Packaging EPR Representative in the EU: Rules since 12 August 2026

Short answerSince 12 August 2026, the Packaging and Packaging Waste Regulation (EU) 2025/40 (PPWR) applies in every EU country. The producer is the company that first makes packaged goods available in a country (Article 3(1), point (15)). It registers there for producer responsibility (extended producer responsibility, EPR). A producer established in another EU country appoints an authorised representative in each country where it sells directly to end users (Article 45(3)). For producers from outside the EU, each country can require one, and Germany asks for a representative in Germany. Your own Dutch company covers the Netherlands as importer and producer.

What applies since 12 August 2026

The PPWR replaces the Packaging Directive 94/62/EC. It applies directly in all 27 EU countries, with one set of packaging rules for the whole single market. These duties apply today:

Declaration of conformity. Each packaging type needs proof that it meets the requirements, with technical documentation and evidence from the supplier.
Substance limits. Food-contact packaging stays below the PFAS limits, and the heavy-metal limits still apply.
Name on the packaging. Packaging shows the name, registered trade name or trade mark and a postal address of the manufacturer and, where relevant, the importer.
Producer registration. Producers register for producer responsibility in each EU country where they first make packaging available.
Authorised representative. A producer established in another EU country that sells directly to end users appoints an authorised representative for producer responsibility in that country (Article 45(3)). For producers established outside the EU, each country can require one.
Reuse systems. A company that places reusable packaging on the market has a system for collection, cleaning and redistribution.

The packaging representative per country

Where you sell to end users	Who is the producer	What you arrange
The Netherlands, from stock that your Dutch company imports	Your Dutch company	Your Dutch company registers itself in the Netherlands, where Verpact manages the packaging scheme.
Another EU country, with direct sales to end users	Your company, as the seller	An authorised representative in that country, through a partner
Germany, with direct sales to end users	Your company, as the seller	A representative established in Germany and a registration in the German packaging register LUCID, through a partner

One registration covers one country. Selling packaged goods directly to consumers in ten EU countries means ten registrations.

Germany: a representative in Germany

Germany applies the PPWR with its own packaging law (VerpackDG). A producer established outside Germany that counts as a producer under this law appoints a representative in Germany. These rules took effect together with the PPWR on 12 August 2026. Producers register in the packaging register LUCID, which the central packaging agency (ZSVR) manages (WKO, October 2026).

For a seller from the UK, the US or Asia, the German representative comes through a partner in Germany. We choose that partner with you, and you see the price first.

What marketplaces check

Online marketplaces ask producers for their producer responsibility details before they let them sell in a country (PPWR, recital 132). They check the registration for each country. Listings with a missing or invalid registration can be suppressed, so arrange the registrations before you list in a new country.

The same marketplaces show your EU responsible person for product safety in each listing. See EU responsible person for Amazon sellers and services for Amazon sellers in Europe.

Your own Dutch company covers the Netherlands

When your Dutch company imports your goods and first makes them available in the Netherlands, it is the producer there. It registers itself in the Netherlands, where Verpact manages the packaging scheme. Above 50,000 kg of packaging a year, it declares the packaging to Verpact and pays the waste management contribution (business.gov.nl, 2025). This threshold applies for now. It ends at the latest when producers first report to the new producer register under the PPWR, which Verpact expects before the second quarter of 2028 (Verpact, September 2026).

For direct sales to end users in other EU countries, your Dutch company appoints an authorised representative in each of them, through a partner. The same company is your importer at customs, applies for the Article 23 licence for import VAT and can be the responsible operator for product safety (GPSR). See all EU representative roles per product.

In December 2025, the European Commission proposed to pause the representative duty of Article 45(3) for producers established in the EU until 1 January 2035. The same proposal covers batteries. For producers from outside the EU, the representative rules stay in place. This is still a proposal in October 2026. If it passes, a producer established in the EU may choose whether it appoints representatives in other EU countries.

Batteries, electrical equipment and textiles

Batteries. Producer responsibility under the Batteries Regulation (EU) 2023/1542 applies since 18 August 2025, also for batteries built into products. A producer that sells batteries directly to end users in another country appoints an authorised representative there.
Electrical and electronic equipment. The WEEE Directive 2012/19/EU works per country in the same way, with a registration in each country of sale.
Textiles and footwear. Directive (EU) 2025/1892 asks every EU country to have a producer responsibility scheme by 17 April 2028. Distance sellers from another EU country or from outside the EU count as producers there. A seller from another EU country appoints a representative there, and each country can ask the same of sellers from outside the EU.

The timeline ahead

The PPWR adds duties in steps. Recyclability classes and packaging minimisation start in 2030. Bans on some single-use packaging formats apply from 1 January 2030 (Article 25 and Annex V). The first recycled-content minimums for plastic packaging apply from 1 January 2030 at the earliest (Article 7). Harmonised labels for consumers follow once the European Commission adopts its implementing acts. Reuse targets start in 2030 and rise in 2040, and the recycled-content minimums also rise in 2040. From 2035, packaging must be recyclable in practice, in large volumes.

Your next steps

List every packaging type you place on the EU market, and collect the evidence from your suppliers for the declaration of conformity.
Check your registration in each EU country where you sell to end users, and appoint a representative where the rules ask for one. For Germany, choose a representative established in Germany.
Decide where your EU company belongs. With a Dutch company, packaging, VAT and customs are in one company. See EU market entry and Article 23 and fiscal representation.

Sources

Regulation (EU) 2025/40 on packaging and packaging waste (PPWR), Official Journal of the EU (2025): the legal text, with Article 45 on authorised representatives, the application dates in Article 71, and recitals 123 and 132.
European Commission, packaging waste: the implementing acts and guidance as they are published.
European Commission, guidance document for Regulation (EU) 2025/40, Commission Notice C/2026/3084 (2026): the definition of producer, the date of application and the dates for recyclability, labelling and the packaging bans.
European Commission, PPWR frequently asked questions (2026): the general date of application and the dates for recycled content.
Commission proposal COM(2025) 982 (10 December 2025): the proposal to pause Article 45(3) for producers established in the EU until 1 January 2035, for packaging and batteries.
WKO, PPWR in Deutschland (October 2026): the representative in Germany, the VerpackDG and the LUCID register.
business.gov.nl, packaging waste management contribution (checked September 2025): producers and importers above 50,000 kg of packaging a year pay the contribution to Verpact, also companies abroad that sell online to Dutch consumers.
Verpact, PPWR en microondernemingen (September 2026, in Dutch): the threshold of 50,000 kg a year applies for now, until the first report to the new producer register.
Regulation (EU) 2023/1542 on batteries and waste batteries, Official Journal of the EU (2023): producer responsibility and the authorised representative.
Swedish Environmental Protection Agency, producer responsibility for battery producers (September 2025): the rules since 18 August 2025, also for batteries built into products, and the authorised representative.
Directive (EU) 2025/1892 amending the Waste Framework Directive, Official Journal of the EU (2025): Articles 3 and 22a, with producer responsibility schemes for textiles and footwear by 17 April 2028.

Last reviewed: October 2026.

Your packaging registrations, arranged

We set up your Dutch company and register it as producer in the Netherlands. For the other EU countries and for Germany, a partner takes the representative role. You see every price first and have one contact person on our team. We are an independent Dutch firm.

Want our team to have a look? → All EU representative roles per product · Services for Amazon sellers in Europe

Frequently asked questions

Does a seller from outside the EU need a packaging EPR representative?

In many cases, yes. Since 12 August 2026, a seller that ships packaged goods directly to end users in an EU country is the producer there and registers in that country. Each country can ask producers from outside the EU for an authorised representative, and Germany does. Your own Dutch company can be the producer itself: it registers in the Netherlands and appoints a representative in each other country where it sells directly to end users.

Does the packaging representative for Germany have to be in Germany?

Yes. A producer established outside Germany that sells packaged goods to end users in Germany appoints a representative in Germany. The producer registers in the German packaging register LUCID. These rules took effect together with the PPWR on 12 August 2026.

Do marketplaces check packaging registrations?

Yes. Online marketplaces ask producers for their producer responsibility details before they let them sell (PPWR, recital 132). Listings with a missing or invalid registration can be suppressed, so arrange the registrations before you list in a new country.

Can my own Dutch company cover packaging EPR?

Yes, for the Netherlands. When your Dutch company imports your goods and first makes them available in the Netherlands, it is the producer there and registers itself. For direct sales to end users in other EU countries, it appoints an authorised representative in each of them (Article 45(3)), through a partner.

Which PPWR rules apply since 12 August 2026?

The PPWR applies directly in all 27 EU countries. Packaging needs a declaration of conformity and must meet the substance limits, such as the PFAS limits for food-contact packaging. Packaging shows the name and postal address of the manufacturer and, where relevant, the importer. Producers register for producer responsibility in each country where they first make packaging available.

Do batteries and textiles follow the same model?

Yes. Producer responsibility for batteries applies since 18 August 2025. A producer that sells batteries directly to end users in another country appoints an authorised representative there. For textiles and footwear, every EU country has a producer responsibility scheme by 17 April 2028, and distance sellers from other countries count as producers there.

What PPWR deadlines follow after 2026?

Recyclability classes and packaging minimisation start in 2030. Bans on some single-use packaging formats apply from 1 January 2030, and the first recycled-content minimums for plastic packaging from 1 January 2030 at the earliest. Reuse targets start in 2030 and rise in 2040.