Who must register for packaging EPR in Ireland, and how

Reviewed against S.I. No. 282 of 2014 and Repak's 2026 membership documents on 29 September 2026. This is general information about Regulation (EU) 2025/40 and Ireland's national EPR scheme, 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.

The register and what it involves

The system runs on the European Union (Packaging) Regulations 2014 (S.I. No. 282 of 2014), enforced by local authorities, with policy at the Department of Climate, Energy and the Environment. There is no single national online producer register. Major producers must be members of an approved body, and Repak is Ireland's only one. Membership has been compulsory for major producers since 1 January 2023, when amending regulations removed the option to self-comply under local-authority oversight.

Joining Repak is via Regular Membership (fees based on the amount and type of packaging you place on the market) or Scheduled Membership (a flat annual fee based on audited turnover, with no packaging statistics to record; not open to manufacturers or importers). Repak also has a separate application route for e-commerce and distance sellers located outside Ireland with no Irish VAT number. All producers, whatever their size, carry basic obligations: segregate packaging waste by material, arrange recovery, and keep records.

De-minimis: the major-producer test

A “major producer” has annual turnover greater than €1 million (excl. VAT) and places more than 10 tonnes of packaging on the Irish market per year, both conditions required (a cumulative “AND”). Below the threshold you are not a major producer (no Repak membership duty) but still carry the basic segregation and record obligations. Do not treat the 10 t / €1m test as permanent under the PPWR: it is expected to go as Ireland aligns its scheme with the Regulation, which would bring smaller producers into full EPR.

The Authorised Representative rule

Irish packaging law does not add a representative requirement of its own. S.I. No. 282 of 2014 mentions a manufacturer's authorised representative only for heavy-metal reporting, and we found no provision requiring one for packaging EPR. A foreign distance seller joins Repak directly. Repak's own authorised-representative service covers WEEE and batteries, not packaging, and Repak is closing it at the end of 2026.

The EU rule is what can require a representative. Since 12 August 2026, Article 45(3) of Regulation (EU) 2025/40 has required a producer that makes packaging available directly to end users in a member state where it is not established to appoint an authorised representative for EPR there. That includes EU-based sellers shipping to Irish consumers from another member state. If you supply Irish retailers who resell your goods unchanged, you are not the producer in Ireland and Article 45(3) does not reach you. Its second sentence lets each member state go further for producers established outside the EU; we found no Irish measure doing so. A proposal to suspend Article 45(3) until 2035, COM(2025) 982, stalled when the Council ended negotiations on it in April 2026 and left it out of its 24 June 2026 mandate, so the rule applies now. Confirm the practical route with Repak.

Reporting and penalties

Repak Regular Members report twice a year, packaging tonnages by material: in August for January to June, and in February for July to December of the previous year. Scheduled Members pay a flat fee and file no statistics. Breach is a criminal offence enforced by local authorities: on summary conviction, a fine (local authorities quote up to €3,000) and/or up to 12 months' imprisonment; on conviction on indictment, a fine of up to €500,000 and/or up to 3 years (S.I. 282/2014). Penalties for breaching the PPWR itself are for each member state to set under Article 68, with national rules due by 12 February 2027. Drinks containers in Ireland's deposit return scheme, Re-turn, are handled separately from Repak.

How onerous is it?

Moderate. For a major producer the mechanics are straightforward (Repak handles compliance) but require twice-yearly weight-by-material data and variable fees. A seller based outside Ireland that ships to Irish consumers joins Repak directly and, under Article 45(3), also needs an authorised representative.

Frequently asked questions