Product regulation and compliance update series

European Commission publishes guidelines on the implementation of the Packaging and Packaging Waste Regulation

On 30 March 2026, the European Commission published guidelines on the application of the Packaging and Packaging Waste Regulation (PPWR). The document is intended to facilitate the uniform implementation of the new rules across the EU, reduce administrative burdens, and support businesses and Member States in fulfilling their obligations under the Regulation.

Context

The PPWR came into force on 11 February 2025 and aims to reduce the growing volume of packaging waste, harmonise rules across the single market, an create the conditions for sustainable packaging systems.

Key principles

• clarification of the definitions of packaging, producer and importer, and the rules for their identification;
• clarification of the rules for applying bans on single-use packaging and materials containing PFAS from 12 August 2026;
• interpretations regarding the mandatory recyclability of packaging and the timetable for the application of design requirements;
• guidance on reuse targets and the operation of deposit-refund schemes;
• labelling rules – full harmonisation of regulations and a ban on maintaining parallel national systems;
• a discussion of exceptions, including for compostable packaging and non-standard transport packaging.

Entities covered by the PPWR

The PPWR covers a wide range of entities involved in the packaging life cycle, in particular producers of packaged products, importers, where they are the first to place packaging or packaged products from third countries on the EU market, and distributors, where they are the first to make packaging or packaged products available on the market of a given Member State.

Next steps

The Commission will translate the guidelines into all EU languages before their formal adoption. Work is also underway on delegated and implementing acts concerning, among other things, recyclability, reporting, labelling, recycled content and assessment criteria.

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Council of the European Union adopts an amendment to the Regulation on CO₂ emissions from heavy-duty vehicles

On 30 March 2026, the Council of the European Union formally adopted a targeted amendment to the Regulation on CO₂ emission standards for heavy-duty vehicles. The new rules introduce temporary flexibility in the calculation of emission credits to help manufacturers meet the 2030 emissions reduction target, without compromising the EU’s long-term climate goals.

Context

The amendment is part of the automotive package presented on 16 December 2025, designed to support the transport sector’s transition towards clean mobility.

Key principles

• introducing temporary flexibility for the period 2025-29, allowing manufacturers to accumulate emission credits based on achieving individual emission levels, rather than following a more restrictive linear reduction path;
• encouraging manufacturers to introduce zero-emission heavy-duty vehicles earlier;
• the amendment primarily concerns heavy-duty vehicles over 16 tonnes and certain categories of buses over 7.5 tonnes;
• monitoring the use of geographical indications on the market, including responding to infringements of protection in the meaning of Articles 40 and 41 of Regulation 2023/2411 and issuing decisions prohibiting the further placing of the product on the market;
• maintaining the existing reduction targets: 15% from 2025, 43% from 2030, and 90% from 2040.

Entities covered by the amended Regulation

The amended Regulation primarily apply to manufacturers of heavy-duty vehicles, including lorries, buses and coaches, who are responsible for meeting the emission reduction targets.

Next steps

The amended Regulation will be published in the Official Journal of the EU and will enter into force 20 days later. It will be directly applicable in all Member States. A review of the rules on CO₂ emission standards for heavy-duty vehicles has also been announced for  2027, which may result in further legislative adjustments.

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Second draft of the bill amending the Act on Waste Electrical and Electronic Equipment, the Act on Vehicle Recycling, and the Act on Waste and Packaging Management

On 18 March 2026, the second draft of the bill aimed at amending the provisions on waste electrical and electronic equipment (WEEE), vehicle recycling, and waste and packaging management was published on the Government Legislation Centre’s website.

Context

The draft fulfils the obligation to implement Directive 2024/884, amending Directive 2012/19/EU on WEEE, following the CJEU judgment in Case C‑181/20, which found that the provisions concerning PV panels and their retroactive inclusion in waste management costs were flawed. The deadline for transposing the Directive expired on 9 October 2025.

Key principles

• alignment of the Act on WEEE with Directive 2024/884 by amending the cut-off dates for determining waste management financing obligations;
• maintaining the existing division of responsibility for ‘new’ and ‘old’ equipment, with a date adjustment to minimise the risk of retroactive charges on producers and a clarification of the financing rules in Articles 18 and 19 of the Act on WEEE;
• introducing provisions into the Act on Vehicle Recycling specifying the conditions under which parts removed from vehicles and sent for reconditioning do not constitute waste, together with the specification of transport and documentation requirements;
• expanding the legal framework to include the institution of an authorised representative in the Act on Packaging and Packaging Waste Management and in the Act on Vehicle Recycling, with the option (or, in the case of non-EU entities, the obligation) to fulfil the obligations of the importer through a representative;
• amending also the Waste Act by adding registration and record-keeping obligations relating to the operation of authorised representatives and updating the scope of data in the Database on Products, Packaging and Waste Management.

Entities covered by the bill

The changes primarily concern importers of electrical and electronic equipment,  particularly those who have previously imported PV panels or equipment not listed in Annex 6.

Entities from outside Poland and the EU importing packaged products should also pay particular attention, as they will be required to appoint an authorised representative.

Next steps

Pursuant to the bill, the amended Act will enter into force 14 days after its publication, with the exception of the provisions concerning the mandatory appointment of an authorised representative by entities from outside the EU and the accompanying provisions, which are to apply from 1 January 2027.

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Safety Gate 2025: record number of warnings and strengthened supervisory measures in the EU

On 5 March 2026, the European Commission published its annual report on the functioning of the Safety Gate system in 2025. The number of notifications concerning dangerous products reached its highest level since the system was launched, reflecting the intensified activities of national authorities and the strengthening of the legal framework for product safety.

Context

Safety Gate is an EU early warning system enabling the rapid exchange of information on dangerous non-food products between market surveillance authorities in Member States

and the EEA. The General Product Safety Regulation has modernised the supervisory framework, whilst the obligation for online platforms to register with the system has increased the effectiveness of measures in the online environment.

Key information from the report

• 4,671 alerts were reported – a 13% increase compared to 2024 and more than double the figure for 2022;
• market surveillance authorities carried out 5,794 follow-up actions, including product recalls, border detentions and the removal of offers from online platforms;
• the most frequently reported product groups were: cosmetics (36%), toys (16%), and electrical appliances and equipment (11%);
• over 53% of warnings concerned the presence of hazardous chemicals (including BMCHA in cosmetics and TPO in nail varnish);
• online monitoring tools detected over 20,800 dangerous products in online listings after scanning 1.6 million websites;
• the modernisation of EU regulations (including Regulation 2023/988 and the new Toy Safety Regulation) has increased the effectiveness of removing dangerous products from the market.

Entities mentioned in the report

The report primarily concerns manufacturers, importers and distributors of consumer products, in particular cosmetics, toys and electrical equipment, which accounted for the largest proportion of notifications.

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March reports from the Trade Inspection Authority

Below we present selected information on the Trade Inspection Authority (IH) inspection reports published last month on the website of the Office of Competition and Consumer Protection (UOKiK).

Information on the prices of goods and services

The results of the IH’s inspections concerning the correct display of prices of goods and services have been published on the UOKiK website. The inspections were carried out in 2025 by provincial IH inspectorates across Poland. A total of 3,026 businesses were inspected, including retail outlets, service providers, petrol stations, car parks and businesses providing hotel services. A total of 461,437 products were checked, including 5,252 products offered at reduced prices.

Findings of the inspections:

• 1,462 businesses (48% of those inspected) were found to have various types of irregularities;
• it was established that the irregularities concerned 60,001 products (13% of those inspected), and these included the absence of unit prices for products, incorrect calculation of the unit price, the absence of a price list for services, calculating discounts in relation to a price other than the lowest price from 30 days before the reduction, and the absence of information regarding the lowest price from 30 days before the reduction.

Consequences of the inspections:

• in the case of 73 businesses, the IH refrained from imposing a penalty due to the negligible harm caused by the offence or the implementation of corrective measures;
• 899 administrative decisions were issued imposing financial penalties totalling PLN1,204,194 and some administrative proceedings are still ongoing. 

Labelling of fruit and vegetables with the country of origin

The results of the IH’s inspections concerning the labelling of fruit and vegetables with the country of origin have been published on the UOKiK website. Inspections were carried

out in 2019-20 by the IH on behalf of the President of the UOKiK in retail outlets across Poland, and recently in 2026 IH staff have again verified whether labelling errors persist.

In total, hundreds of shops belonging to the largest chains and thousands of batches of products were inspected.

Findings of the inspections:

• according to data from the 2019–2020 inspections, the systemic nature of errors in country-of-origin labelling affected 30-40% of outlets belonging to the largest chains;
• following the actions of the President of UOKiK, further inspections by the IH revealed a clear positive effect: the scale of irregularities in 2025 has fallen to below 1% of product batches.

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