Who must register for packaging EPR in Ireland, and how
Ireland has no single national online producer register. A “major producer” — turnover over €1 million (excl. VAT) and more than 10 tonnes of packaging a year (both conditions) — must join the approved body, Repak (Ireland's only one, mandatory since 1 January 2023). A non-Irish distance seller must appoint an Irish-resident Authorised Representative. The 10 t/€1m threshold is expected to be phased out under PPWR.
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.
| Register / authority | No single online register; major producers join the approved body (Repak) |
|---|---|
| PRO / compliance scheme | Repak (Ireland's only approved body) |
| Authorised Representative | Yes Required for non-established producers |
| De-minimis threshold | “Major producer” test: turnover > €1m AND > 10 t packaging/yr |
| National instrument | the European Union (Packaging) Regulations 2014 (S.I. No. 282 of 2014) |
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 (mandatory since 1 January 2023; the former self-compliance option was removed for major producers).
Joining Repak is via Regular Membership (fees calculated from amount and type of packaging) or Scheduled Membership (fixed annual fee by turnover, no packaging statistics). 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. The 10 t/€1m threshold is expected to be phased out under PPWR — do not treat the exemption as permanent.
The Authorised Representative rule
The 2014 Regulations define an authorised representative as a person established in the State appointed by written mandate by a producer established in another member state. A non-Irish distance seller with no Irish establishment must appoint an Irish-resident AR — Repak operates an Authorised Representative Service.
Reporting and penalties
Repak Regular Members report twice a year — packaging tonnages by material: H1 (Jan–Jun) by 21 August; H2 (Jul–Dec) by 21 February the following year. Scheduled Members pay a flat fee and file no statistics. Breach is a criminal offence enforced by local authorities — summary conviction fines up to €3,000 and/or up to 12 months; conviction on indictment up to €500,000 and/or up to 3 years. A Deposit Return Scheme (“Re-turn”) launched 1 February 2024, separate from Repak.
How onerous is it?
Moderate. For a major producer the mechanics are straightforward (Repak handles compliance) but require bi-annual weight-by-material data and variable fees; a foreign producer additionally needs an Irish-resident Authorised Representative.
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Get my full PPWR obligations report →Frequently asked questions
What is a “major producer” in Ireland?
A producer with annual turnover greater than €1 million (excl. VAT) AND placing more than 10 tonnes of packaging on the Irish market per year. Both conditions are required. A major producer must join Repak; below the threshold you are not a major producer but still carry basic segregation and record duties.
Is Ireland's 10-tonne threshold permanent?
No — it is expected to be phased out under PPWR, bringing smaller producers into mandatory EPR (reported around August 2026, with component-level data from 2027). Do not treat the exemption as permanent.
Do foreign sellers need an Authorised Representative in Ireland?
Yes — a non-Irish distance seller with no Irish establishment must appoint an Irish-resident authorised representative, appointed by written mandate. Repak operates an Authorised Representative Service.
Sources
- Repak — FAQ, the major-producer test and mandatory membership — https://repak.ie/about-us/faq/
- S.I. No. 282 of 2014 — the European Union (Packaging) Regulations 2014 — https://www.irishstatutebook.ie/eli/2014/si/282/made/en/print
- The 10-tonne threshold's expected removal under PPWR — https://www.pincvision.com/news/no-more-10-tonne-threshold-for-packaging-epr-in-ireland