Changelog

What we changed, and when.

This tool cites the regulation article by article, so when we correct a citation, sharpen a date, or the law itself moves, you should be able to see exactly what changed. Every entry says what it was, what it is now, and the article behind it.

10 July 2026 — accuracy review against the regulation text

We reviewed the guides and the report against the text of Regulation (EU) 2025/40 on EUR-Lex and the Commission's implementation guidance, and made the following corrections:

Empty-space cap re-cited to Article 24. The 50% empty-space ratio for grouped, transport and e-commerce packaging is set by Article 24, not Article 10. Article 10 is the separate packaging-minimisation duty. Corrected across the guides and the report.
Minimisation is a 2030 duty, not a day-one one. The new PPWR minimisation duty (Article 10) applies from 1 January 2030; until the end of 2029 the existing EU packaging minimisation requirements carry over under Article 70(1)(b). Our "day-one" lists no longer include minimisation.
EPR split into registration and responsibility. Producer registration is Article 44; the extended-producer-responsibility fees and the authorised-representative duty are Article 45. Places that put registration under Article 45 now cite Article 44.
Reuse-target exemption re-cited to Article 29. The binding reuse targets are Article 29, and the micro-enterprise exemption sits in Article 29(13) (no more than 1,000 kg of packaging placed on a member state's market in a year, by a micro-enterprise).
PFAS and heavy-metal limits stated as fixed numbers. The PFAS limits in food-contact packaging are fixed in Article 5(5) — 25 ppb for any single PFAS, 250 ppb for the sum, 50 ppm including polymeric PFAS, with a 50 mg/kg total-fluorine screening trigger — not values still being specified. The heavy-metals sum limit is 100 mg/kg (Article 5(4)).
"Placing on the market," not existing stock. The PFAS restriction attaches to packaging placed on the market from 12 August 2026, whatever its manufacture date — reworded from language that read as retroactive.
"Whichever is later" mechanisms added. The recyclability grade-C floor, the harmonised-labelling date and the empty-space cap each depend on when the underlying implementing or delegated acts enter into force. Those conditions are now stated with each date.
Timeline milestones added. 12 February 2027 (member states notify penalty rules, Article 68); 12 February 2028 (empty-space calculation-methodology implementing act, Article 24(2)); 12 February 2029 (reusable-packaging marking, Article 12(2)); 1 January 2029 (deposit-return systems for single-use beverage containers).
Recycled-content exemptions listed precisely. Contact-sensitive packaging is generally in scope of the Article 7 targets; the exemptions are the specific categories in Article 7(4) and 7(5) (certain medicinal, medical-device and infant-food packaging, compostable packaging, dangerous-goods transport packaging, and plastic parts under 5% of a unit's weight).

The corrections were applied to the guides, the free check, and the paid report in every language it is offered in.

Why we keep this page. The whole value of a screening that cites the regulation is that it holds up when someone opens the source and checks. That only works if we correct mistakes in the open rather than quietly. If you bought a report before a correction above and want to know whether it affected your result, get in touch and we will tell you.