The key factor is who is the first company in the domestic supply chain."

***Zentrale Stelle Verpackungsregister** , [What will change from 12 August](https://www.verpackungsregister.org/en/i-want-to-know-what-will-change-from-12-august), guidance page*

The Commission adds a caution that applies to all guidance in this piece: its notice does not amend the Regulation, and only the Court of Justice of the European Union can give binding interpretations ([PR-EU-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-001/)). The Bundesrat's resolution of 10 July 2026 asked for a follow-up amendment to the VerpackDG soon after entry into force, though on recycling routes rather than on who counts as the producer ([PR-DE-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/germany/pr-de-001/)). SPI found no published trade body position comparing producer definitions across these jurisdictions.

## What leaders should do now

1. **Compliance leads, by 31 December 2026:**  build a role map of SKU, legal entity and market that names, for each of the six definitions, the provision that points to the producer (Exhibit 2), and attach the evidence, such as the brand on the pack, the importer of record or the marketplace contract.
2. **German operations, by 12 November 2026:**  check that LUCID entries reflect the PPWR brand principle rather than the repealed section 3(14) VerpackG test, using [SPI's German packaging law piece](https://www.strategicpackaginginsights.com/insights/germany-packaging-law-2026-verpackg-plastic-tax/) for the deadlines.
3. **UK finance and procurement, before the 1 April 2027 data deadline:**  record the large or small status of every UK supplier and customer, since regulations 16 to 19 move the obligation according to it, and keep the evidence regulation 15 allows.
4. **US commercial teams, in Q1 2027:**  test each brand against the three US small producer lines on the right measure, sales, fiscal year revenue or calendar year revenue (Exhibits 8 and 9), and ask the PRO in writing where a private-label or licensing structure leaves the producer unclear.
5. **E-commerce leads, in Q1 2027:**  list every marketplace and direct shipping route by market and record which party each text points to for the product pack and for the shipping pack (Exhibit 11).
6. **India regulatory teams, before the 30 June 2027 annual return:**  confirm whether each brand owner entity falls inside the MSME exclusion on the current MSME criteria, and keep purchase records from registered producers and importers for the clause 10.3 deduction.
7. **General counsel, at each market entry:**  have the role map checked with counsel before registering, since the texts differ on establishment, brand and size.

## Questions for your board

- For each of our top 20 SKUs, do we know which of our entities is the producer in each market, and under which provision?
- Where do we rely on a supplier, importer or marketplace to carry the obligation, and what evidence do we hold?
- Which of our brands sit between USD 1 million and USD 5 million of US sales, inside California's scope but possibly outside Oregon's and Colorado's?
- Has our German registration moved from the old VerpackG test to the PPWR brand principle?
- How many of our UK counterparties are large producers, and who checks that each year?
- Do our Indian entities fall inside or outside the brand owner group, on both readings of the MSME exclusion?

## What to watch

- **12 November 2026:**  deadline for existing German register entries to be updated under section 68 VerpackDG ([Ledger 27](https://www.strategicpackaginginsights.com/insights/germany-packaging-law-2026-verpackg-plastic-tax/)).
- **31 December 2026:**  old German system participations end.
- **1 April 2027:**  UK data for July to December 2026 from large producers and for all of 2026 from small producers ([PR-GB-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-002/)).
- **30 June 2027:**  Indian annual returns for 2026 to 2027 under clause 10.6 ([PR-IN-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-001/)).
- **1 July 2027:**  Colorado's annual inflation adjustment of the USD 5 million exemption under C.R.S. 25-17-713(2).
- **31 December 2027:**  end of the German transition for packaging outside system participation operating without section 19 approval ([PR-DE-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/germany/pr-de-001/)).
- **No date set:**  the Omnibus VIII outcome on the PPWR authorised representative duty, which leaves the producer definition itself untouched ([PR-EU-012](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-012/)).

## Methodology

- **Data used:**  SPI rules [PR-EU-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-001/), [PR-DE-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/germany/pr-de-001/), [PR-GB-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-002/), [PR-US-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-002/), [PR-US-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-003/), [PR-US-004](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-004/) and [PR-IN-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-001/) in the [SPI Regulation Tracker](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-001/), with the ALDI UK and Amazon profiles in the [SPI Packaging Buyers Database](https://www.strategicpackaginginsights.com/data/packaging-buyers-database/). Primary texts consulted on 2 November 2026: Commission Notice C/2026/3084, which quotes PPWR Article 3; SI 2024/1332 regulations 15 to 24 on legislation.gov.uk; Colorado's HB22-1355 signed act; CalRecycle's exemptions page; G.S.R. 237(E); the Schedule II gazette text annexed to a CPCB affidavit; and the 2016 PWM Rules.
- **Unofficial texts:**  the VerpackG and VerpackDG wording is from buzer.de, ORS 459A.866 and 459A.863 from oregon.public.law, and PRC 42041 from california.public.law, all unofficial compilations. SPI has not yet confirmed these against the Federal Law Gazette, the Oregon Legislature's official ORS or California's official code site, and marks them as unofficial in the sources.
- **Translations:**  Schedule II clauses 3 and 4 were read in the Hindi gazette text; English wording is SPI's.
- **Counting rules:**  Exhibit 1 counts lettered or numbered provisions that name a person as producer of packaging, excluding cross-references and paper-only or food serviceware-only routes. Exhibit 11's archetypes are SPI's grouping.
- **Calculations:**  Exhibits 9 and 10 are SPI calculations in one currency each, from the statutory thresholds, for illustrative firms.
- **Limitations:**  SPI has not yet confirmed the current inflation-adjusted Colorado line, how DEQ and Colorado treat a private-label retailer that neither manufactures nor licenses its brand, whether Indian rule 3 definitions changed between 2016 and 2026, the text of PPWR Article 45(4) against the Official Journal, or later amendments to SI 2024/1332. Nothing here is legal advice.

**Related:**  [LUCID registration deadline 12 November 2026](https://www.strategicpackaginginsights.com/news/germany-lucid-registration-deadline-november-12/)

## Sources

1. European Commission: Commission Notice C/2026/3084, guidance document for Regulation (EU) 2025/40, 10 June 2026, [https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52026XC03084](https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52026XC03084), consulted 2026-11-02.
2. EUR-Lex: Regulation (EU) 2025/40 on packaging and packaging waste, OJ L 22.1.2025, [https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202500040](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202500040), consulted 2026-10-14.
3. legislation.gov.uk: SI 2024/1332, contents (as made), [https://www.legislation.gov.uk/uksi/2024/1332/contents/made](https://www.legislation.gov.uk/uksi/2024/1332/contents/made), consulted 2026-11-02.
4. legislation.gov.uk: SI 2024/1332, regulations 15 to 22 (as made), [https://www.legislation.gov.uk/uksi/2024/1332/regulation/15/made](https://www.legislation.gov.uk/uksi/2024/1332/regulation/15/made), consulted 2026-11-02.
5. legislation.gov.uk: SI 2024/1332, regulations 23 and 24 (as made), [https://www.legislation.gov.uk/uksi/2024/1332/regulation/24/made](https://www.legislation.gov.uk/uksi/2024/1332/regulation/24/made), consulted 2026-11-02.
6. buzer.de: VerpackDG section 3, unofficial consolidated text, [https://www.buzer.de/3_VerpackDG.htm](https://www.buzer.de/3_VerpackDG.htm), consulted 2026-11-02.
7. buzer.de: VerpackG section 3, unofficial consolidated text, [https://www.buzer.de/3_VerpackG.htm](https://www.buzer.de/3_VerpackG.htm), consulted 2026-11-02.
8. Zentrale Stelle Verpackungsregister: I want to know what will change from 12 August, [https://www.verpackungsregister.org/en/i-want-to-know-what-will-change-from-12-august](https://www.verpackungsregister.org/en/i-want-to-know-what-will-change-from-12-august), consulted 2026-11-02.
9. Deutscher Bundestag: Drucksache 21/5346, government bill for the VerpackDG, [https://dserver.bundestag.de/btd/21/053/2105346.pdf](https://dserver.bundestag.de/btd/21/053/2105346.pdf), consulted 2026-10-14.
10. ORS 459A.866, unofficial compilation, [https://oregon.public.law/statutes/ors_459A.866](https://oregon.public.law/statutes/ors_459A.866), consulted 2026-11-02.
11. ORS 459A.863, unofficial compilation, [https://oregon.public.law/statutes/ors_459A.863](https://oregon.public.law/statutes/ors_459A.863), consulted 2026-11-02.
12. Oregon DEQ: Producer Obligations Summary, Recycling Modernization Act, [https://www.oregon.gov/deq/recycling/Documents/RMAProducerObligationsSummary.pdf](https://www.oregon.gov/deq/recycling/Documents/RMAProducerObligationsSummary.pdf), consulted 2026-10-14.
13. Colorado General Assembly: HB22-1355, signed act, [https://content.leg.colorado.gov/sites/default/files/2022a_1355_signed.pdf](https://content.leg.colorado.gov/sites/default/files/2022a_1355_signed.pdf), consulted 2026-11-02.
14. California Public Resources Code section 42041, unofficial compilation, [https://california.public.law/codes/public_resources_code_section_42041](https://california.public.law/codes/public_resources_code_section_42041), consulted 2026-11-02.
15. California State Assembly Committee on Natural Resources: analysis of SB 54, as amended 26 June 2022, [https://www2.calrecycle.ca.gov/Docs/Web/129120](https://www2.calrecycle.ca.gov/Docs/Web/129120), consulted 2026-11-02.
16. CalRecycle: Extensions, Exemptions, and Exclusions, [https://calrecycle.ca.gov/packaging/packaging-epr/exemptionsexclusions/](https://calrecycle.ca.gov/packaging/packaging-epr/exemptionsexclusions/), consulted 2026-11-02.
17. CalRecycle: SB 54 Permanent Regulations approved and in effect, 1 May 2026, [https://content.govdelivery.com/accounts/CALRECYCLE/bulletins/4157d91](https://content.govdelivery.com/accounts/CALRECYCLE/bulletins/4157d91), consulted 2026-10-14.
18. Plastic Waste Management Rules, 2016, English text, NSWAI copy, [https://www.nswai.org/docs/PWM_2016_english.pdf](https://www.nswai.org/docs/PWM_2016_english.pdf), consulted 2026-11-02.
19. CPCB reply affidavit in NGT OA 22 of 2022, annexing G.S.R. 133(E), [https://www.greentribunal.gov.in/sites/default/files/news_updates/2222_0.pdf](https://www.greentribunal.gov.in/sites/default/files/news_updates/2222_0.pdf), consulted 2026-11-02.
20. MoEFCC Gazette G.S.R. 237(E), 31 March 2026, MPCB copy, [https://www.mpcb.gov.in/sites/default/files/standing_orders/Plastic_Waste_Management_2026.pdf](https://www.mpcb.gov.in/sites/default/files/standing_orders/Plastic_Waste_Management_2026.pdf), consulted 2026-11-02.
21. CPCB reply in NGT OA 1179 of 2024, 28 April 2025, [https://www.greentribunal.gov.in/sites/default/files/news_updates/REPLY%20BY%20R-2%20CPCB%20IN%20OA%20NO.%201179%20of%202024%20HARIYALI%20WELFARE%20SOCIETY%20VS%20UNION%20OF%20INDIA.pdf](https://www.greentribunal.gov.in/sites/default/files/news_updates/REPLY%20BY%20R-2%20CPCB%20IN%20OA%20NO.%201179%20of%202024%20HARIYALI%20WELFARE%20SOCIETY%20VS%20UNION%20OF%20INDIA.pdf), consulted 2026-10-14.
22. SPI Regulation Tracker and SPI Packaging Buyers Database, /data/packaging-regulation-tracker/european-union/pr-eu-001/, consulted 2026-11-02.