PPWR ObligationsEU Reg. 2025/40

Packaging EPR by EU country

The PPWR product rules, restricted substances, recyclability, recycled content, labelling, are identical in all 27 EU states, because a Regulation applies directly (Art. 4). What changes country to country is the extended-producer-responsibility administration: where you register, the PRO and its fees, whether you need an Authorised Representative, and the small-quantity threshold. Tick the countries you sell into to see what each one asks of you.

Registration is national, not EU-wide. Under Article 44 you must register in the producer register of each member state where you first make packaging available. Under Article 45(3), a producer that makes packaging available in a state where it is not established must appoint an Authorised Representative for EPR in that state, in force from 12 August 2026. It is narrower than it is usually described: Article 45(3) reaches only producers within Article 3(1)(15)(c) and (d), and both of those turn on supplying directly to end users. Sell to a reseller who passes the goods on unchanged and you are not caught by it. The second sentence of Article 45(3) is separate: it lets each member state decide whether to require a representative from producers established outside the EU more generally, so that part is a national question. A proposal to suspend Article 45(3) until 2035, COM(2025) 982, has stalled: the Council ended negotiations on it in April 2026 and left it out of its June 2026 mandate and Parliament's rapporteur has proposed cutting it back to micro and small firms. It applies today and we would not plan on that changing.

Penalties are set nationally (Art. 68), there is no EU-wide fine; member states must lay down their penalty rules by 12 February 2027. So the same packaging can carry very different registration steps, fees and enforcement depending on the market.

The fourteen country cards below were checked against each country's national law on 29 September 2026. This is general information about Regulation (EU) 2025/40 and national EPR schemes, not legal advice. Thresholds, fees, penalty amounts and go-live dates come from national law and PRO schedules that change, treat every figure as needing a fresh check, and confirm anything you act on with the national authority or qualified counsel.

Which EU countries do you sell into?

Tick a country to see its packaging-EPR requirements below. Countries in bold have a detailed per-country page.

Tick one or more countries above to see what packaging EPR requires in each.

Do you actually have to file in these countries?

Most of what is written about this assumes the answer is yes in every market. Often it is not. Three questions decide it, and the third one is the one that matters.

In the countries you ticked above, who do you supply?
Which packaging are you asking about?

Free, and no email needed for the counts.

This is a screening of what you have told us against published national requirements, with the question that decides it made explicit. It is not legal advice and it is not a conformity assessment. Confirm anything you act on with the national authority or qualified counsel.

How to read this

For each country the card shows the producer register / authority you sign up with, the PRO (Producer Responsibility Organisation / compliance scheme) you contract with, whether a non-established producer needs an Authorised Representative, the de-minimis threshold (the small-quantity floor, where one exists), and the one catch worth knowing. The Authorised Representative line reads Yes, for every non-established producer where national law requires one from everyone not established there, EU or non-EU (France and Spain), and Only if you sell direct to end users where national law adds nothing broader than Article 45(3); the note under it gives the national detail. Where national law leaves a point open, or we could not trace it to the primary text, the card says so and names who to confirm with; do not treat those as settled.

Thirteen member states do not yet have a detailed page here. For those, the same cross-cutting rules apply: a national producer register (Art. 44), and an Authorised Representative wherever you supply end users directly in a state where you are not established (Art. 45(3), since 12 August 2026). Each of them may also require a representative from non-EU producers more broadly under the second sentence of Article 45(3), so confirm the current authority, threshold and AR position with the national scheme. The fourteen detailed countries below carry per-country pages: Germany, France, Italy, Spain, the Netherlands, Belgium, Poland, Austria, Ireland, Sweden, Portugal, Czechia, Denmark and Romania.

Sources