Topic

Packaging and extended producer responsibility

PPWR, per-member-state registration, authorised representatives and national EPR fees.

Extended producer responsibility is the clearest example of the EU’s split model: harmonised rules, national money. Regulation (EU) 2025/40 (PPWR) applies directly in all member states from 12 August 2026, but registration and fees remain national.

The practical consequence for a cross-border seller is arithmetic. Registration is owed in every member state where packaging is first made available, an authorised representative is required per member state where the seller is not established, and the compliance cost therefore scales with destination count rather than revenue.

What this topic covers: PPWR obligations and dates, EPR registration and mandates, packaging design and recyclability requirements, labelling acts, marketplace verification duties, and the parallel EPR regimes for textiles, batteries and WEEE.

Articles

• 14 Aug 2026The Commission says relief is coming for authorised representatives. It is a proposal, and it is narrower than it soundsReplying to angry small sellers on Instagram, the Commission points to its December 2025 proposal to suspend the authorised representative obligation until 2035. The proposal is real, still in committee, and covers producers established in the EU — not sellers outside it.
• 12 Aug 2026The regulation that arrives today: PPWR and the 27 registrations behind itRegulation (EU) 2025/40 applies from 12 August 2026. It harmonises packaging design and documentation across the EU — and leaves registration and fees national, which is where the cost lands for cross-border sellers.