Companies selling packaged goods across European Union borders face new registration and extended producer responsibility (EPR) requirements under the bloc’s Packaging and Packaging Waste Regulation (PPWR), which began applying on 12 August 2026.
The rules require producers to register in member states where they place packaging or packaged products on the market and, in certain cross-border sales situations, appoint an authorised representative to fulfil their EPR obligations.
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While the PPWR establishes a common EU framework for packaging, companies operating across multiple markets can still face national registration, reporting and waste-management requirements.
The additional administrative and financial burden has raised concerns among small and micro businesses, particularly online sellers operating across several EU countries. The European Commission has proposed changes that could ease some of these requirements.
Cross-border sellers face new EPR requirements
The PPWR entered into force on 11 February 2025 and began applying on 12 August 2026, replacing the EU’s previous Packaging and Packaging Waste Directive with directly applicable rules covering packaging throughout its lifecycle.
Its EPR provisions are particularly significant for companies placing packaged products on different EU markets.
Under the regulation, producers must register in the relevant member states where they first make packaging or packaged products available. They are also responsible for financing the collection, sorting and treatment of packaging waste associated with products they place on the market.
These obligations include registration, reporting and payment of EPR fees, with specific arrangements varying between member states.
Companies established in one EU member state that make packaging or packaged products available directly to end users in another member state can also be required to appoint an authorised representative for their EPR obligations.
As a result, businesses selling across several EU markets may need to manage multiple national registration and compliance systems despite operating under a common EU packaging framework.
The requirements have particular implications for smaller sellers. Euractiv reported that the EPR provisions apply broadly to packaged goods without a minimum sales threshold, raising concerns among businesses selling relatively small volumes across borders.
Small businesses warn of rising compliance costs
The new requirements have prompted concerns among small and micro businesses, particularly companies using online channels to reach customers in multiple EU countries.
Euractiv reported that a petition opposing aspects of the new EPR requirements had attracted more than 70,000 signatures. A European Commission consultation on the EPR rules also received more than 5,000 responses within two weeks, with most responses coming from small and micro businesses.
For smaller companies, the costs can extend beyond EPR fees. Businesses may need to complete registrations in multiple countries, work with national producer responsibility organisations and appoint authorised representatives where required.
Businesses have warned that these combined costs could make some cross-border sales commercially unattractive, potentially prompting smaller sellers to limit the countries in which they operate.
Online businesses are particularly exposed because they can sell to consumers across numerous EU markets without having a physical establishment in each country.
The Commission has also proposed a “pay-on-behalf” mechanism under which smaller companies could delegate certain EPR obligations to online platforms when selling across multiple markets. Businesses would, however, still bear the associated costs.
Commission proposes change to authorised representative rule
The authorised representative requirement is also the subject of a proposed amendment.
As part of its environmental omnibus proposals, the European Commission has proposed suspending the PPWR provision requiring EU-established producers to appoint an authorised representative when making packaging or packaged products available directly to end users in another member state. The proposed suspension would run until 1 January 2035.
The proposal has not yet changed the current requirement. It remains subject to the EU legislative process, with the European Parliament and member states considering the proposed amendments.
The Commission has described the suspension as a measure intended to reduce the burden on producers while work continues on a broader reform of the EU’s EPR system.
The issue highlights a potential tension within the PPWR. While the regulation aims to create a more harmonised framework for packaging across the EU, companies can still encounter different national systems for registration and EPR compliance.
For businesses operating across borders, determining which entity carries responsibility for packaging under each sales model will therefore be critical.
UK exporters also face new obligations
The requirements extend beyond EU-based companies. Businesses based outside the bloc can also be subject to PPWR and EPR obligations when placing packaged products on the EU market.
UK government guidance says UK exporters selling packaged goods to the EU need to comply with the PPWR and EU EPR rules, including registration with the relevant national authority in the EU country of sale.
For UK exporters, this means determining where they qualify as a producer, identifying the EU markets in which registration is required and establishing whether an authorised representative or producer responsibility organisation is needed.
The compliance challenge also extends beyond registration. The PPWR introduces wider requirements covering areas including packaging design, recyclability, recycled content, labelling and reuse.
Companies will therefore need to consider both their packaging specifications and the data required to demonstrate compliance.
Businesses selling across multiple EU markets may also need systems capable of tracking the quantities and types of packaging placed on each national market to support EPR reporting and fee calculations.
Companies face market-by-market compliance task
The PPWR is intended to reduce packaging waste and create more consistent requirements across the EU. For companies selling packaged products across borders, however, the immediate challenge is navigating the national systems through which EPR obligations are implemented.
Until any changes to the authorised representative provisions are adopted, businesses will need to assess their registration, EPR and representation obligations in each relevant market.
For cross-border sellers, ensuring the correct entity is registered, the appropriate EPR arrangements are in place and the required packaging data is available will be central to maintaining access to EU markets.
